Comments on Staff RecommendationsFrom:Paula Shuler
To:OSBT-Web
Subject:Comments on Staff Recommendations
Date:Tuesday, July 11, 2023 11:40:17 AM
Attachments:OSBT.7.12.23, Shuler.pdf
External Sender
OSBT Members,
I am completely in line with HEAL’s comments and asks from Elizabeth Black that were sent to you
previously but I have attached my specific comments regarding each staff recommendation with regard to
reducing prairie dog conflicts on irrigated properties beginning in 2024. I hope you will have a moment to
read these comments and consider them before tomorrow evening. I also plan to speak tomorrow night
about a few other issues that were not addressed by staff - one of them being the lack of a good neighbor
policy or even strategy.
I appreciate the time it takes to become familiar with the many issues facing OSMP. Thank you for your
service. I would be happy to answer any questions.
Best Regards,
Paula Shuler
OSBT,
I have been farming in Boulder County for over 30 years on both private and public land. A portion of our
hay fields are next to OSMP’s Brewbaker and Stratton properties. Brewbaker and Stratton are irrigated
agricultural properties, both were irrigated hay fields without prairie dogs when privately owned, and both
properties have been designated “removal” properties for decades. Yet both Brewbaker and Stratton still
contain large emigrating prairie dog populations that negatively affect many private landowners in all
directions. I know a bit about farming, I know a bit about prairie dogs and I know a lot about what it is like
to be a neighbor to an OSMP irrigated parcel with uncontrolled prairie dog populations. I have been very
actively involved in this conversation with OSMP for many many years.
I would like to directly address what staff is recommending in regard to implementing modifications to
reducing prairie dog conflict on irrigated agricultural properties beginning in 2024. My comments, which I
hope you will seriously consider, are below each staff recommendation in red.
a. Evaluate properties based on individual characteristics including challenges and opportunities for use in
support of the prioritization criteria applied in selecting management sites each year.
There is an existing set of removal selection criteria that was approved with the preferred alternative. The
new category system is very challenging because the C and D categories – especially - seem to be providing
a reason, what appears as an excuse, for OSMP to move these properties down the list; a reason or an
excuse not to steward or manage them appropriately and a justification to abandon irrigation, to change
the parcel designation to allow prairie dogs to remain. I believe some of the new categorizations conflict
with the existing removal criteria. What carries more weight - the original criteria or the new
categorizations? I truly hope these categories, priority tiers or characteristics (which is it, they have
morphed several times in the last three months) are descriptive NOT prescriptive but OSMP has not said
that. OSMP needs to say that and be very clear about it. With more planning and work, parcels can
improve in condition and prairie dogs should be removed. Ecological conditions can change at any time and
prairie dogs should be removed. OSMP needs to tackle and continue work on the more challenging parcels,
not just address the easy parcels. OSBT should direct OSMP to continue working on removing prairie dogs
from and improving parcels in EACH of the categories (A – D) every year. More effort needs to be made to
restore all of these parcels to productive agricultural lands.
Yes, farming and agriculture can be challenging and expensive, especially when irrigation infrastructure has
been ignored for decades. The OSMP Master Plan identifies Agriculture Today and Tomorrow Strategy #1 as
“Focus investments on maintaining and improving existing agricultural infrastructure to standards – both
water related and structural”. The City Charter is very clear; one purpose of Open Space is the
“preservation of water resources in their natural or traditional state”. OSBT should be asking why OSMP
isn’t making a definitive plan to fix these parcels instead of what appears to be making a preamble to
abandon the irrigation and find a reason to change the designations.
b. Expand implementation of the project beyond the previously determined northern project area to
encompass irrigable agricultural properties system-wide that are designated as transition and removal
areas and replace the existing burrow disturbance rule to allow burrow disturbance to a depth of six inches
system-wide, or 12 inches with prior notification on OSMP irrigated agricultural land.
Completely agree with this. Great things have been happening on the parcels in the Northern Project Area
that have had prairie dogs removed and have been or are process of being regenerated. OSMP should be
caring for all their irrigated parcels and removing prairie dogs throughout the entire OSMP system.
I believe that, yet I also know that OSMP will not have completed even half of the acres in conflict in the
project area in the first 3+ years and that is very disappointing. To make it even worse, it appears OSMP is
categorizing acres and making excuses why they cannot or should not remove prairie dogs from all of the
parcels that were originally identified in the Northern Project Area. It is critical that OSMP NOT walk away
from the Northern Project Area. This entire management plan was developed for the Northern Project area
and OSBT should ask staff to make a firm commitment that between 50% - 65% of prairie dog removal acres
will be in the Northern Project Area going forward.
c. Implement lethal control, barrier maintenance, and other related tasks in-house by purchasing
equipment and adding staffing to complete this work rather than by hiring contractors.
YES, absolutely. This should have been done several years ago, if it had, the progress in the project area
would have been much greater. Bringing lethal control (and also barrier construction) in-house will allow
OSMP to lethally manage the 200 acres a year as allowed by the preferred alternative. Previously, because
of contractor costs and availability, OSMP has only been managing closer to 100 acres per year. OSBT
should ask OSMP to lethally manage 200 acres annually in 2024 and beyond. It is the only way to keep up
with PD population growth and make real progress.
d. Cease relocation to the Southern Grasslands as directed by the Grassland Plan unless occupation drops
below 10% in the future. Evaluate alternate receiving sites including Prairie Dog Conservation Areas and
receiving sites off OSMP and pursue if found to be feasible. If receiving sites are not available and thus
relocation is not feasible, explore alternative removal options such as trapping and donating to programs
for raptor rehabilitation or black-footed ferret recovery.
Yes, relocations to the Southern Grasslands should cease because occupancy goals have been met. OSBT
should be asking OSMP about desired occupancy levels on PCAs. OSBT should also be asking OSMP what
the current occupancy levels are on existing PCAs. The northern and Eastern Grassland preserves are at
65%+ occupancy, well above the desired 26% occupancy. The PCAs are also bursting at the seams. The PCA
on Niwot Road, which I pass just about every day, is 50% - 60% occupancy and is a fragmented parcel of
prairie dogs and weeds. It is historically irrigable, yet it has been designated a PCA. Management options
are completely restricted on PCAs and MOAs when prairie dog populations exceed desired levels. MOAs &
PCAs are not good options for receiving sites. Trapping and donating makes sense but much more research
needs to be done and information provided to layout the true cost and management of those programs.
e. Identify funding and capacity to address irrigation infrastructure needs ahead of prairie dog removal on
properties where irrigated agriculture is limited by irrigation infrastructure.
It was stated very clearly at the last annual meeting that there is CIP money carrying over. Use that, then
go find more money from the budget. Apply for a grant from SVLHWCD if you need to. Apply for a “large”
Boulder County Sustainability grant if you need to. Although it seems ridiculous that the City of Boulder
cannot allocate money to fix what the City guidance in MANY cases allowed to deteriorate and break. Find
the money and get the work done. The Grassland Plan lists Deferred Maintenance of Irrigation
Infrastructure as a “Low Ranked Conservation Issue”. Deferred Maintenance, to irrigation infrastructure -
to water delivery - one of your most valuable assests - Low Ranked? I’m not sure how to take that, does it
mean not important? Appears so, because infrastructure repairs have been deferred for so long. OSMP is
reporting how expensive the repairs will be and they don’t have the funding or capacity? Makes no sense
and is completely irresponsible that these repairs were not being done for the last several decades. Yes, it
will be expensive after being ignored, but it needs to be fixed not abandoned. Reference the Master Plan
and Charter purpose in Item A. Water is a major focus, and is critically important. OSBT should guide and
spur OSMP to find the funding and the capacity to address every one of the irrigation issues.
f. Continue to apply Grassland Plan management designation criteria to properties where conditions have
changed to ensure management designations are up-to-date and appropriate.
NO. Almost every one of the Removal and Transition parcels in the Northern project area are Significant
Agricultural Lands of Statewide Importance. They were all irrigable when OSMP acquired them. At this
point in time, to change any one of these agriculturally significant parcels to an MOA or PCA and allow
prairie dogs to remain on these parcels and increase in numbers would be wrong. OSMP needs to make a
bigger effort to restore the irrigation on these parcels and to allow them to remain as transition or removal
irrigable properties.
OSMP does not need more acres of protected prairie dogs. OSMP has a goal of 3000+ acres of prairie dogs
and currently there are over 5000+ acres of prairie dogs. How many acres of prairie dogs is enough? How
many acres of prairie dogs is too many? As a farmer, I certainly don’t want this. I cringe every time I see
the conditions of the MOAs and PCAs. Changing any designations to a PCA or MOA will only take away
from irrigated agriculture and allow for more prairie dogs on OSMP lands. The irrigation infrastructure was
put on the back burner for decades. It’s time to come up with some better solutions than changing
designations.
I hope you watched the video that Elizabeth Black sent from the March 31, 2023 wind storm. Unmanaged
and uncontrolled prairie dogs on fragmented OSMP lands lead to barren ground, degraded soils, erosion
and soil loss. Per the City of Boulder Environmental Advisory Board, “EAB believes the preservation of the
City’s irrigated agricultural lands is of the utmost importance for the region’s environment. Healthy
Grasslands are the single most effective terrestrial storage vehicle for carbon, exceeding the effectiveness
of forests. Further, healthy irrigated lands are less susceptible to fire and drought, reduce soil loss, and
ameliorate runoff and flooding risks. Finally, expansive grasslands rather than barren soils act as an
environmental cooler that generally buffers the rate of rising temperatures in Boulder County which is
increasingly struggling under the effects of global warming.”
OSMP does not need to add any more prairie dog acres to their portfolio by creating more MOAs or PCAs.
If any of these parcels are redesignated to an MOA or PCA, it essentially creates a prairie dog feeder parcels
for the surrounding properties and neighbors, spreading weeds and blowing dust far and wide. This project
is about dealing with the prairie dog conflict on irrigated agricultural lands and bringing back some balance
to the OSMP system, not about adding more prairie dogs to the system. Do not allow OSMP to change any
parcel designations, it is too early in the process to give up and make those changes.
Respectfully Submitted, Paula Shuler
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