Prairie Dog Component Review Draft 8/18/06
City of Boulder
Urban Wildlife Management Plan
Black-Tailed Prairie Dog Component
Board Review Draft
August 18, 2006
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Table of Contents
ExecutiveSummary 1
Introduction to the Urban Wildlife Management Plan5
PurposeandBackground 5
Vision, GoalsandGuidingPrinciples 6
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Scope and Process
Black-tailed Prairie DogManagement Component
Chapter1Introduction 11
Purpose and Objectives of the Prairie Dog Component11
Relationship to Other City Policies and Plans 11
PrairieDogBehaviorandEcology 13
Prairie Dog Management in the Urban Service Area 16
The Open Space and Mountain Parks Department’s Role
in ProtectingPrairieDogs 18
IntergovernmentalRelationships 21
CommunityPerspectivesandValues 23
Chapter2InventoryandAnalysis 27
Inventory 27
Analysis 31
Chapter 3 Management Classifications and Colony Plans 37
Chapter4Implementation 43
City Policy Development and Revision 43
Conservation Practices 48
Intergovernmental Relations 51
Prioritization ofActionItems 53
Appendices
Appendix A: Colony Plans
Appendix B: Evaluation of Management Tools
Appendix C: Policies and Procedures
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Executive Summary
The black-tailed prairie dog is an important part of the prairie grassland ecosystem that surrounds
Boulder. Where they occur, prairie dogs have far-reaching ecological effects upon the landscape.
Prairie dog towns provide habitat for several species and an abundant prey base for predators
such as ferruginous hawks, golden eagles, coyotes, bobcats, badgers and, historically, the
black-footed ferret. Their burrowing activities affect many plants and animals.
The city of Boulder has been in the practice of protecting and managing prairie dogs and
grassland habitat through its Open Space and Mountain Parks program (OSMP) since 1977.
Today, over 20,000 acres of grassland habitat is permanently protected from development and
5,000 of those acres are permanently dedicated as Habitat Conservation Areas (HCAs) for the
conservation of prairie dogs. Similarly, Boulder County has dedicated about 5,000 acres of
public land to the conservation of prairie dogs.Of the prairie dog habitat set aside by public
agencies in Colorado, the lands identified as prairie dog HCAs by the city of Boulder and
Boulder County may represent as much as 70% of the total.
Prairie dogs occur within the city primarilyalong the edges of protected open space and on
small, fragmented parcels. As colonies grow and deplete the resources on one site, they disperse
to other sites and establish new colonies. Prairie dogs will readily move from one site to adjacent
properties and forage on lawns and established landscaping. Prairie dogs can both cause damage
to landscaping and building infrastructure in the urban area and also be a safety hazard where
they occur on public park lands.
For the past 100 years, Boulder has been a national leader in both the protection of open space
and in creating urban growth boundaries and preventing urban sprawl. The city owns and
manages over 40,000 acres of land outside the city dedicated to open space and "greenbelt"
protection. The Boulder Valley Comprehensive Plan established strict growth and development
boundaries through its Area I, II, and III designations. While Area III is set designated
specifically for rural and open space preservation, Areas I and II are the areas designated for
human land use and development.
It is largely due to the protection of open space and the proximity of the greenbelt that certain
species of wildlife come into the city and inhabit the urban area. Wildlife management issues in
the urban area and surrounding natural lands are even more complex given the geographic setting
contiguous to hundreds of thousands of acres of county, state, and federally protected natural
lands.
Goals and Principles for Wildlife Management
The vision, goals, and guiding principles for wildlife management in Boulder are outlined on
pages 6 and 7 of the plan. In general, the city’s goals are to provide for the long-term ecological
sustainability of wildlife, while proactively reducing conflicts between humans and wildlife. The
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city’s goals and the plan support and recommend the protection of animal species, not individual
animals and emphasize humane, non-lethal control of wildlife whenever possible. The plan
recognizes the thousands of acres of natural land in the city’s open space system, as well as the
county’s system, and recommends the continued protection of prairie dogs in HCAs. The
objectives of the plan are to conserve prairie dog populations where possible in the urban service
areas and to remove them from urban areas where they conflict with other land uses and with
humans.
To this end, the plan provides future management direction for the 606 acres of prairie dogs in
the urban area only by designating sites within the urban area either for the protection or removal
of prairie dogs. (The plan does not include management plans for five acres of occupied land on
federal and state property in the service area.) Included in the plan are:
149 acres are designated for long-term protection of prairie dogs
361 acres are designated for interimprotection (and long-term removal)
96 acres are designated for near-term removal (these areas are those where prairie dogs
are most in conflict with regulationsand public services and facilities.)
Inventory, Management Classification, and Colony Reports
The prairie dogs located on these 611 acres were grouped into 20 different colonies or complexes
of colonies based on geographic connectivity. A colony report was developed for each of these
areas and summarizes the inventory information, site analysis, and management
recommendations for the site (see Appendix A). The plan does not specify which methods will
be used to remove prairie dogs from designated sites. Instead, the plan emphasizes the
application of the “Six-step” process that was reinforced through the adoption of the city’s
Wildlife Protection Ordinance in early 2005.
The “Six-step process involves the following decision-makingsteps for managing prairie dog
conflicts: (1) Minimize conflicts through non-removal methods; (2) Remove prairie dogs on
only a portion of a site; (3) Evaluate the potential for relocation; (4) Evaluate the potential for
donation to animal recovery programs (which can mean trapping and lethal control or live
transfer); (5) Evaluate the use of trapping and lethal control through carbon dioxide chambers;
and (6) If the above steps are not feasible, apply pesticides to the burrows. However, the plan
recognizes that relocation receiving sites are limited (especially as the city and surrounding
communities and counties continue to develop) and that lethal control will need to be used to
remove prairie dogs and reduce conflicts with human land uses in certain circumstances.
The city has 5,000 acres of HCAs within its OSMP system. When all of these acres are taken in
aggregate, these HCAs are 66% occupied by prairie dogs. As part of the city’s Grassland Plan,
appropriate occupancy rates will be established for these areas. However, it is important to note
that an optimal level of occupancy for these species is considered to be 20%.
Management Tools
The UWMP evaluates the costs and benefits of various management tools to protect and/or
remove prairie dogs on individual sites. These management tools most likely will need to be
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used in combination or “packages.” The city will emphasize the use of relocation as the primary
means of removing prairie dogs from sites designated for removal in the plan. However, the plan
and the “Six-step process” also recognize thatrelocation receiving sites will not always be
available and lethal control will sometimesbe required to remove prairie dogs and reduce
conflicts with human land uses. In these cases, trapping and gassing through the use of CO
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chambers will be the preferred method of lethal control.
Costs
Urban prairie dog management will continue to be a part of the city’s business costs. It may be
less of a priority in some years than others; however, it will continue to cost thecity of Boulder
time and resources. All management tools cost money. Although the use of burrow fumigants is
the by far the least costly tool, it is also the least humane and is not a recommended technique for
managing prairie dogs. Even with the use of lethal control as a method of removal for prairie
dogs management costs for the next two years (2007-2008) will be in the range of $160,000 to
$275,000 (not including staff time). Without a better balance and use of all methods available for
prairie dog mitigation and removal, these costs will continue to be significant.
Implementation
Because of the city’s location surrounded by thousands of acres of open space and wildlife,
management of urban wildlife and especially prairie dog conflicts will be an ongoing activity for
the city organization. The plan identifies several short and long-term actions (see page 53-54) to
implement the plan and to take a proactive approach to addressing urban wildlife conflicts and to
help maintain an acceptable balance between the presence of wildlife in the city and human land
uses. Some of the specific short-term action items that staff recommends include the following:
1.Develop amendments to Resolution #842 for Council consideration.
2.Review the Wildlife Protection Ordinance and make recommendations to City Council
on possible amendments.
3.Work with CDOW and develop recommendationsto address inconsistencies in the state’s
relocation policies and permitting.
4.Complete the OSMP Grassland Plan and establish ecologically based standards on
relocation and carrying capacity for Open Space grasslands.
As part of the UWMP, options are being evaluated on the most effective and efficient way to
staff and resource wildlife management. These options will be presented to City Council for
consideration prior to the submission of the 2008 budget. One option being evaluated is a
potential “merge” of the city’s wildlife management staff and resources from the various
departments dealing with natural resource management. In the interim, it is recommended that
the staff team participating in the developmentof the UWMP begin implementation of the short-
term action items.
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Introduction to the
Urban Wildlife Management Plan
Purpose and Background
The purpose of the Urban Wildlife Management Plan (UWMP) is to establish a vision, guiding
principles, and protocols for the management of wildlife in the city of Boulder.
Boulder is situated at the base of the foothills of the Rocky Mountains where the Great Plains
mixed and short grass prairies meet the foothill shrublands and montane woodlands of the
eastern Rocky Mountains. As you enter the Boulder Valley, you witness the success of a long
history of planning and open space preservation when you see a compact and vibrant city
surrounded by a vast and diverse greenbelt.
Boulder began its long history of preserving land and natural systems by purchasing Chautauqua
Park in 1898. In 1967, a ballot initiative was passed to permanently increase the city sales tax to
buy, preserve, and maintain greenbelt land. This ballot initiative created our open space system.
Land acquisition and greenbelt protection continues today with the permanent protection of over
40,000 acres of open space and mountain parks surrounding the city.
With the protected system of natural lands surrounding a city, however, comes the conflicts
associated with living so close to wildlife. Bear, coyote, deer, fox, prairie dogs, and many other
species of wildlife do not recognize city boundaries and are commonly seen in the urban area
foraging for food or prey, lounging on someone’s deck, rummaging through dumpsters and trash
cans, or taking up residence in areas marginally suitable for wildlife habitat.
Boulder has a long history in wildlife management through its OSMP program, but until recently
the city has not focused on comprehensive management of wildlife within the urban area. The
attitude toward urban wildlife was generally “live and let live” unless conflicts arose between
residents and wildlife. If any wildlife posed a concern in the city, the issues were addressed on a
case-by-case basis.
Over the past decade, however, as the city builds out and vacant land becomes less common,
conflicts between wildlife and human uses of land have become more frequent. While residents
have learned to tolerate the conflicts posed by some species such as deer, the presence of other
animal species such as prairie dogs and bear pose problems that are less easily resolved through
education and tolerance. Many potential conflicts between human uses and wildlife need pre-
emptive planning and physical solutions to prevent or minimize harm to either wildlife or to
people.
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Although conflicts between wildlife and humans in the city have been addressed on a case by
case basis, there has not been a comprehensive policy statement or long-term plan for
management of wildlife in the urban area. Consequently, wildlife issues have generally been
addressed inconsistently and with a lack of clear policy and procedure. Most important, however,
the city has generally not been proactive in preventing potential conflicts which can result in
higher costs than that of preventive action. The lack of preventive action has sometimes resulted
in the use of lethal control which could have been avoided or minimized with better planning. In
addition, decision-making at the scale of individual properties and/or species is often difficult,
ineffective and inefficient.
The need for the UWMP became most evident over the past few years during the development of
the city’s Wildlife Protection Ordinance. Concerns were raised by Council during that process
about the need for a broader look at wildlife relative to urban land uses when making decisions
about the management of wildlife in specific areas or sites. Although Council adopted an
ordinance which outlines a policy for the use of lethal control on individual properties, it also
directed staff to begin the development of a plan that would allow us to look at and resolve issues
in a city-wide context.
The purpose of this plan is to understand the context, benefits and conflicts posed by urban
wildlife and to outline a plan for the management of individual species or groups of species.
Since most wildlife/human conflicts in the urban area occur out of the context of the natural
ecosystem of that species, most urban species management will be addressed on a species by
species basis. Where appropriate, the plan will address the management of species on an
ecosystem level. The UWMP will: 1) establishpolicies and procedures for managing wildlife
within the city on both public and private land, and 2) outline a set of actions for long-term
management of wildlife in the city.
Vision, Goals and Guiding Principles
Boulder’s Vision
In Boulder's urban areas, the city will endeavor to provide for diverse, self-sustaining, native
wildlife populations in numbers compatible with basic human needs, social and economic values,
and long-term ecological sustainability, while proactively reducing conflicts between humans
and wildlife.
Guiding Principles
The city will emphasize humane, non-lethal control of wildlife when consistent with
guiding principles 2-6 and the vision statement.
The urban area is primarily intended for the development and support of human land
uses and services as described in the Boulder Valley Comprehensive Plan.
The city will balance environmental, economic, and social sustainability principles in
managing urban wildlife.
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The community values and supports the protection of wildlife habitat and biological
diversity. Urban wildlife management should be compatible with an ecosystem
approach to land management.
The city will strive to use the best science in understanding and managing urban
wildlife.
The city will develop clear and easily understood standards, protocols and regulatory
processes for managing situations where conflicts arise between wildlife and urban
land uses.
Goals for the Urban Wildlife Management Plan
The UWMP will:
provide a clear and easily understood framework for balancing environmental, social,
and economic goals when managing wildlife on public and private lands;
prioritize effective strategies and assess the costs for sustainable, long-term
management of urban wildlife and its habitat;
establish wildlife management policies and practices that proactively reduce
human/wildlife conflicts, reflect overallcommunity values and sustain ecological
integrity;
set up a decision-making hierarchy to address wildlife conflict situations in urban
areas;
outline a set of strategies for providing on-going education and keeping the public
informed about current practices and policies;
integrate urban wildlife management across city departments and coordinate
management with other public jurisdictions and agencies; and
assess and inventory areas in the city with the greatest potential for conflict and
areas that provide the best opportunity for conservation.
Scope and Process
The geographic scope or study area of the UWMPincludes private and public land in the city’s
urban service area or Area I and Area II as defined in the BVCP. The study area for the UWMP
also includes some sites outside the urban service area where planned or existing human uses
may conflict with the presence of prairie dogs (e.g. the regional park site in the Planning
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Reserve, the dams at the Boulder Reservoir, the Valmont Butte, and the 75 St. Wastewater
Treatment Plant).
The plan was developed in two phases. The first phase of the plan involved the development of a
set of guiding principles for the management of wildlife in the city as well as a vision and set of
Phase I
goals for the plan. was endorsed by City Council in January of 2006. This policy
document will provide a framework to identify and prioritize future work including management
plans for species, groups of species and habitat types.
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Phase II
is the development of species-specific components to the plan, starting with the black-
tailed prairie dog component.
Staff team
City Manager’s Office
Stephanie Grainger, Deputy City Manager
Planning & Development Services
Bev Johnson, Environmental Planner
Open Space and Mountain Parks Department
Mark Gershman, Environmental Planner
Bryan Pritchett, Acting Visitor Plan Implementation Coordinator
Parks and Recreation Department
Jeanne Scholl, Conservation Manager
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Black-Tailed Prairie Dog
Management Component
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Introduction
Purpose and Objectives of the Prairie Dog Component
The purpose of the prairie dog management component is to identify prairie dog protection
opportunities in the urban service area and outline strategies for resolving short and long-term
conflicts in the urban service area. There are five primary questions that the plan seeks to
address:
Where in the city should prairie dogs be protected?
Where should they be removed?
How can we protect them (in place) and minimize conflicts?
How should we remove them if necessary?
How do we balance costs and humane treatment?
The above questions guided development of the following objectives of the component:
Develop an inventory and assessment of prairie dogs in the urban area.
Develop a framework for understanding the conflicts and compatibilities between
prairie dogs and human land uses.
Develop recommended management goals for each colony in the city.
Review techniques and strategies for meeting management goals and develop a
decision-making framework for either protection or removal of prairie dogs.
Identify costs and prioritize actions for plan implementation.
Relationship to Other City Policies and Plans
Boulder Valley Comprehensive Plan (BVCP)
The BVCP provides the overarching context and broad city policies for more detailed planning
which occurs through all other city planning efforts. The BVCP is a joint plan between the city
of Boulder and Boulder County, providing shared land use decision-making in the Boulder
Valley. The plan sets a course for the future growth and development in the city and the lands
just outside the city's boundaries. The plan is developed and adopted by four governing bodies
including: the city of Boulder Planning Board, the City Council, the Boulder County Planning
Commission, and the Board of County Commissioners.
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The BVCP was first adopted in 1970 has been one of the most important tools for managing
Boulder's growth by defining the desired land use pattern regarding location, type, and intensity
of development in the Boulder Valley.Area designations establish the framework for annexation
and service provision. Area I is the area within the city. Area II is the area planned for
annexation and service provision within the 15-year planning period. Areas I and II form the
city's Service Area. Area III-Rural Preservation Area includes lands designated to remain rural in
character. Area III-Planning Reserve is an area where the city and county intend to maintain the
option of expanded urban development beyond the planning period.
BVCP Policies Relevant to the Black-Tailed Prairie Dog Component of the
Urban Wildlife Management Plan
4.02AdaptiveManagementApproach.
The city will employ an adaptive management approach to resource protection and
enhancement. An adaptive management approach involves ongoing monitoring of
resource conditions, assessment of the effectiveness of managementactions, revision of
management actions based on new information from research, and learning from
experience what works and what does not.
4.06Natural Ecosystems.
The city and county will protect and restore significant native ecosystems on public and
private lands through land use planning, development review, conservation easements,
acquisition and public land management practices. The protection and enhancement of
biological diversity and habitat for federal endangered and threatened species and state,
county and local species of concern will be emphasized. Degraded habitat may be
restored and selected extirpated species may be reintroduced as a means of enhancing
native flora and fauna in the Boulder Valley.
4.12Management of Wildlife-Human Conflicts.
The city recognizes the intrinsic value of wildlife in both the urban and rural setting. The
city will practice wildlife management to minimize conflicts with residents and urban
land uses while identifying, preserving and improving appropriate habitat for wildlife
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species in the urban area. When a wildlife species is determined to be a nuisance or a
public health hazard, a full range of alternative wildlife management techniques will be
considered by the city and county in order to mitigate the problemin a manner that is
humane, effective, economical and ecologically responsible. The city recognizes the
benefit of coordinating wildlife and wildlife habitat management with other agencies and
that management plans should be formulated within a larger ecosystem framework.
Departmental Master and Resource Management Plans
The following departmental master and resource management plans provide guidance for the
UWMP:
Parks and Recreation Master Plan
Open Space and Mountain Parks
Long Range Management Policies
Grassland Ecosystem Management Plan
City Ordinances
In February of 2005, the Boulder City Council adopted an ordinance which establishes policies
and procedures for managing prairie dogs within the city. These ordinances provide a basis for
the development of the prairie dog component of the UWMP. The following is the list of
subsections from the Boulder Revised Code which have informed this plan:
Limitation on Lethal Means of Control for Prairie Dogs and Birds (B.R.C. 6-1-11)
Damaging Prairie Dog Burrows Prohibited (B.R.C. 6-1-12)
Killing Wild Animals Prohibited (B.R.C. 6-1-12): Prevents the killing of wild
animals that are protected by federal or state law.
Bird Protection Sanctuary Created (B.R.C. 6-1-33)
Use of Poison Restricted for Lethal Control of Birds (B.R.C. 6-1-34)
Injuring or Capturing Wild Birds Restricted (B.R.C. 6-1-35)
Procedures for Obtaining Prairie Dog Lethal Control Permits (B.R.C. 6-1-36)
Procedures Affecting the Relocationof Prairie Dogs (B.R.C. 6-1-37)
Fees and Requirements for Issuance of Prairie Dog Lethal Control Permits (B.R.C. 6-
1-38)
Special Permit (B.R.C. 6-1-39)
Prairie Dog Behavior and Ecology
Prairie dogs are ground dwelling members of the squirrel family. There are four species of
prairie dogs in the United States. The species that occurs in Boulder and throughout eastern
Colorado is the black-tailed prairie dog (Cynomys ludovicianus).
Black-tailed prairie dogs live in family groups known as coteries. A coterie is a contiguous,
territorial family group that is generally made up of one breeding male, three to four adult
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females and 6 or more yearlings and juveniles. Coterie territories are aggressively defended by
coterie members. Territory sizes vary and the area covered within the territory provides all the
resources needed by the coterie. Colonies consist of a number of coteries.
Prairie dogs build burrows as living quarters. Burrows consist of a series of underground tunnels
with several chambers and one or more entrances. At least one chamber is used as the nest or
nursery burrow. Burrow entrances are constructed in a way that provides protection from
predators, defense against weather and air circulation throughout the burrow. Burrows can be
shallow to the surface or more than 10 feet deep.
Unlike some other rodents, prairie dogs are not prolific breeders. Prairie dogs only breed once
per year, usually not until their second year and each female is fertile only for a day. Also, in
any specific breeding season only about half of the adult females in a colony produce young.
Litters are normally three to four pups, however,only about half survive their first year, mainly
due to infanticide. Breeding season begins in February, and in May, the young emerge from the
burrows. In the spring, there are tremendous social, physiological and evolutionary pressures on
year-old males to disperse.
Prairie dogs, unlike some other burrowing animals (e.g. pocket gophers), do not “travel”
underground. All dispersal and movement activities are above ground. In urban areas, barriers
such as roads, buildings, and parking lots significantly influence and limit dispersal.
Black-tailed prairie dogs’ diet varies throughout the year, but consists mainly of grasses in the
spring and summer and cactus and plant roots, in the fall and winter. Cannibalism among black-
tailed prairie dogs has also been observed; primarily infanticide by lactating females killing the
unweaned offspring of coterie mates. This most often occurs when mothers are out foraging and
the nursery burrow is left unprotected. When food resources are limited, mothers must spend
more time and go further away from the nursery burrow to forage. This provides greater
opportunities for infanticide to occur. Under these circumstances offspring survival may be
minimal. Dispersing males also cannibalize the young in coteries they are able to invade.
In order to detect and avoid predators, prairie dogs clip all tall vegetation. In these cases, they
may or may not consume the plants. They avoid areas of tall dense vegetation. Therefore, visual
barriers (that cannot be clipped) act as deterrents to colony expansion and dispersal. However,
since burrows typically have more than one opening, visual barriers that are not several feet
deep, can be breached, coincidentally, by normal burrowing activity.
Prairie Dogs in the Grassland Ecosystem Context
Black-tailed prairie dogs are an important species in functioning short and mid-grass prairies.
They are referred to as “keystone” species because of their influenceon the areas they inhabit.
Their feeding and clipping behavior alters the composition and structure of the vegetation of the
area. Their burrowing activities aerate the soil and bring sub-soils and minerals to the surface.
The burrows themselves provide homes to burrowing owls, rattlesnakes, rabbits, a variety of
insects, tiger salamanders and other wildlife. They serve as important prey for raptors, coyotes,
foxes, badgers and the endangered black-footed ferret.
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On large, intact, native grasslands, where the vegetation evolved with the prairie dogs, the plants
have adapted massive root systems to withstand long term “grazing” by prairie dogs and,
consequently, plant diversity is generally high. When resources become too limited on a
particular coterie territory, the territory may be abandoned with the coterie establishing a new
territory at the edge of the colony where there are adequate resources for natural distribution and
patches of grasslands are able to recover.
Plague
Plague is an infectious disease that was inadvertently introduced from Asia into the North
American prairie ecosystem around 1900. Its causative bacterium,Yersinia pestis, isfound in
fleas. In wild animals plague is generally referred to as sylvatic plague and it has been identified
in over 70 species of mammals in the United States. A significant number of these mammals
“carry” plague, but do not always succumb to it. Prairie dogs on the other hand are very
susceptible to sylvatic plague. Due to their social nature, entire prairie dog colonies can be killed
by plague in a matter of a few days.
Plague can be transmitted to humans by flea bites or by exposure to infected pets. There are two
types of plague that can occur in humans. Both are caused byYersinia pestis, but they are
transmitted differently and their symptoms differ. Pneumonic plague affects the lungs and is
transmitted when a person breathes in Y. pestis particles in the air (such as when an infected pet
sneezes). Bubonic plague is transmitted through the bite of an infected flea or exposure to
infected material through a break in the skin. Pneumonic plague can be transmitted directly from
person to person (e.g. coughing, sneezing, etc.); bubonic plague cannot.
Both types are rare, but bubonic plague is more common than pneumonic plague. According to
the Centers for Disease Control and Prevention (CDC), one to forty human cases in the United
States were reported annually(average = thirteen cases) by western states between 1971 and
1995. A CDC fact sheet points out, “The numberof human plague infections is low when
compared to diseases caused by other agents, yet plague invokes an intense, irrational fear,
disproportionate to its transmission potential in the post-antibiotic/vaccination era”. Colorado
Department of Public Health and Environment statistics indicate fifty-one human plague cases in
Colorado since 1957. Of those, only seven cases were directly linked to prairie dogs or other
rodents; one of those was fatal. If diagnosed early, plague can be cured and symptoms treated
with antibiotics.
Conflicts with Human Land Uses
Although an important species in native short and mid-grassprairies, prairie dogs are often
considered a nuisance in urban and agricultural environments. Due to the dispersal activities of
prairie dogs and the significant lack of predators in the urban environment, prairie dogs are often
in conflict with urban land uses. Prairie dogs can cause costly damage to agricultural crops,
landscaping, earthen dams, airports, and golf courses.
Historically, Colorado had over 27,000,000 acres of potential habitat for prairie dogs. However
the past 100 years, much of the historic range of the black-tailed prairie dog has been converted
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to agricultural, residential, industrial, and commercial land uses. In farmed ground prairie dogs
can decimate or destroy a crop of alfalfa, grains or hay. Around the turn of the century, the
United States government sponsored prairie dog poisoning programs to reduce competition with
livestock and farmers. This program, which continues today, peaked in Colorado in 1921 when
approximately 80,000 acres were poisoned.
Expanding urban areas, especially the rapidly growing Front Range in Colorado, has seen the
conversion of prairie dog towns into human land uses--as housing and commercial development
replaces grasslands. Urbanization along the Front Range has fragmented prairie dog colonies,
hemming the remaining animals into ever-smaller parcels.
Prairie dogs occur within the city primarilyalong the edges of protected open space and on
small, fragmented parcels. Prairie dog colonies are not static. As colonies grow and deplete the
resources on one site, they disperse to other sites and establish new colonies. Prairie dogs will
readily move from one site to adjacent properties and forage on lawns and established
landscaping. Sites within Boulder that are currently unaffected by prairie dogs may be affected
next year after the breeding season.
Vegetation on urban sites is generally non-native and plant diversity is low. Urban sites,
therefore, are less able to withstand constant foliage consumption by prairie dogs. Furthermore,
because the colonies are bounded by either unsuitable habitat or no habitat at all (roads), coteries
are restricted to their current locations for extended periods of time. Prairie dogs do not
hibernate and, therefore, their impacts to the vegetation are year round. Often this results in
significant weedy areas or areas of bare soil and can result in soil erosion. While infanticide and
cannibalism may provide a mechanism for population self-regulation by prairie dogs, the
decreased number and assortment of predators in urban areas may also lead to or exacerbate the
issues of limited food resources for urban prairie dogs. In these areas their ecosystem is
extremely modified and simplified.
In addition to causing damage, prairie dogs can be a safety hazard. Many of the prairie dog
colonies within Boulder are located in transportation right-of-ways. As the colonies expand, they
sometimes disperse across roads causing potential hazards to themselves and motorists.
Prairie Dog Management in the Urban Service Area
Boulder’s involvement in management of prairie dogs in the urban service area began in 1998.
Concerns about the protection of prairie dogs arose from several incidents in Boulder and in
some surrounding communities where large colonies of prairie dogs were poisoned to make
room for new development. The loss of prairie dog colonies in the area prompted community
concern over the lack of protection for the species. In addition, the United States Fish and
Wildlife Service (the Service) reviewed a petition in the late 1990sto list the black-tailed prairie
dog as a threatened species. Although the Service found that the species was warranted for
listing, the listing was precluded by other, higher priorities. This means that, currently, the
black-tailed prairie dog receives no protection under the federal Endangered Species Act.
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City staff received direction from City Council in August 1998 to address prairie dog protection
within the city. In January 2000, Council adopted an emergency ordinance (Section 6-1-11,
“Poisoning Animals Prohibited”, B.R.C. 1981) and Resolution No. 842 concerning the protection
and management of black-tailed prairie dogs. The ordinance prohibited the poisoning of prairie
dogs within Boulder and on all city-owned or managed properties.
After adoption of the ordinance in January 2000, a few incidences occurred which tested the
effectiveness of the new code. Grading activities on some private development sites impacted
prairie dog habitat, however, it could not be proven that any prairie dogs were actually harmed.
To address this loophole in the code, Council adopted Ordinance No. 7133 on July 17, 2001
which prohibited the destruction of prairie dog burrows.
In 2003, the city was notified by the Colorado Department of Agriculture that the city's
ordinances which prohibit prairie dog and bird poisoning were preempted by state law regarding
commercial pesticide applicators. The state's position was that our ordinances need to be either
repealed or amended.
On January 18, 2005, City Council adopted the final Wildlife Protection Ordinance. The
ordinance limits the use of lethal control on prairie dogs by requiring land owners to obtain a
permit to kill prairie dogs on a site within the city. In order for a permit to be issued, the
landowner must satisfactorily demonstrate that all non-lethal options for managing prairie dogs
on a site are not feasible. The foundation of the ordinance is a “Six-step” decision-making
process for managing prairie dogs on a site. The process prioritizes the following actions for
managing prairie dogs on a case-by-case basis:
Step 1. Minimize conflicts with the wildlife through non-removal methods.
Step 2. Remove animals on a portion of the site where conflicts are occurring.
Step 3. Evaluate potential for relocation.
Step 4. Consider animal recovery programs (ferret or raptor).
Step 5. Evaluate trapping and individual euthanasia.
Step 6. If earlier steps are not feasible and pesticides must be used:
Pay into city habitat mitigation fund
Post notice on property of pesticide application
17
The Open Space and Mountain Park Department’s Role
in Protecting Prairie Dogs
As early as the the1890’s Boulder began acquiring and managing what was to become a system
of over 40,000 acres of natural and agricultural areas. In the 1950s Boulder established physical
limits for the provision of city services and soon thereafter defined its urban growth boundaries.
Boulder is viewed as a pioneer in taking action to balance human impacts and urbanization with
protection of natural and rural areas. Furthermore, the city has developed management plans,
practices, and policies specifically for prairie dogs since the late 1970s. This body of work has
been used by other municipalities and land management agencies as starting points for a great
deal of the work that has been done for prairie dogs along the Colorado Front Range.
The preeminent method for conservation of prairie dogs remains the protection of prairie dog
habitat through public land acquisition. Based on recent research by city staff today there are
roughly 14,222 acres of prairie dog habitat that have been set aside for protection by public lands
management agencies in the state of Colorado (see chart below).
CityAcres Dedicated for thePercent of Total
Protection of Prairie Dogs
Arvada1551.1%
BOULDER (City)5,00035%
Boulder County5,00035%
Broomfield3252.3%
Buckley AFB 4603.0%
Ft. Collins 2,06514.5%
Highlands Ranch40.3%
Jefferson County63.4%
Louisville80.6%
PawneeNot less than 200 acresat least 1.4%
Rocky Flats NationalUp to 750 acres (when refuge is 5.3%
Wildlife Refugeestablished)
Rocky Mountain Arsenal Not less than 200 acresat least 1.4%
National Wildlife Refuge
TotalApproximately14,222
It is possible that there are other areas that have been set aside for prairie dogs, however,
regardless of the overall total, over 10,000 acres are being protected in Boulder County—mostly
by the city of Boulder and Boulder County’s open space programs. Boulder contributes a
significant percentage of the grasslands designated for black-tailed prairie dog conservation and
is a leader in black-tailed prairie dog habitat protection. Of the prairie dog habitat set aside by
public agencies in Colorado, the lands identified as prairie dog Habitat Conservation Areas
(HCAs) by the city of Boulder and Boulder County may represent as much as 70% of the total.
18
The OSMP Black Tailed Prairie Dog Habitat Conservation Plan
The city’s Open Space and Mountain Parks Department (OSMP) and the Parks and Recreation
Department protect numerous acres of grasslands and populations of prairie dogs in the Boulder
Valley. In 1996, the Open Space Board of Trustees approved a Black Tailed Prairie Dog Habitat
Conservation Plan (the BTPD plan) for city natural lands that was developed over an eighteen
month period with extensive public involvement. The goal of this plan is to protect, preserve and
enhance habitat suitable for black-tailed prairie dogs in the overall context of functioning
grassland ecosystems.
One of the most important elements of the BTPD plan is that it identifies the places where prairie
dogs are most likely to be successfully conserved in the context of social and ecological
constraints. It is a plan that results in the protection of individual prairie dogs and prairie dog
colonies in the context of burrowing owls, raptors, other species associated with prairie dogs as
well as grasslands undisturbed by prairie dogs. Grasslands without prairie dogs are distinct and
critical habitat for the plants, animals and ecological communities that do not occur where prairie
dogs are active.
1
The BTPD plan is implemented through a system of HCAs and a set of management policies.
Management policies, like this element of the Urban Wildlife Management Plan (UWMP)
address issues of containment/exclusion, population control, response to plague, education and
monitoring. The system of prairie dog habitat conservation areas established by the BTPD plan
includes 5,000 acres mostly on OSMP. The prairie dog HCAs range in size from six to almost
three thousand acres.
Over the past decade, the HCAs on OSMP have filled up and prairie dog populations have
spread to other OSMP lands. OSMP accepted many prairie dogs from relocators stymied by
state regulations restricting their ability to move prairie dogs across county lines. These
reintroductions from off OSMP lands contributed to the establishment of new colonies in and out
of HCAs.
As of the most recent annual mapping (fall 2005) there were approximately 3,900 acres of active
prairie dog colonies on city of Boulder OSMP lands. About 1,500 acres were in the HCAs. Of
the 2,400 acres outside the HCAs, 1000 acres were mapped on lands that were acquired since
1996 and not yet integrated into the plan.The remaining 1,400 acres of active prairie dog
colonies were mapped on lands not designated as habitat conservation areas. OSMP managers
face questions similar to managers of urban lands in trying to determine how to respond to the
expansion of prairie dogs outside of areas identified for their conservation and how to set levels
at which to manage prairie dogs within the HCAs. Given current population levels outside of
HCAs and density of animals with the HCAs, OSMP is no longer accepting prairie dogs from
relocation projects. Biologists and managers face a significant challenge in managing prairie dog
populations in the context of grassland ecosystems.
1
The term prairie dog “habitat conservation area” was used in the 1996 plan to clarify that the city sought to manage for the long term
sustainability of habitat. In 2005 the OSMP Visitor Master Plan created a system of “habitat conservation areas” to guide patterns of visitor
use. Whilethere is some overlapinthe two HCA designations they are different.
19
During the development of the BTPD plan, the OSMP recognized the need to place prairie dog
habitat conservation within a more comprehensive grassland-based approach. With a decade of
experience implementing the BTPD plan and the benefit of other agencies’ experience, staff is
now ready to update and revise prairie dog habitat conservation as part of the development of
OSMP Grassland Ecosystem Management Plan (Grassland Plan) over the next year.
OSMP Acquisition of Property for Prairie Dog Conservation
The mission of the OSMP is to protect the natural environment and land resources that
characterize Boulder and foster appreciation and use that sustain the natural values of the land
for current and future generations. OSMP is the city department that acquires and manages
lands with the conservation of native species and ecological systems as a primary goal.
Although other city programs such as Parks and Recreation, Utilities and Transportation also
purchase land, their focus is upon providing other community services.
In the BTPD plan, fee acquisition was not identified as an appropriate conservation or conflict
reduction strategy for lands in the urban service area. However, 210 acres of existing prairie dog
colonies were identified for long term protected status. Over half of this amount (120 acres) is
part of the existing habitat conservation areas around Boulder Reservoir. Consequently, the plan
recommends new protected status for about ninety acres; fifty are privately owned and forty are
public lands. Some of the publicly owned lands are county and state rights-of-way. The city may
seek to acquire some level of interest in the lands (e.g. conservation easement) in order to ensure
appropriate prairie dog management of areas which fall outside city control.
Some members of the community have suggested that additional lands should be purchased for
prairie dog habitat conservation as an alternative to removal. It is the experience of OSMP Real
Estate Services Division that grassland acquisitions generally fit into two categories: those
already occupied by prairie dogs, and those with few or no prairie dogs because of active
agricultural management (irrigation, annual plowing, and prairie dog control). While the
acquisitions of grasslands occupied by prairie dogs may not provide receiving sites for
relocations; these land purchases do reflect the city’s focus on broad open space goals rather than
individual species. Purchasing lands for a single species would represent a significant shift away
from policy guidance provided by City Council during the discussions of OSMP’s six year
Acquisition and Management Plan (2005-2011) in 2005. Furthermore, given that the average per
acre cost of land in the Boulder Valley is over $30,000, it is important that OSMP properties be
able to provide a range of conservation values and other community services. Removal areas in
the UWMP area have zoning/land use designations, current land uses, and per acre costs that are
inconsistent with the purchase of those properties as OSMP lands under BVCP guidance and
OSMP’s Acquisition and Management Plan.
The acquisition of lands for prairie dog conservation on the eastern plains of Colorado has been
suggested by some as a beneficial strategy to compensate for impacts along the Front Range.
The approach of purchasing large blocks of habitat to compensate for incremental impacts has
been used in the past to compensate for environmental impacts to wetlands and habitat for
endangered species. Colorado’s Shortgrass Prairie Initiative is an example of a program that
offsets habitat loss in shortgrass prairie resulting from transportation improvements by
20
safeguarding large blocks of prairie that are home to a number of imperiled species. While such
a program might provide the city with a way to protect habitat of significant conservation value
for prairie dogs and prairie ecosystems, it would require support of the commissioners in the
county where these lands were acquired if the protected areas were to become receiving areas for
prairie dogs relocated from Boulder. Funding a program that conserved land far from Boulder
may not be viewed as a priority by community members or decision makers.
Since the completion of the BTPD plan in 1996, approximately 18,000 acres of OSMP lands
have been acquired. About 900 acres of these grassland purchases were mapped in the fall of
2005 as being occupied by prairie dogs.
The BTPD plan describes a set of policies to determine the role that newly acquired properties
would play in the conservation of prairie dogs. The policies identify specific steps to be taken
during property negotiation, an evaluation outline to determine the ecological suitability of the
land as prairie dog habitat, and others questions to determine if the site is appropriate for the
establishment of an HCA. Applying these procedures to the lands acquired during the past
decade may be the most cost-effective way to increase the extent of formally recognized prairie
dog habitat conservation areas in the broader context of grassland conservation. This also does
not require the city to raise or expend funds specifically for prairie dogs or to acquire properties
within the service area that have been identified for urban land uses.
Intergovernmental Relationships
Federal Authority
Black-tailed prairie dogs (Cynomys ludovicianus) are native to the Great Plains. Once abundant,
less than two percent of the pre-settlement range of the black-tailed prairie dog (prairie dog)
remains today. Due to their decline, in 1998, three environmental groups petitioned the United
States Fish and WildlifeService (Service) to list the prairie dog as a threatened species under the
Endangered Species Act.
The factors contributing to the decline of the prairie include:
Habitat conversion to urban and agricultural uses
Habitat fragmentation
Unregulated shooting
Unregulated poisoning
Susceptibility to sylvatic plague
Inadequate regulatory mechanisms (at the state level)
In 2000, the Service issued their finding, indicating that the threatened status was warranted, but
precluded its listing, citing other higher priorities. Since that time, the prairie dog has been
removed from candidacy for listing.
21
Federal permits for wild to wild relocation are required by the Food and Drug Administration. In
addition, there are Federal Aviation Administration (FAA) requirements related to airport safety
that require airport operators to take measures to ensure runways, taxiways and areas adjacent
are free of holes and obstructions. The FAA also requires operators to control to the extent
possible rodent populations or populations of other prey animals that may attract raptors and
increase the potential for aircraft collisions with birds.
State Authority
In the state of Colorado, prairie dogs are considered both a small game (wildlife) species and a
pest species. Their management and control is mainly predicated by Title 35 (Agriculture) and
Title 33 (Wildlife and Parks and Outdoor Recreation) of the Colorado Revised Statutes (C.R.S.).
Under Title 35, the Colorado Department of Agriculture has primaryauthority and responsibility.
C.R.S. Title 35 defines prairie dogs as destructive rodent pests and generally populations of
prairie dogs as a public nuisance. Authority is granted to county commissioners to require
eradication of prairie dogs on private lands. If private property owners in such counties do not
comply, the county is authorized to carry out the eradication itself and bill the property owner or
place a lien on the property if the owner does not pay. C.R.S. Title 35 further requires state and
federal landowners to control or eradicate prairie dogs on lands owned by them, to the extent
possible. And finally, Title 35 also prohibits the relocation of prairie dogs from one county to
another with out the permissionof the receiving county’s commissioners and the state wildlife
commission. Article 10 of Title 35 describesthe processes by which permits and licenses are
procured for the purposes of poisoning prairie dogs in Colorado.
C.R.S. Title 33 defines prairie dogs as smallgame. This title establishes the licensing
requirements, seasons and manners of take by which prairie dogs can be hunted. C.R.S. 33 also
describes the exemption for these requirements if damage to property or crops is occurring. Title
33 spells out the requirements for trapping, possessing, transporting and releasing prairie dogs.
A permit or license from the Colorado Division of Wildlife is required to trap, possess, transport
and/or release prairie dogs. However C.R.S 33-6-107(9) precludes the need for a permit or
license to kill prairie dogs if they are causing damage to property. This provision is the premise
for prairie dog lethal control throughout the state.
City Authority and Responsibility in Wildlife Management
The city has no responsibility to manage populations of prairie dogs or other wildlife and the
regulatory authority for managingpopulations of wildlife in Colorado is the Colorado Division
of Wildlife (CDOW) and the Wildlife Commission. However, according to C.R.S. Title 35, the
Boulder Board of County Commissioners could require eradication on private property in
Boulder County.
22
Community Perspectives and Values
Prairie dog management issues elicit strong emotions and varying positions in Boulder,
particularly in relation to the use of lethalcontrol. There is a very vocal segment of the
community that believes that the life of each individual prairie dog is precious and should, to the
greatest extent possible, be preserved. The view of another segment of the community, and the
one that is reflected in the BVCP, that suggests that environmental, social, and economic
sustainability goals of the community should be balanced when making urban wildlife
management or any city policy decision. The BVCP also implies that ecological balance and
native biodiversity should be the cornerstone of city wildlife management policy and decision-
making. In other words, in an urban environment, wildlife protection must be balanced with
human needs and developed land uses. This point of view would permit the use of lethal control
measures in order to further the objectiveof ecological balance and preservation.
Although a formal survey or set of interviews was not conducted for this component, staff
believes a fair representation of the range of community viewpoints can be summarized from
interviews, public meetings, and public hearing that occurred during the development of the
Wildlife Protection Ordinance (as adopted in February 2005), public meetings for the UWMP,
and informal conversations between staff and various stakeholders over the years.
What staff has found over the past few years is that many values regarding prairie dogs are
similar among residents and some are very different and opposing to one another. For example,
most community members who have been involved in the urban wildlife discussions over the
past few years seem to agree that-
protection of native ecosystems is important;
the city should, to the extent possible, prevent the inhumane treatment of animals; and
the use of poisons should be minimized because poisons cause serious environmental
problems.
The fundamental difference in viewpoint among community members over prairie dog
management revolves around whether or not individual prairie dogs should be killed and whether
or not some lethal control techniques are morehumane than others. There appears to be a wide
range of viewpoints with regard to-
the relative importance of protecting individual animalsin comparison to protecting
functioning grassland ecosystems;
the definition and relative value of ‘euthanasia’ or lethal control practices other than the
use of poisons;
the value of the city’s public recreational assets (e.g. ballfields and soccer fields) relative
to the value of the individual prairie dogs inhabiting these sites; and
how far the city can go in preventing the use of lethal controlon private property.
The general perspective that was endorsed by City Council during the adoption of the Wildlife
Protection Ordinance and in Phase I of the UWMP is that all animals should be protected from
inhumane treatment to the extent possible. However, the urban area is primarily intended for
human land uses and services and individual prairie dogs should not be protected at the expense
23
of natural ecosystems. If, for example, protecting all prairie dogs means that the integrity and
biodiversity of native grasslands is compromised, more humane methods of lethal control (by
trapping and use of carbon dioxide gas chambersas opposed to the use of fumitoxins) may serve
a valid public purpose.
Over the years, staff has had several discussions with various stakeholder groups (e.g. wildlife
advocacy groups, property owners, and recreational user groups) in regard to prairie dog
management issues. It has become, clear, however, that consensus on these issues is not
probable. This is not an area in which community members speak with a single voice but one in
which Council will be called upon to make difficult and controversial decisions. The following
is a summary of the various community viewpoints.
Prairie Dog Advocate Groups
The groups that were involved in the development of the Wildlife Protection Ordinance and
those involved in developing the UWMP have expressed a strong viewpoint that no
individual animal should ever be killed except to be put out of pain and suffering.
Prairie dog advocacy groups and some who are in the business of relocating prairie dogs
have argued that the city must, to the extent possible, protect individual animals from being
killed or from being treated inhumanely. These groups have also expressed the view that
relocation of prairie dogs or the construction of barriers should be the primary solutions to
the conflicts in the urban area. They have urged the city to use, or obtain for use, as much
land as necessary for the protection of these animals.
Businesses and Property Owners
Most private property owners and business representatives maintain, for the most part, that
prairie dogs on private property are in conflict with the current or allowed land uses on the
sites. Private landowners express the view that the city must find a way to balance wildlife
protection with human needs. Some property owners are willing to accommodate and
manage an active prairie dog colony on their sites; however, others are finding it difficult to
live with the prairie dogs. Landowners want to be allowed to develop and fully utilize their
properties.
Private property owners express concern with perceived safety, health, and liability issues
associated with prairie dogs on their sites.They note that employees and clients continually
voice health and safety concerns when prairie dogs reside in close proximity to buildings and
public areas. Some landowners feel that the city has a responsibility to deal with prairie dogs
that come onto private land from city land and the cost burden associated with this issue
should not be the sole responsibility of an affected private landowner.
Most property owners feel that humane treatment is important; however, they also expressed
concern over the relatively high costs of morehumane methods of lethal control such as
trapping and euthanization and the installation and maintenance costs of effective barriers.
Private property owners have also expressed a viewpoint that the current waiting period for
lethal control permits is too long.
24
Environmental Groups and Technical Advisors
Most of the representatives from these groups have stressed the need to balance various
environmental concerns and goals. Technical advisors and members of these organizations
emphasize the protection of native species, biodiversity and the health of natural ecosystems.
Although there is generally support for the humane treatment of animals, there is no support
for elevating the protection of individual animals to the point where it might endanger the
health of native grasslands. They expressed concern that current prairie dog populations on
city open space lands may be compromising the health of grassland ecosystems.
Members of these groups feel that urban prairie dogs serve an educational purpose and are
important as prey for raptors; however, they assert that prairie dogs need to be managed in
order to prevent overpopulation. This view would allow killing some animals where
necessary to protect the health and biodiversity of natural ecosystems. They emphasized the
need for humane lethal control of animals whenever possible.
Overall, there are a range of perspectives and values in Boulder toward urban wildlife. The
following is a summary of those positions:
How the Community Values Wildlife
Intrinsic
value of wildlife as living things regardless of their utility to humans.
Aesthetic
value associated with the pleasure of seeing and hearing wildlife and
of having the diversity of form and texture associated with wildlife habitat soften
and modify a landscape otherwise dominated by buildings and roads.
Spiritual
value derived from a variety of belief systems wherein encounters with
wildlife or the presence of wildlife and habitat holds special meaning about the
beauty and value of all life.
Ecological value
of that wildlife in the city.
Educational
value to teach ecological lessons such as human participation in
larger natural systems, energy flow, and predator-prey relationships.
Economic
value associated with wildlife and habitat as amenities that attract
residents, visitors and businesses and keep property values high.
25
26
2
Inventory and Analysis
Inventory
An inventory of the prairie dog colonies in the study area was completed in October of 2005. The
inventory was combined with previous information about prairie dogs on other city properties
currently outside the service area (e.g. the regional park site in the Planning Reserve, the Boulder
Wastewater Treatment Plan, and the Valmont Butte property).
The purpose of the inventory was to obtain accurate colony size, location, and ecological
condition assessments of the colonies as well as information concerning surrounding land uses
and existing barriers or constraints to colony expansion. Prairie dog densities for each colony
were not estimated as part of the study due to the dynamic nature of population densities and to
budget limitations. An accurate count of individual prairie dogs in each colony, therefore, is not
available.
The results of the inventory show approximately 611 acres of prairie dog habitat in the study area
under diverse ownership (see mapon page 29). The size of colonies ranges from a few hundred
square feet to over 100 acres. Of the 611 acres occupied by prairie dogs, 471 acres are publicly
owned (including city, county, state, and federal jurisdictions) and 140 acres of habitat are on
privately owned land.
It is very difficult to determine the densities or prairie dog numbers that the 611 acres may
represent. Research indicates that the densities in these colonies may range anywhere from 13 to
49 prairie dogs per acre. Therefore, very rough estimates would indicate from 7,940 to 29,900
prairie dogs in the urban area. By comparison, it could be estimated that there are roughly
45,500 to 171,500 on OSMP land.
Condition of Colonies
Most of the prairie dogs in the study area occupy very marginal habitat in that the conditions are
not optimum and staff does not consider themhigh-functioning grassland ecosystems. Except
for a few colonies, the prairie dogs live in small, densely populated and fragmented areas.
(Although density counts were not systematicallyconducted, site-by-site observations sometimes
were recorded about population densities). The marginal sites typically have little to no
vegetation throughout much of the year and are dominated by invasive non-native weeds. The
sites which still retain somewhat healthier vegetation were generally the larger, less fragmented
sites that were not fully inhabited by prairie dogs or sites that were newly inhabited by prairie
dogs and retained some of the original manicured landscaping as originally developed with the
land use.
27
28
INSERT MAP WITH COLONY STATS
29
30
For purposes of the analysis and plan recommendations, the 611 acres of prairie dog habitat in
the study area were grouped into 20 different colonies or complexes of colonies based on
geographic connectivity. Each colony consisted of a grouping of one or several public and/or
private parcels. A colony report was developed for each of these areas and summarizes the
inventory information, analysis, and management recommendations (Appendix A).
Analysis
Assumptions
In establishing a framework for analyzing the twenty colonies and developing management
options, staff made some key assumptions. The following is an outline of those assumptions:
1.The primary site condition that influenced the management recommendations is the size
of the parcel and the degree to which protection of the prairie dogs on the site will result
in the escalation of the level of conflict in and around the site.
2.The city can not ultimately prevent a private property owner from removing prairie dogs
from his or her property. In addition, the city does not have jurisdiction over prairie dog
management on other public lands. The city, however, can encourage cooperative
management arrangements or try to influence wildlife management policies of other
jurisdictions.
3.Conflicts that are considered to pose high enough risk to require near-term management
actions include: a) public safety relatedto dams, airports, and play fields; b) new
development; c) damage to existing buildings and landscaping, and d) regulatory non-
compliance.
4.Conflicts that are considered low risk and do not require prompt removal of prairie dogs
from a site include: a) public health related to plague, b) public safety related to
roadways and bike paths; and c) potential development of a site in the long-term.
Analysis Framework
In developing management recommendations for each colony, staff analyzed several factors
including:
Ownership
Colony condition
Landscape context
Land Use/Nature and level of conflicts
Ownership
Staff considered the type of land ownership underlying the prairie dog colonies and the number
of separate public jurisdictions in making management recommendations. The primary
assumption regarding prairie dogs on private land is that, ultimately, the city has more control
over the protection of prairie dogs on city-owned land than on private land or other public
31
properties. The assumption that was established during the development of the lethal control
ordinance and continues to influence these management recommendations is that the city can not
ultimately prevent the removal of prairie dogs from any non-city-owned sites.
The ownership of the parcels is also important in that multiple ownership of parcels within one
colony area presents management challenges for several reasons. Where state, county, or federal
jurisdictions are involved, the city can not impose regulatory requirements to manage prairie
dogs on those parcels. Prairie dog colonies on other public parcels are included in the plan,
however, because the city can encourage cooperative arrangements with the agencies. In
addition, it is in the city’s interest to know where future conflicts with prairie dogs may arise on
private or city-owned land. In most cases, the other public agencies have adopted similar
management policies and practices for handling prairie dog conflicts and also look to the city for
guidance in forming policy or making management decisions.
Colony conditions
Overall, the vegetative condition of a site was nota primary factor in the analysis because most
of the sites in the study area were generally degraded and considered marginal habitat.
Furthermore, sites which are currently in reasonably good condition will likely become degraded
in a short period of time unless there are continual management efforts to restore vegetation to
support the colony on the site.
The primary site condition that influenced the management recommendations was the size of the
parcel and the degree to which protection of the prairie dogs on the site will result in an
escalation in the level of conflict in and around the site.
Landscape Context
The analysis of the colonies included a broader observation of the landscape surrounding the
colony. The purpose of looking at this factor was to understand whether the colonies were
isolated from larger grassland ecosystems or if they were interconnected with other colonies on
natural lands. An understanding of the larger landscape also can provide guidance on the
effectiveness of certain management strategies.In some situations, colonies within the city are
directly connected to larger colonies outside the city (e.g. Winchester Circle). In situations such
as these, removal of the prairie dogs on the private parcels is not a good long-term management
strategy by itself as prairie dogs from the adjacent OSMP parcel will continue to move onto the
private sites. Removal in these situations mustbe combined with effective barriers and good site
design to minimize the use of on-going removal efforts over the long-term.
Land Use/Nature and Level of Conflicts
The most important consideration in the analysisof individual prairie dog colonies is the nature
and level of conflict the prairie dogs pose with either existing or planned land uses on a site. The
three primary questions that staff asked in analyzing each colony were-
What is the existing or planned land use of the site?
What is the nature of the conflict?
What is the level of the conflict?
32
Can the conflict be substantially mitigated without removing prairie dogs from a site
at a reasonable long-term cost?
Nature of Urban Conflicts
Prairie dogs often pose unique wildlife conflicts with human uses in an urban setting primarily
because of their burrowing nature and dispersal patterns. Once a prairie dog coterie (or family
group) has inhabited a site, the coterie will remain on that siteunless it either dies off from
disease, predation, or human interference or there are significant deterrents to cause them to
leave the area. While many of the conflicts ofconcern between prairie dogs and human lands are
related to the protection of developed property, there are also concerns from the community
related to human health and safety. The general types of conflict that were identified by staff are
as follows:
Public safety
Dams – The Northern Colorado Water Conservancy District manages the dams on the
east side of the Boulder Reservoir. The district requires that the dam embankments
and a buffer area around the dams remain free of prairie dogs to ensure dam stability.
Airport – The Federal Aviation Administration (FAA) requires that the Boulder
Municipal Airport runways remain free of prairie dogs to prevent potential
interference with take-off and landing of airplanes. The FAA also requires airport
operators to take measures to discourage rodents (prairie dogs are classified in the
animal order, “Rodentia”) from inhabitingairports, since rodents can attract raptors
and other predators that pose a threat to aircraft.
Roadways and bike paths – Staff has infrequently received complaints from the
public of the possible accidents that may occur on roadways and bike paths as a result
of prairie dogs crossing paths with bicyclists or motorized vehicles. However, there
are no actual documented incidents of this occurring.
Play fields – Concerns have been raised by staff and recreational user groups of the
safety issues involved having prairie dogs and their burrows on open play fields.
Burrows and prairie dogs pose a serious trip hazard in these situations.
Damage to built facilities and required landscaping
Most private property owners of existing facilities identify this conflict as their primary
concern. The city’s land use regulations require development to meet certain landscaping
standards. However, once prairie dogs have moved onto a developed property, they tend
to damage or destroy much of the landscaping on the site by either burrowing around the
root zones of trees and shrubs or consuming herbaceous plant material (sod grasses in
particular). Once the landscaping is destroyed, the development may be out of
compliance with an existing development agreement or code requirement (properties with
site plan agreements are required to maintain a property according to the agreement in
perpetuity or until the plan is amended).Continual restoration of impacted landscaping
can become costly to a landowner and not likely to succeed if prairie dogs remain on site.
Other related conflicts identified by landowners are the impact of burrowing activities
33
around outdoor lighting, alarm systems and other electrical or fiberoptic infrastructure
that may result in severed lines or exposure of the lines to other forces.
New development
Most new development projects require full use of a property for grading, installation of
utilities and buildings, and staging of construction equipment. Unless a development site
is quite large, it can be difficult to construct new facilities on a site without impacting
prairie dogs or their burrows.
Public health/plague
Plague is identified by many community members as a concern where prairie dogs are in
close proximity to human activities. Plague is widespread in the western United States
and firmly entrenched among wild rodents in North America. It is frequently detected in
squirrels, prairie dogs, wood rats, and other species of ground squirrels and chipmunks.
Concerns are often raised by the public about the risk of plague because of the close
proximity of prairie dogs to buildings and recreational facilities. Issues have also been
raised concerning the close proximity of prairie dogs to food production facility and the
potential disease risk as a result.
Because of the low incidence of plague occurrence in humans, it is staff’s opinion, that
plague should not be considered a high level of conflict or strong reason for removing
prairie dogs from a site.The causative bacterium (Yersinia pestis) is transmitted to
people through flea bites and direct contact with infected animals. Several rodent species
are host to one or more species of fleas which, when infected, are carriers of plague.
These fleas generally do not infest other animals unless their natural hosts are
unavailable. Fleas present on prairie dogs and other rodents like the fox squirrels (which
are commonly found in backyards) can carry plague, although its frequency is very rare.
In order to contract plague, a person would need to have direct contact with an infected
flea. This is extremely unlikely. If precautions are taken, the probability of an individual
contracting plague, even in active plague areas, is quite low.
Plague cannot be eliminated from our natural environment. Removal of prairie dogs
from an area will not totally eliminate the risk of plague.
Regulatory non-compliance
A few of the conflicts listed above can result in non-compliance of a property with local,
state, or federal regulations or guidelines.Destruction of landscaping on a site can put a
property out of compliance with city landscaping requirements. Prairie dogs in close
proximity to a food production facility can be inconsistent with federal food safety
guidelines, and, as mentioned above, prairie dogs around the runways put the airport out
of compliance with Federal Aviation Administration regulations. In addition, the State
Engineer’s Office requires that dam faces be kept free of any type of burrowing activity
that may compromise dam integrity and safety.
34
Level and Prioritization of Conflicts
Staff considered the level or potential risk of all the above conflicts in developing management
recommendations. While the nature of some conflicts is based on real or documented situations,
others are based more on human fear or precaution and, in actuality, present a very low level of
risk to humans. Conflicts that were considered to pose high enough risk to require management
actions included:
public safety related to dams,airports, and public playfields;
new development in the near term;
damage to existing facilities and landscaping; and
regulatory non-compliance
Conflicts that staff assumed were low enough risk not to prompt specific management actions
included:
public health related to plague;
public safety related to roadways and bike paths; and
potential new development in the long-term
In terms of property protection, there are conditions where prairie dogs may coexist with existing
or planned development while in other situations, development of the property would harm the
animal. In these situations, staff considered the cost and effectiveness of barriers on a case-by-
case basis.
35
36
3
Management Classifications
As a result of the area-by-area analysis, each prairie dog colony complex was designated for
either removal or protection. In some cases where conditions were found to vary across an area,
a combination of removal and protection was recommended for specific areas. The category
“protection” was broken into two sub-categories, longer-term and interim. Longer-term
protection was used to designate areas managedby the city or others where the current and
projected land uses are compatible with prairie dog occupation, and where land management
practices are either directed specifically for prairie dog protection, or where prairie dogs are
treated with “benign neglect”. Interim protection is proposed for areas where development is
planned but not imminent; protection may occur in the short term, but removal may become
necessary in the long-term. The analysis and recommendations for each prairie dog area are in a
series of Colony Reports in Appendix A and summarized on the map and in the chart below.
Long Term Protection
Interim Protection
96 acres
Near-Term Removal
16%
149 acres
24%
367 acres
60%
37
38
INSERT MAP OF COLONY PLAN
39
40
Long-term Protection (approximately 149 acres)
The largest area of longer-term protection consists of approximately 132 acres of active
prairie dog colonies on the prairie dog habitat conservation area managed by the Parks
and Recreation and OSMP departments on the east side of Boulder Reservoir (colony
#1b). Prairie dogs have long occupied city and state road rights-of-way along Pearl and
Foothills parkways where they provide opportunities for observation and are not involved
in significant conflicts. The analysis for prairie dogs in the rights-of-way of colonies 8a,
8c and 9 suggested that the majority would be appropriately designated for longer-term
protection. These road rights-of-way contain about seventeenacres of active prairie dog
colonies.
Interim Protection (Removal in the long-term) (approximately 361 acres)
Interim protection of areas occupied by prairie dogs was identified as an option where: 1)
there are no currentsignificant conflicts; 2) natural lands management decisions have
not been made; or 3) development plans are unknown or not anticipated for at least six
years. The six year timeframe was selected to reflect a typical mid-range planning
horizon and is used by the city for capital improvement project planning. The largest area
identified for interim protection is the regional park site in the Planning Reserve (colony
#17). This site includes 152 acres of currently active prairie dog colonies. The current
CIP does not include the development of this site.
There are about 140 acres of prairie dog colonies on OSMP in the study areaidentified
for interim protection. The majority ofprairie dog acreage is on properties purchased
from IBM in the Gunbarrel area (colony #2). OSMP land interest (conservation
easement) with prairie dogs in the study area also includes about three acres near the
Boulder Community Hospital at Foothills Parkway and Arapahoe Rd. (colony #8c).
These colonies were identified for interim protection because they have not been
reviewed as part of the BTPD Plan.
In addition, there are small areas occupied by prairie dogs at the city’s wastewater
th
treatment plant on 75 Street (colony #16), in the undeveloped areas of Valmont Park
(colonies #7 and #9) and 63 acres of private property identified as candidates for interim
protection.
Near-Term Removal (approximately 96 acres)
Removal areas were identified where the presence or activities of prairie dogs are most in
conflict with regulations, public services and facilities or landowner preferences. Areas
evaluated in the BTPD Plan, but not designated as conservation areas or transition areas
were also identified as removal areas.
There are three areas in the study area where removal is a regulatory requirement.
Federal regulations require that the runway area of the Boulder Municipal Airport be kept
free of prairie dogs (colony #6). There are currently no prairie dogs on the airport site, as
the city has been actively monitoring and removing the animals from the site. State dam
safety regulations and agreements with the Northern Colorado Water Conservancy
41
District require that prairie dogs be excluded from an area 100 feet from the base of the
two dams at the Boulder Reservoir (colony #1b). There are currently are no prairie dogs
in the ten acres affected by this regulation since the area has recently been treated with
burrow fumigants. Finally, the federal Environmental Protection Agency has required
that prairie dogs be removed from the contaminated tailings portion of the Valmont Butte
site estimated at approximately ten acres (colony #10).
Prairie dogs have become active in several parks where their presence and activities are
considered incompatible with the intended public uses of these areas. As a result these
areas have been identified as removal areas. These include the developed portions of
Valmont Park (colony #9), Tom Watson Park (colony #1a) and the East Boulder
Community Center (EBCC)(colony #13). Areas occupied by prairie dogs adjacent or
near park sites have also been identified as potential removal areas. These include the
Hogan-Pancost property south of the EBCC (colony #13), OSMP & Park and Recreation
Department lands west of Foothills Community Park (colony #4) and a portion of the
state highway right of way east of the Pleasantview soccer complex (colony #5). These
areas were identified as removal areas becausethey pose a significant threat to the city’s
ability to provide services at nearby parks.
The OSMP lands west of Foothills CommunityPark were reviewed as part of the BTPD
plan and not recommended as a prairie dog habitat conservation area for several reasons,
including incompatibility with the planned (at the time) park. It is likely that the owners
of the Hogan-Pancost property would support the removal of prairie dogs from their
property as they are planningannexation and residential development of the parcel. There
are also private properties where the landowners desire to remove prairie dogs due to
irreconcilable conflict, such as on going damage to property. Approximately sixteen
acres across four sites have been identified as removal areas for this reason.
Some of the larger blocks of prairie dog activity identified for protection or removal are nested in
a natural land system (Boulder Reservoir, IBM and the Planning Reserve) where considerable
ecological context remains. These areas should be managed in accordance with the BTPD plan
which is focused upon preserving and restoring grassland habitat for the prairie dog.
Management of these areas may change as the BTPD plan is updated.
42
4
Implementation
The objectives of the prairie dog component of the UWMP are to conserve prairie dog
populations where possible in the urban service area while reducing conflicts with prairie dogs
and other land uses. How the city responds to the conflicts between prairie dogs and other land
uses is critical to the success of urban prairie dog management. Balancing prairie dog
conservation with conflict reduction will require taking actions that remove the threats to prairie
dog conservation and remove sources of conflict. This approach is based upon the assumption
that both conflict and threatsto conservation will decrease if the sources are removed.
In addition to direct actions, it will be also be necessary to increase staff capacity and work
closely with interested members of the community. While these strategies are indirect, they are
needed to help prepare the way for direct conservation and conflict reduction strategies.
This plan recommends the use of three complementary pathways to reduce conflict and conserve
City Policy Development or Revision,Conservation
prairie dog populations. These are: 1) 2)
PracticesIntergovernmental Relations
, and 3) .
City Policy Development and Revision
Existing policies (including laws, regulations, ordinances and plans) guide prairie dog
management and conservation. Some aspects of conflict reduction and prairie dog conservation
can be addressed best by adjusting and establishing policies. Over the past few years, the city has
developed and adopted local policies to address prairie dog conservation.In addition, there are
also relevant policies at the state and federal level.
The UWMP – Black-tailed Prairie Dog Component establishes classifications of lands within the
urban service area, as either prairie dog “Protection Areas” or “Removal Areas”. The intention
of these designations is to clearly articulate a recommendation about the suitability of these areas
for prairie dogs. These new designations present a new approach to prairie dog management by
identifying where prairie dogs should be protected and where they should be removed.
This section of the plan provides a summary of issues associated with integrating the UWMP
management designations into existing city regulations, rules, ordinances and policies. The
recommendations in this section include both ways of integrating the UWMP into and improving
the effectiveness of existing ordinances and policies.
43
City Council Resolution #842
In January of 2000, the City Council passed “Resolution # 842 Regarding the Protection and
Management of Black-Tailed Prairie Dogs.”This resolution recognized the importance of
prairie dogs both ecologically and as a community value, and that there are large-scale patterns
of prairie dog population decline. The resolution also confirmedthe city’s commitment to the
protection of prairie dogs and their habitat and established a goal of eliminating any need for
poisoning or extermination. Relocation was identified as the preferred (only) method of
removing prairie dogs from a site. The resolution also provided direction for staff to:
develop a set of policies emphasizing the protection of prairie dog habitat on private
and public lands. Furthermore, it directs staff to;
establish relocation policies so the city will accommodate the prairie dog relocation
needs of public and private landowners on open space and other city lands
take the lead in preparing receiving siteson open space, and insure that appropriate
ecological conditions exist for successful relocation.
The resolution represented the City Council’s earliest articulation of a visionfor prairie dog protection
and management outside of the OSMP system. The resolution, however, presents unclear direction
about the role of city open space and other city-owned lands as receiving sites for prairie dogs. The
resolution provides direction that open space and city-owned lands should be managed as functioning
ecological systems. On the other hand, the resolution clearly directs staff to “establish policies such
that the City of Boulder will accommodate all prairie dog relocation needs of private and public lands
in the city.”
Staff experience over the past five years indicates that there will be times when city lands will not be
able to accommodate prairie dog relocation. And while staff has repeatedly taken “extra measures” to
accommodate relocation requests over the years, it is not clear that these decisions have been
reasonable. While prairie dog survival has been good, these relocation projects have had other
implications for long term management of city-lands as functioning prairie ecosystems. In attempting
to implement the direction in this resolution, the city has found that it cannot always accommodate all
relocation needs or manage all prairie dog HCAs in a sustainable manner.
In addition, one key element of the resolution, the prohibition on the use of lethal control, has been
superseded by subsequent policies. Although relocation remains the preferred method of removal,
both relocation and lethal control are now both allowed by city policy and ordinance.
:
Action Items
1)Develop amendments to Resolution #842 for Council consideration that
resolve conflicts between the resolution and current policy.
44
Wildlife Protection Ordinance
The most significant ordinance affecting the management of prairie dogs in the city of Boulder is
the Wildlife Protection Ordinance or Chapter 1 of Title 6 of the Boulder Revised Code (6-1
B.R.C. 1981). This chapter includes most of the regulations that deal with relocation and lethal
control of prairie dogs and burrow destruction. This chapter limits the conditions under which
lethal control or burrow destruction is allowed, and describes the processes for obtaining a
permit to allow the use of lethal control. Lethal control permitting requirements are summarized
in the table below.
ABC
Lethal Control AllowedLethal Control AllowedwithLethal Control Requiring a
without PermitSpecial PermitPermit
Safety or compliancewith FAA Owners and occupantsofAll others
requirements at an airportresidential lots containing a
single residence
Protectionof structural integrity
orsafety at dam or other Immediatehealthhazards
structure
Completion or maintenanceof
Public or utility relatedprojects
public improvement project
conducted accordingtoapprovedby City Council.
practices designed to minimize
Ongoing or continuous use oflethalcontrolto prevent re-colonization canbe
harm to animals
includedin a lethalcontrol permit. Such a program mustbeginimmediately
after the initial prairie dog removal.
Partof research relatedto
animal control or protection
The permitting process for the use of lethal control requires applicants to explore and document
alternatives to the use of lethal controls including: non-lethal control, changing land-use or
habitat conditions to minimize conflicts, and relocation. Applicants whose situation does not
meet the criteria outlined in columns A or B of the table above are required to pay a processing
fee of $1500 for a permit and a mitigation fee of $1,200/acre of active prairie dog habitat lost
(unless prairie dogs are donated to a wildlife recovery program). There is a minimum 90-day
permit review and public comment period for these applicants. If it is decided that relocation
sites are available, the lethal control permitmaybe delayed for an additional twelve months to
allow for relocation.
There are potentially several issues with thecurrent ordinance that may hinder or impede
efficient and successful implementation of the UWMP. Some of the preliminary issues that staff
has identified include the following:
The current regulations do little to promote or reward voluntary protection of
1.
prairie dogs.
Voluntary agreements between the city and a cooperating landowner could
be developed to promote protection of prairie dogs and their habitat on non-city property
while giving assurances to participating landowners that in specific areas lethal control of
prairie dogs would be allowed.
45
The burrow destruction restrictions may be in opposition to policy of minimizing
2.
use of lethal control.
Prohibitions of prairie dog burrow destruction do not allow: a) all
landowners to respond to colony expansion onto their property; b) damage associated
with relocation; or c) damage to prairie dog burrows that may be incidental to property
use or management.
Vigilant land owners or managers detecting the first establishment of burrows on a
property who respond by filling burrows may be able to avoid the use of lethal control,
and the expense of the permitting process. In addition if landowners can act without delay
to fill or destroy burrows, they are more likely to be successful in discouraging prairie
dog from establishing a colony where one is not wanted. The time frame for a lethal
control permit (90 days to 15 months) is sufficient time for significant expansion and
establishment of prairie dogs, thus increasing the amount of relocation or lethal control
that would need to be done in the future.
3.The requirement that an applicant look at options for on-site protection may be
inconsistent with UWMP management classification.
Action Item:
2)Review Wildlife Protection Ordinance for possible conflicts with
implementation of the UWMP and propose amendments for Council
consideration.
3)Continue administration of Wildlife Protection Ordinance and lethal
control permitting process.
City of Boulder Land Use Code (Title 9 of the Boulder Revised Code)
Among other things, Boulder’s land use code (Title 9, B.R.C., 1981) seeks to promote
development that supports and implements the goals of the BVCP. Certain development projects
in the city are required to go through the Site Review and approval process as outlined in the
Boulder Revised Code. Under that process, project proposals are reviewed and approved if the
city finds that they meet a set of criteria relating to site design. One of several criteria applied in
the site review process and outlined in subsection 9-2-14(h) of the Boulder Revised Code
specifically relates to the protection of prairie dog habitat:
No site review application shall be approved unless the approving agency finds that:
…
(h)(iii) The project provides for the preservation of or mitigation of adverse impacts to
natural features, including, without limitation, healthy long-lived trees, significant plant
communities, ground and surface water, wetlands, riparian areas, drainage areas, and
species on the federal Endangered Species List,“Species of Special Concern in Boulder
46
or prairie dogs (Cynomys ludovicianus) which
County” designated by Boulder County,
is a species of local concern, and their habitat
;
Action Item:
4)Revise site review criteria to eliminate conflicts with the UWMP
.
Boulder Valley Comprehensive Plan
The environmental policies of the BVCP describe the interconnectedness of the natural
environment, the economy, the built environmentand community livability. Prairie dogs affect
all these elements and the BVCP environmentalpolicies provided guidance for the approach and
recommendations of this plan. The following concepts that have been discussed during the
development of the prairie dog component of the UWMP that could be incorporated into the
BVCP:
Natural resource management and biodiversity conservation is often most effectively
delivered through the management of natural lands. The Rural Preservation Area (Area
III), especially city and county open space, is the primary location for activities
associated with the conservation of biological diversity and ecosystems.
Urban areas play other significant roles that are not always compatible with the
conservation of all types of wildlife.
The urban area is primarily intended for the development and support of human land uses
and services described in the BVCP.
Action Item:
5)Consider revisions to the BVCP during the next major update to
clarify where biodiversity and ecosystem conservation will be
emphasized relative to the planning areas.
Open Space and Mountain Parks Grassland Ecosystem Management Plan
In 1995, the Open Space Board of Trustees (OSBT) approved a Black-Tailed Prairie Dog Habitat
Conservation Plan (BTPD). The plan describes the areas of OSMP dedicated to prairie dog
conservation, and describes how OSMP conserves prairie dog habitat in the context of broader
grassland management. This plan was completed with the intentionof developing a more
overarching Grassland Plan to balance, agricultural uses, natural resources and visitor use in
OSMP grasslands. However due to other priorities including the development of the Forest
Ecosystem Management Plan, the Visitor Master Plan and a system-wide vegetation map for
OSMP the Grassland Plan has not been completed.
47
Critical elements of the Grassland Plan such as habitat suitability and relocation criteria are
needed to identify relocation opportunities as alternatives to lethal control for the prairie dog
component of the UWMP. There is an on-going need to identify relocation opportunities in
Boulder County because state law restricts the relocation of prairie dogs across county lines.
OSMP grasslands often appear to be the mostappropriate places to relocate prairie dogs;
however, the BTPD does not include specific standards or criteria for the relocation of prairie
dogs. Preliminary criteria that were developed in 2004 remain general. Consequently, requests
to relocate prairie dogs to OSMP lands have been addressed on a case-by-case basis.
Action Item:
6)Prioritize the completion of the OSMP Grassland Plan.
Conservation Practices
Land Acquisition
The purpose of the OSMP is to acquire and manage lands with the conservation of native species
and ecological systems as a primary goal. Although other city programs such as Parks and
Recreation, Utilities and Transportation also purchase land, their focus is upon providing other
community services.
Fee acquisition was not identified as an appropriate conservation or conflict reduction strategy
for lands in the urban service area. However, as part of this plan 210 acres of existing prairie dog
colonies are identified for long-term protection status. Over half of this amount (120 acres) is
part of the existing HCAs around Boulder Reservoir. Consequently, the plan recommends new
protected status for about 90 acres; 50 are privately owned and 40 are public lands. Some of the
publicly-owned lands are county and state rights of way. The city may seek to acquire some level
of interest in the lands (e.g.conservation easement) in order to ensure appropriate prairie dog
management of areas which fall outside city control.
In addition, as part of the development of the Grassland Plan, the staff can formalize property
review procedures to make HCA determinations on newly acquired properties, and apply those
procedures to grasslands that have not yet been considered for inclusion in the system of prairie
dog HCAs.
Action Items:
7)Develop a prioritized list of easements and other property acquisitions
in areas identified for long-term protection in this plan.
8)Develop policy guidance to review properties for inclusion in the OSMP
HCA system.
48
Land Management Practices
Without on-going management of both designated Protection and Removal areas, it is likely that
prairie dogs on lands in the service area will be involved in conflicts on site, or spread out to
neighboring properties. Continual management of prairie dog colonies is needed on an on-going
basis to address soil erosion, noxious weed management and maybe needed to address prairie
dog population levels. More detailed site-based plans should be developed for public properties
and for private properties in cooperation with affected private landowners. In addition to
exclusion and removal (both described in the Management Tools section) site-based plans should
also include:
Prairie dog population management procedures
Inventory for and response to the presence of associated species (e.g. raptors and
burrowing owls)
Vegetation management (weed control response, native plant and soil conservation)
Monitoring for and responding to disease (e.g. plague)
Educational or interpretive uses of the site
The role played by the colony in ongoing management research (e.g. birth control,
vegetation impacts, role of prairie dogs ask a keystone species
Although there has been funding for developing and implementing prairie dog and grassland
management programs on city natural areas—the funding is limited for this work on other city
lands, state and county rights of ways or private property. Some landowners could face
significant expense to develop and carry out a plan to either protect or remove prairie dogs. The
city could offer free technical assistance or cost-share planning and implementation as a way to
educate, encourage, and reward those involved in prairie dog conservation and conflict
reduction. The city could also play a role as intermediary, connecting people concerned about
prairie dog conservation who are willing to volunteer their labor or donate funds, with people
who own the land where prairie dogs live.
Developing management plans would require working with 25 to 40 private landowners and
representatives from approximately six city departments as well as Boulder County and the State
of Colorado.
Prioritization of Colony Management Plans
Establishing priorities and timing for implementation of colony plans is necessary to minimize
the use of lethal control, manage costs, ensure humane treatment (whenever possible and
financially reasonable) and protect facilities. Among the three management classifications (long-
term protection, interim protection and removal), implementation of the recommendations on
developed or developing public lands is the highest priority for the city. In addition, availability
49
and capacity of receiving sites will also be considered when assessing priorities for removal
areas and interim protection areas.
The following criteria were used to prioritize implementation of colony plans.
1)Current or potential threats to human safety or health (e.g. sports fields)
2)Regulatory Requirements (e.g. dams and airports)
3)Imminent development
4)Long-term costs of inaction
5)Level and type of conflict (e.g. loss of public asset or destruction of mechanical
systems)
Removal does not necessarily equate to killing – particularly if removal plans are implemented
gradually over time as receiving sites become available. When receiving sites are available, it is
the city’s intention to move quickly to implement removal from high priority areas. Costs and
funding sources associated with this will need to be identified and analyzed.
During times when receiving sites are unavailable and immediate removal is necessary, the city’s
Six-step process, as outlined on page 17, will be followed. In the meantime, it is assumed that
private property owners will apply for lethal control permits and follow the Six-step process.
Below is a list of the recommendations for prioritizing removal on public land. Prairie dog
removal on private properties will be dictated by landowner decision. In anticipation of this, the
staff recommendations include actions to work with property owners.
Priorities for Public Land Removal Areas
Near term (2006 - 2007)
Tom Watson Park (encroachment into play fields, human safety, loss of public asset
and long term costs of inaction)
Valmont Butte (soil contamination, regulatory requirement)
South Valmont Park multi-use field buffer area (encroachment into play fields, loss of
public asset/investment and long term costs of inaction)
East Boulder Recreation Center (encroachment into park, loss of public
asset/investment and long term costs of inaction)
Right-of-way at Foothills Parkway and Kalmia (loss of public asset/investment and
long term costs of inaction)
Foothills Community Park (loss of public asset/investment and long term costs of
inaction)
Long-term Removal(2008 or later)
Gunbarrel Fire Station (long-term costs of inaction)
Foothills and Pearl (Development, destruction of landscaping and mechanical
systems)
South Valmont Park (development of a public asset)
North Valmont Park; north of Valmont Road (development of a public asset)
50
Action Items:
9)Work with other agencies and private property owners to develop
site management plans to protect and contain or remove and
exclude prairie dogs in accordance with the colonydesignations.
Developsite management plans accordingtothe prioritizationinthe planby working with
agenciesand private property owners.
Workwithcommunity groups to identify lands availableas receivingsitesfor prairie dog
relocation.
10) Provide technicalassistance to city departments to implement the
recommendations of the UWMP.
Coordinate technicalassistance for site management plan implementation.
Develop and administeranannual prairie dog management budget for City Council
approval.
Conduct annual inventories of prairie dog colonies in the city and
11)
prioritize annual removal and relocation efforts.
Intergovernmental Relations
Regional Cooperation and Coordination
Several staff of Front Range communities participate in the Front Range Prairie Dog Working
Group (FRWG). This intergovernmental coalition was established by Boulder staff in 2005 at
the direction of City Council. The group meets at least quarterly and to share information about
prairie dog management.
Action Items:
12)Develop and maintain an on-going list of potential relocation sites in
the Front Range in cooperation with other jurisdictions.
13)Continue participation in and management of the Front Range Prairie
Dog Working Group.
51
State of Colorado Policies and Law
The citizens of Colorado own all wildlife in the state. The Colorado Division of Wildlife
(CDOW) has primary responsibility for managing wildlife statewide. The management of prairie
dogs in Colorado is guided by several planning documents and implemented through educational
programming, research, land management, intergovernmental agreements, regulations and
administrative directives. State laws and agency actions are sometimes in conflict with Boulder’s
wildlife goals and management activities. The following is a preliminary list of recommended
actions to resolve some of those conflicts:
Senate Bill 111
Colorado Senate Bill 99-111, now codified as state law under C.R.S. 35-7-203, was
enacted by the Colorado State Legislature in the spring of 1999 and requires the approval
of county commissioners to relocate prairie dogs across county lines. With few
exceptions, SB111 has essentially stopped inter-county relocation, whether by public
agencies or private parties.
This law is somewhat unusual for Colorado because it provides county commissioners
with the authority to make decisions about what would otherwise be legal activities on
private lands. In most other cases, manylandowners would reject the idea of government
officials being able to dictate how they used their lands. In addition, county
commissioners in the range of the black-tailed prairie dog are unlikely to approve
relocation of prairie dogs to their county for a variety of reasons.
Counties like Boulder are especially affected by this law because of tight land supply.
Boulder is a relatively small county, land prices are relatively high, and a large
percentage of suitable habitat is already occupied by prairie dogs.
Action Item:
14)Develop a legislative strategy to modify or repeal C.R.S. 35-7-203.
Review and Tracking of Colorado Wildlife Commission Meeting Agendas
Strategic plans and changes to regulations and policies are typically reviewed by the
Governor- appointed Wildlife Commission. Agendas and materials for Wildlife
Commission meetings are posted on the internet.It could be beneficial for the city to be
aware of proposed changes in state regulations or policies that could affect the city’s
management of prairie dogs.
Action Item:
15)Review the Colorado Wildlife Commission meeting agendas for
actions that could affect the city’s prairie dog management.
52
State Relocation Policies
The CDOW Administrative Directive W-17 describes the permitting program for capture
and relocation of prairie dogs. The directive was completed in 2000. The CDOW
policies for relocation permit review are inconsistent with regard to the attributes of
receiving sites to be evaluated and the thresholds for judging a receiving site acceptable.
They are also inconsistent with regard to the attributes of sending sites to be evaluated—
especially with regard to plague and the treatment of animals originating in colonies
where plague has been active.
During the six years since the administrative directive was released, the CDOW and
affected parties learned a great deal about relocation and the key attributes important for
project success and compliance with CDOW goals and purpose. In response to these
changes, and in order to improve the policy, CDOW staff will be working to revise the
Administrative Directive W-17. The city of Boulder will participate in review of
proposed modifications and provide input on changes to the state policy.
Action Item:
16)Develop recommendations to the CDOW to address inconsistencies
in the state’s relocation policies and permitting.
Prioritization of Action Items
Short-Term Action Items Priority
1)Develop amendments toResolution #842 for Council consideration.1
2)Review Wildlife Protection Ordinance for possible amendments. 1
4)Revise site review criteria to eliminate conflicts with the UWMP. 1
6)Prioritize thecompletionof the OSMP Grassland Plan.1
16)Develop recommendations to the CDOW to address inconsistencies in1
the state’s relocation policies and permitting.
5)Consider revisions to the BVCP during the next major update to clarify 3
where biodiversity and ecosystem conservation will be emphasized
relative to the planning areas.
7)Develop a prioritized list of easementsand other property acquisitions in3
areasidentified for long-term protection.
8)Develop policy guidanceto review properties for inclusion in OSMP HCA 3
system.
14)Develop a legislative strategy to modify or repeal C.R.S. 35-7-203. 3
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On-Going Action Items
9)Work with property owners to develop site management plans to 1
protect and contain or remove and exclude prairie dogs.
10)Provide technical assistance to city departments to implement UWMP1
recommendations.
3)Continue administrationof Wildlife Protection Ordinance and lethalcontrol1
permitting process.
11)Conduct annual inventories of prairie dog colonies and prioritize2
annual removal and relocation efforts.
12)Develop and maintain an on-going list of potential relocation sites. 2
13)Continue participation in and management of the Front Range Prairie 2
Dog Working Group
15)Review the Colorado Wildlife Commission meeting agendas for actions 3
that could affect the city’s prairie dog management.
The action items listed above with a priority #1 are those work items that need to be addressed in
the near future to resolve city policy inconsistencies and prevent some of the current issues from
escalating. Priority #2 items are those actions that would improve or enhance our success at
managing prairie dogs within the city and would occur on an on-going basis. Priority #3 items
are actions that would be helpful to the program but do not necessitate immediate action.
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Appendix A:
Colony Reports
55
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Appendix B:
Evaluation of Management Tools
There are several tools for accomplishing the management actions outlined in Chapter 3. It is
likely that a package of management tools will need to be used in each of the areas occupied by
prairie dogs. This chapter provides an analysis of the benefit, feasibility and costs of tools that
are currently available or show promise of addressing the goals of the plan. The box below
describes the evaluation criteria that were applied to the following management tools:
Containment and Exclusion
Visual barriers
o
Hardscaping as a barrier to excavation
o
Removal
Relocation
o
Lethal control
o
Trapping and killing
Burrow fumigation (use of poisons)
Birth Control
Benefit
A strategy is beneficial if it provides protection of prairie dogs or conflict resolution
at a given site. Strategies that leverage other approaches, or are effective across
multiple sites or have long-lasting outcomes are considered more beneficial.
Feasibility
The overall feasibility of a management action is dependent upon the availability of
people; the time, talent, experience and support to carry it out. It is also critical that
the strategy appeal to the motivations of community members who must support the
management. Strategies that are simple, have been proven effective before, and for
which funding are available are more likely to be successful.
Cost
Strategy costs were estimated for the appropriate time horizon and capped at ten
years (for strategies that may continue indefinitely). Costs estimates were based
upon 1) one-time costs, 2) annual costs, 3) person hours, and 4) frequency.
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Containment and Exclusion
Visual Barriers
As prairie dog populations increase the colonies tend to grow as the second year males are forced
out of the colonies. While there is some evidence that prairie dog populations grow more slowly
under crowded conditions, numbers still tend to increase and there are second year males that are
dispersing. Colony growth and dispersing individuals often results in conflicts with neighboring
properties. A successful prairie dog protection area in an urban setting needs a means to
discourage colony growth and dispersal to nearby properties. The most common approach to
colony dispersal is the use of barriers.
Benefit: Barriers can reduce conflict by controlling the dispersal of prairie dogs onto
areas where they are not wanted.
Visual barriers alone, however, are not likely to offer 100% effective containment. If
prairie dogs continue to reproduce, colony density will continue to increase. At some
point dispersing young will be forced to find a way over, around or through a barrier.
Prairie dogs quickly find the way out where barriers are not continuous around the
exclusion/containment area or where gates are needed for people or vehicles to enter and
leave the area. Furthermore, barriers that are effective at containing or excluding prairie
dogs can also restrict the movement of other small and medium sized terrestrial animals
such as mice, toads, salamanders, frogs, snakes, and lizards.
A variety of site conditions on protection and removal areas as well as adjacent lands can
affect the degree to which barriers are effective. Barriers are most effective in flat areas
where the prairie dogs cannot get a hillside view of adjacent lands and, when installed
with an adequate buffer between the barrier and the currently occupied landscape. On the
other hand, barriers are not particularly effective in situations where the manager is trying
to contain prairie dogs in sparsely vegetated areas surrounded by rich grass cover. Visual
barriers can be long-lasting if constructed out of durable materials and installed with
attention to high winds and exposure to sun. Longevity is also dependent upon the
consistency of monitoring and maintenance.
Feasibility:The construction of barriers is viable. Fencing contractors in the Boulder
area specialize in the construction of prairie dog barriers.There are OSMP and Parks and
Recreation staff who have experience in building and maintaining visual barriers.
However, the city does not currently have the capacity to build or maintain visual barriers
on other lands or throughout all of the city park system.
City staff has found that barriers are relatively simple to construct and install. Staff has
heard that private landowners are satisfied with the work of contractors, indicating that
barrier construction is not significantly more complex for those with less experience
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managing prairie dogs. Cost-share projects to establish visual barriers on lands managed
by multiple owners could be complex and require special agreements.
Visual barriers appeal to motivations of many members of the community because the
strategy offers a non-lethal alternative to prairie dog protection and conflict resolution
and appears to have few obvious effects on non-target animals. On the other hand, some
people find visual barriers to be visually obtrusive and aesthetically unacceptable.
Costs: The one-time costs associated with visual barrier construction range from $7 to
$17 per linear foot depending upon the material. Fencing a square one acre area would
cost between $5,900 and $14,000. Ongoing costs include monitoring and maintaining the
barrier at approximately $500-$1,000 per acre annually. A higher initial investment
would reduce the annual maintenance costs, especially in early years. Additional costs
would be associated with plantings that might be used to soften the visual impact of a
visual barrier. Staff has not estimated the range of costs for plantings and maintenance.
Hardscaping as a Barrier to Excavation
Under natural situations, prairie dogs will not occupy areas where they cannot excavate burrows.
Managers of developed areas have begun experimenting with the use of buried wire mesh
(chicken wire or hardware cloth), pavement and layers of rock (rock mulch) to discourage prairie
dog burrowing.
Benefit: Pavement, rock mulch and wire meshbarriers can reduce conflict by controlling
the establishment of prairie dogs in areas where they are not wanted. Wire mesh barriers
also have the advantage of being an effective stand-alone strategy for excluding prairie
dogs where they are not already established. In addition, hardscaping can be used around
occupied areas as a tool to limit the spread of a colony. However, because prairie dogs
are likely to walk across hardscaped areas, this approach alone is unlikely to be effective
alone as a strategy for containment. Containment strategies also do not address continued
reproduction, and pressures on prairie dogs to disperse. The effectiveness of hardscaping
increases if the barrier is placed throughout an exclusion area and all around a
containment area. The movement of people, vehicles and other animals across the surface
is unaffected. Since it results in the destruction of burrow entrances, hardscaping will
reduce the availability of prairie dog burrows for use by species such as burrowing owls
and other burrowing animals such as pocket gophers.
Hardscaping requires that the vegetative cover be disturbed or removed from an area.
Areas treated with wire mesh can be restored to grass cover, while there are fewer
planting options for stone mulch, and none for paving. This approach has broad
application in urban areas where it is likelythat development, landscaping or other land
use practices will result in the removal of vegetation and soils. The need to disturb native
vegetation and soil over large areas means that this would not be a beneficial strategy in
natural areas. Hardscaping for prairie dog management is a relatively recent innovation,
and it is unclear how long wire mesh would remain effective. Paving and stone mulch
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are probably fairly stable over time, especially with periodic monitoring and
maintenance.
Feasibility:Hardscaping is a viable tool. There are contractors in the Boulder area that
specialize in paving and concrete, and landscaping. The installation of wire mesh and
restoration of grass (or other) cover is a relatively straightforward project for landscaping
contractors. City staff has some experience in building and maintaining hardscaping
applications; however, the city does not currently have the capacity to build or maintain
hardscaping on other lands.
Hardscaping like visual barriers is appealing because it is a non-lethal alternative and has
limited unwanted effects. Hardscaping applications vary in their visual appeal, but
provide a number of choices (wire meshbeing essentially invisible once the ground
surface is revegetated). Establishing hardscaping on private lands or lands managed by
other agencies could be complex and require special agreements.
Costs: The one-time costs associated with hardscaping include the costs of site
preparation, materials, installation (including revegetation if applicable). In addition to
the material costs, there are also site preparation and revegetation costs which would
double or triple the area cost. On-going costs are probably relatively low, but capacity
would be needed for periodic inspection and repairs.
Removal
Relocation
Relocation of prairie dogs normally involves live capture by trapping prairie dogs on the ground
surface, or removing them from their burrows. Burrow removal techniques include flushing
burrows with a water/soap mixture, or vacuuming prairie dogs out of their burrows. It is
common for relocation projects to include a combination of specific techniques. Once captured,
prairie dogs are transported and released at sites deemed suitable by CDOW and if across county
lines, by appropriate county officials.
Benefit: The relocation of prairie dogs can address conflicts in removal areas, and may
reduce dispersal related issues in protected areas. Relocation is a strategy with
widespread application and has similar effectiveness across sites. The effects of
relocation for removal can be long lasting, but require that all prairie dogs be removed
from a site and that effective means of excluding re-colonization are also implemented.
Relocation is seldom completely effective at removing all the prairie dogs from an area.
Relocation for population reduction is a short-term strategy and needs to be repeated
periodically to have long lasting effects.
Feasibility: Relocation is also a viable tool. There are contractors and some volunteer
organizations in the area that provide prairie dog relocation services. The city has had
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problems with the reliability and capabilities ofsome contractors. In addition, city staff
has developed experience with trapping and burrow flushing on city land; but do not have
the capacity to offer these services to others in the community.
Relocation techniques vary in their appeal to members of the community. There is
controversy about success rates, “humaneness” of the process and mortality rates for
relocated animals. However, relocation is generally preferred to lethal alternatives.
Impacts to some non-target animals may be higher if burrow flushing and vacuuming is
combined with live trapping, however, flushing can also increase the survivability of
other non-target animals. Some membersof the community are especially opposed to
vacuuming because they say this technique exposes prairie dogs to a greater risk of harm.
The practicality of relocation is limited by the availability of receiving sites. There are
currently few or no receiving sites in Boulder County and state regulations require the
county commissioners’ approval for relocations that cross county lines. Commissioner
approval, especially outside Boulder County, is not considered likely.
Prairie dog relocation is not simple. Preparation for relocation requires pre-planning to
obtain the necessary authorizations and permits, receiving sites and contractors (or
staffing and materials). The state and federal permitting processes usually take a
minimum of thirty days and often up to sixty days. Contractors and permits must be
schedule for particular times of the year when relocation is effective or not required to be
followed by lethal control. Once the planning is complete, relocation implementation is
opportunistic because it is strongly influenced by weather conditions.
Costs: Costs estimates range from $60 - $200 per animal relocated. Estimates of average
prairie dog densities on in the Boulder Valley range from 13-49 animals/acre. The cost
for relocating prairie dogs on one acre could range from $800 to $9,800. The range of
cost/acre for relocation reflects some of the feasibility issues, the availability of
volunteers and the differences among flushing, vacuuming and live trapping. If the
receiving site does not have pre-existing burrows, restoration costs associated with
creating artificial burrow systems can be substantial. Follow up treatments with
trapping/killing or burrow fumigation to ensure 100% removal would increase costs. If
constructed barriers are needed to preventrecolonization, there would be additional
barrier costs. On-going costs for this strategy would be dependent upon prairie dog
recolonization of the site.
Lethal Control
City Council has clarified the city’s preference that lethal control measures be used only as a last
resort in section 6-1-1 of the Boulder Revised Code (see Six-step process on page 17).
Removal and Killing
This management technique involves live capture by the methods described under
relocation. Prairie dogs may be killed on site or transported live to the federal black-
footed ferret recovery program to support the re-introduction of this federally endangered
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species. Prairie dogs are a natural food source and prey base for ferrets and are integral
to the ferret recovery program. Prairie dogs that are used in ferret transition programs are
suffocated by carbon dioxide gas (CO) in a controlled chamber. The lethal treatment
2
occurs either on-site or at an off-site facility, depending on the contractors capabilities.
Prairie dogs are then stored (frozen) and delivered to recovery programs for black-footed
ferrets or raptor rehabilitation programs.
Extensive documentation of the effectiveness and guidelines for the use of CO to kill
2
animals has been developed by the American Veterinary Medical Association (AVMA)
and Humane Society of the United States (HSUS).
Benefit: This approach shares the benefits, and limits of relocation.
Can effectively remove prairie dogs.
Can reduce prairie dog density
Can be applied in a variety of sites
.
Long term effectiveness requires complete removal and burrow flushing, live trapping
and vacuuming are seldom 100% effective.Removal and killing is not a stand-alone
strategy, removal applications will require exclusion measures to ensure the area will not
be re-colonized and may require the use of other lethal means to achieve 100% removal.
Feasibility: The removal aspect of this project shares the following aspects of feasibility
with relocation.
Contractors are available to capture and kill prairie dogs.
Staff has experienced reliability and capability issues with some contractors.
Complexity of prairie dog removal projects (although no receiving site is
needed).
Variable public support for live-trapping, burrow flushing and vacuuming.
The need for live prairie dogs is affected by the demand; the ferret recovery program
does not always accept prairie dogs. The transport of live prairie dogs is also more
complex than transporting dead and frozen animals since there are permit requirements
for transporting live prairie dogs.
Killing prairie dogs is not consistent with the motivations of the community. City policies
unequivocally state that lethal control is considered a last resort and city regulations seek
to ensure that other non-lethal alternatives are explored. When there is no alternative to
lethal control, it is the city’s policy to encourage, live trapping,individual killing to
minimize suffering and the use of prairie dogs in animal recovery programs.
Costs: Costs for removal and killing (using CO) range from $1,800-$2,500/day for
2
initial treatment. Estimates prepared for the case study suggest a formula where a day is
needed for each 2-3 acres. This translates to a $600-$1,200/acre cost for initial treatment.
Subsequent treatments to ensure 100% removal would add additional costs.
Transportation costs for moving live prairie dogs to ferret transition projects vary and are
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not included in these estimates. If constructed barriers are needed to prevent
recolonization, there would be additional barrier costs.
Burrow Fumigation (Use of Poisons)
This method involves the use of fumitoxins (fumigants) to poison prairie dogs. There are
two types of fumitoxins that are typically used to kill prairie dogs; zinc phosphide treated
grain (oats) and aluminum phosphide tablets.
Zinc phosphide-treated oats are placed by prairie dog burrows after a period of pre-
baiting with untreated oats. When prairie dogs feed on the treated grain the zinc
phosphide reacts with moisture and acid in the animals’ stomach to produce a poisonous
phosphine gas.
Aluminum phosphide pellets are placed into prairie dog burrows and the nearby burrow
entrances are sealed. The aluminum phosphide reacts with soil moisture to produce
poisonous phosphine gas which is inhaled by prairie dogs.
Depending upon the dose, phosphine poisoning can result in death within minutes or after
several days. Both of these fumitoxins are “restricted use” pesticides and may only be
applied by a licensed pesticide applicator and in a manner consistent with labeling
requirements. Zinc phosphide may onlybe used from July1 through January 31
Aluminum phosphide is labeled for use throughout the year but is only effective when
soil temperatures are above 40 degrees and soil moisture levels are high.
Benefit: Poisoning prairie dogs is an effective means of removing prairie dogs from areas
where they are not wanted or for reducing prairie dog populations. Fumitoxins have been
used in a variety of settings and have broad applicability. While poisoned grain can kill
up to 90% of prairie dogs on a site, repeated application of burrow fumigants can kill all
prairie dogs in the area treated. The effects of poisons, like any method of removal, will
have long-term effectiveness only if prairie dogs are excluded from re-colonizing the site.
On the other hand, poisons have impacts on non-target animals. Birds and other small
mammals can be poisoned when feeding upon zinc phosphide-treated grain. In an urban
setting this management strategy poses a very great risk to human health especially to
children who could accidentally ingest poisoned grain. Burrow fumigants kill all
vertebrates (amphibians, reptiles, birds,mammals) and most other animals living in
treated burrow. Aluminum phosphide is extremely flammable and both poisons are
hazardous to aquatic life.
Feasibility: Qualified and experienced certified pesticide applicators are available to
poison prairie dogs. Poisoning is relatively simple.
Despite the fact that poisoning is possible to undertake, it clearly does not appeal to the
motivations of many members of the community. There is general agreement that
poisoning wildlife is undesirable. It is the city’s policy to encourage and, where
appropriate, require parties to exhaust all other options prior to the use of lethal controls.
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Fumigant poisoning is considered particularly undesirable and is not considered a
humane alternative by the AVMA and the HSUS due to length of time to death (hours to
days) and symptoms of death (caustic erosion of mucous membranes, hemorrhagic
bleeding, vomiting, pulmonary edema).
Costs: Costs estimates for prairie dog poisoning include a set up fee of about $500 and a
charge from $2.50-$3.50 per hole. Burrow entrances density counted at 35 sites around
Boulder ranged from 40-145 holes/acre. That translates into a “per acre” cost ranging
from $600 to $1,000. It is likely that repeated treatments would be necessary for
complete removal of prairie dogs. If constructed barriers are needed to prevent
recolonization, there would be additional barrier costs.
Emerging Management Techniques: Birth Control
There are several instances where natural resource managers have interrupted the reproductive
cycle of animals as an alternative to lethal control. As prairie dog management begins to affect
communities concerned about humane treatment of animals, new attention could be focused
2
upon birth control techniques.
The idea behind birth control for prairie dogs is straightforward. A chemical would be
introduced into the diet of prairie dogs through treated bait. This chemical would inhibit
reproduction. A certain percentage of the population would be affected and fail to reproduce.
Prairie dogs would continue to die from natural causes, but due to the introduction of the birth
control, fewer prairie dogs would be born. By adjusting the doses of birth control, managers
could use this technique to eliminate the prairie dogs from a site or reduce populations to more
sustainable levels.
Benefit: Birth control or chemosterilants have not yet been demonstrated to be an
effective technique for removing prairie dogs or controlling their numbers. If successfully
developed this technique could be used throughout the study area because of ease of
access (necessary for delivering the chemical to the prairie dogs). The use of birth
control, like other control techniques would also require that effective means be
developed to prevent recolonization of removal areas or emigration into protection areas
where population numbers need to be lowered.
One of the greatest difficulties with chemosterilants is that they are not species specific.
Therefore grain treated with a chemosterilant agent could be ingested by birds or other
small mammals reducing reproductive success of non-target organisms. Some agents are
2
Surgical sterilization is anoptionused forpopulation control ofpets, including petprairie dogs, and some
wildlife (e.g. beavers). This approach relies uponthe same removal tools that havebeenpreviously
analyzed as well as a surgical procedure thatwould add to the cost. Complications associated with surgery
as well as practicality and costs issues kept this alternativefrommore thorough analysis.
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also known to bio-accumulate, which means that predators (such as hawks, eagles or
coyotes) feeding upon prairie dogs could also be affected.
There have been at least two field trials to test the potential of chemosterilants in
controlling prairie dog populations. In one of these studies, conducted in Fort Collins the
investigators observed a 59% reduction in the proportion of observed young to adults
when comparing the treated colony with the control. More study is needed to determine
the effectiveness of chemosterilants.
Feasibility: There are currently no chemosterilants available for use to control prairie
dogs. Consequently there are no people with the experience to carry out this strategy. It
does however appeal to the motivations of the community as it is an alternative to lethal
control. Feasibility would be greater if funding were available for research into this
alternative (perhaps by a coalition of governments and land management agencies).
In addition to developing a better understanding of the effectiveness of different
chemosterilants, there are several practical matters that need to be resolved before this
technique is available for managers. These include obtaining federal registration of the
agents for use in the field, determining dosage requirements, and optimal bait
formulations.
Costs: The cost effectiveness of this approach cannot be determined due to the many
questions about effectiveness, dosage, and delivery systems all of which are currently
unknown.
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Appendix C:
Policies and Procedures
Procedures for Removal of Prairie Dogs from City Properties
The following procedures guide city departments in the removal of prairie dogs from city
properties. These procedures affect properties identified as removal areas under this plan.
Properties exempted from these procedures include the Boulder Municipal Airport and the
Boulder Reservoir Dam buffer areas.
1.Notify the city manager of the intent and timing to remove prairie dogs from a site a
minimum ofX monthsprior to the earliest planned date for removal.
2.The city manager will post notice the Daily Camera under “News From City Hall” of the
intent to remove prairie dogs from a site and solicit input from the public on a possible
relocation site in and allow a 60-day public comment period.
3.If a potential relocation receiving site is identified prior to the deadline for public
comment, staff will investigate the feasibility of using the site for relocation. If the site is
feasible, the city manager will notify City Council and staff will follow the relocation
procedures below.
4.If no relocation receiving sites are identified prior to the deadline for public comment,
staff will proceed to remove prairie dogs from the site with the following steps:
a.Investigate potential for donation of animals to an animal recovery program
(ferret or raptor).
b.Develop a plan and cost estimate for trapping (which may involve flushing) and
lethal control through the use of CO chambers.
2
c.Obtain a Special Permit (Section 6-1-39, Boulder Revised Code) from the city
manager for the use of lethal control.
d.The city manager will notify City Council of the issuance of a special permit.
5.The city manager may exempt any department from the above procedures at his
discretion with prior notice to City Council.
Relocation
The following relocation policy applies to city-owned and managed lands. This policy
supercedes all previous internal policies as approved by the city manager.
Purpose
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The purpose of this policy is to establish a protocol for prairie dog relocation activities from city-
owned lands. The policy also outlines best management practices for city activities in prairie
dog habitat that do not require prairie dog relocation or permanent habitat destruction and will
not cause direct harm to individual prairie dogs.
Scope
This policy applies to all city lands or activities in prairie dog habitat.
Policies and Procedures
A.The city department managing a parcel of land shall be responsible for managing
prairie dogs on that land.
B.The city department responsible for managing the receiving site will be
responsible for managing all relocation activities involving that site.
C.The city shall maintain a geographic information system showing the location and
distribution of prairie dog populations throughout the Boulder Valley. The
information in the GIS will be provided to OSMP by departments managing lands
with prairie dogs. Standards for prairie dog mapping will be developed, agreed
upon and followed by all departments. Mapping costs shall be borne by the city
department controlling or managing the property.
D.All costs associated with relocation are the responsibility of the sending
department. An estimate of costs shall be agreed upon among the sending and
receiving site managers, in writing, prior to the start of work. Costs include,
without limitation, labor and expenses for trapping, transport of prairie dogs and
receiving site preparation. Costs may also include visual barrier placement and
maintenance, survival (relocation success) monitoring and receiving site
restoration.
E.The city manager shall be responsible for approving, approving with conditions,
or denying all relocation activities affecting city-owned properties in accordance
with applicable management plans.
F.For prairie dogs on city-owned lands, relocation shall be considered if any one of
the following criteria is met:
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1.There is an approved development plan that is scheduled to begin construction
within a one-year time period;
2.Protection of the habitat on the site is infeasible, as determined by the city
manager, due to unmanageable conflicts related to development, construction
of public infrastructure or public safety;
3.There is a legally substantiated or imminent threat to public safety resulting
from the presence of prairie dogs, including without limitation, a threat from
burrowing around a dam.
4.The prairie dogs are causing direct harm to a building structure or utility
infrastructure and all other alternatives to mitigate the impact have been
exhausted.
5.Relocation is necessary to meet the objectives of plans describing the
management of protected colonies (Protected Areas and HCA’s), or removal
areas. Such plans include the OSMP Grassland Ecosystem Management Plan,
or the Urban Wildlife Management Plan.
G.If public safety is a concern, the city manager shall make the final decision on
relocation after consultation with the City Attorney’s Office and the appropriate
staff from OSMP and the managing department.
H.City departments shall first considerproperties under their own management for
relocation.
I.All city trapping and relocation activities involving city properties shall be
provided by the city department responsible for managing the land or contracts
administered solely by the city department involved.
J.City trapping and relocation activities not involving OSMP properties may be
conducted by other qualified city staff or an outside consultant permitted by the
state after coordination with the OSMP and approval by the city manager.
Standards for Relocation
A.All relocation activities shall be permitted by the state and shall adhere strictly to
state permit requirements and guidelines as specified in the CDOW
Administrative Directive W-17 on the Capture and Relocation of Prairie Dogs
(March 9, 2000).
B.Prairie dogs shall only be relocated between June 1 and March 1 and only when
favorable weather and ecological conditions are present during this period.
Absolutely no trapping or relocation shall occur between March 1 and June 1.
C.No trapping or releasing shall occur during inclement weather. Inclement weather
includes, without limitation, periods when temperatures are above 90°F or below
35°F. Inclement weather also may include days when heavy precipitation is
occurring, has occurred recently, or is expected to occur.
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D.Whenever possible, receiving sites shall be previously occupied prairie dog
towns.
E.Prairie dogs shall not be relocated into areas affected by the plague for a
minimum of one year after a plague event. If prairie dogs must be relocated to an
infected area in less than two years, precautions shall be taken to minimize the
spread of plague.
F.Following a relocation effort, the department managing the sending site is
responsible for protecting the site from recolonization of prairie dogs by
employing the following techniques as appropriate:
Disking or plowing the site to destroy inactive burrows.
Backfilling and plugging all inactive burrows within the area from which
prairie dogs were removed.
The use of temporary barriers such as silt fencing.
Construction of a permanent barrier.
Hardscaping.
G.The landowner is encouraged to time the commencement of construction within a
few days of the completion of the relocation activities to prevent recolonization.
Best Management Practices for Activities in Prairie Dog
Habitat
The following best management practices apply to city activities in areas where there are
burrows occupied by prairie dogs, and in areas where there are occupied or unoccupied prairie
dog burrows in Habitat Conservation Areas (as identified in the BTPD), or prairie dog Protection
Areas (as identified in the UWMP). The following best management practices apply to city
activities that will result in soil disturbance; areshort-term in duration; and do not require prairie
dog relocation or permanent habitat destruction. These policies shall be revised as practice and
research presents new information:
A.Provide public notice of the nature, purpose, and duration of the activity at the site
in a prominent location prior to commencement of the activity. Public notice is
required to alert the public to the purpose, intent, and procedures of the activity
relative to the provisions of sections 6-1-11 and 6-1-12 of the Boulder Revised
Code. The notice shall meet the following standards:
1.The notice must be placed at a trailhead leading to the site of the activity,
and/or placed in a visible location along the street abutting the property where
the activity will occur.
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2.The notice must be placed on a weather-proof sign according to following
specifications:
no smaller than 8 ½” x 11” in size if placed on a trailhead bulletin board
no smaller than 24” x 32” in size if posted as a free-standing sign.
3.The notice must remain in place for the duration of the activity.
B.Consult with qualified plant and wildlifeecologists prior to beginning the project
and for post-project reclamation. Construction and/or restoration plans must be
reviewed by a qualified ecologist and demonstrate minimization of impact to
prairie dog habitat as well as to existing soils and native vegetation.
C.Avoid all construction and/or restoration activities in prairie dog towns from
March 1 to June 1 unless: 1) the nature of the work would cause minimal
disturbance to the prairie dogs or their habitat; 2) the required relocation efforts
have been completed; and 3) the construction activity during this period is critical
for the immediate public health, safety, and welfare of the community or the
success of the restoration project.
D.Temporarily flag as many burrow holes as possible and flag the approximate
extent of the burrowing system. Concentrate activity around the periphery of
prairie dog towns to the extent possible.
E.Overall disturbance to the area where prairie dogs are located shall be minimized.
Keep vehicles and construction equipment as far away as possible from the prairie
dog town.
F.If irrigation is planned following seeding or planting, do not allow water to enter
active burrows during the time that the young pups may be still confined to the
burrows (from March 1 to June 1) and unable to escape the water.
G.Earth-moving equipment, tractors, seed drills, and other restoration equipment
should progress through the area at as slow a rate as possible to avoid direct injury
or mortality. However, the project should be completed as quickly as practical.
Interpretation
Employees with questions concerning possible conflict between their interests and those of the
city, or the interpretation and application of any of these rules, should direct their inquiries to
their department director. The department director may refer the matter to the city manager for
final resolution.
Exceptions or Changes
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This policy supersedes all previous policies, rules or regulatory guidance covering the same or
similar topics. Any exception to this policy may be granted only by the city manager. This policy
may be reviewed and changed at any time with the approval of the city manager.
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