Comments on proposed prairie dog management changes for hearing July 12From:Kevin Markey
To:OSBT-Web
Cc:Dave Kuntz; Jon Carroll; Michelle Estrella; Brady Robinson
Subject:Comments on proposed prairie dog management changes for hearing July 12
Date:Wednesday, July 12, 2023 3:11:41 PM
External Sender
Comments on Proposed Prairie Dog Management Changes
Open Space Board of Trustees, Hearing on July 12, 2023
Introduction
My name is Kevin Markey. My wife and I live about 3/10 of a mile south of the Bennett and
Steele properties. We farm a portion of our 39 acres for vegetables and fruit, producing
produce for sale at various local markets, and jellies, jams, and relishes for sale under the
Cottage Foods Act at seasonal fairs and markets. We lease most of our property for dryland
grazing. We have our own prairie dog control problem, and we attempt – at considerable cost,
especially the physical labor involved – to keep the population down at a dull roar.
We are concerned about the poor management of OSMP properties because of the weeds they
spread and the migration of prairie dogs in the neighborhood. And we are concerned because
of the burden the properties place on our good neighbors.
Reaction to Staff proposal
I will specifically address each of the proposals contained in the motion Staff has proposed the
the Board of Trustees make and approve. My wife and I oppose several of the provisions
without modification. My comments are interpolated in-line. The original text is in italics.
Staff requests Open Space Board of Trustees make a motion to:
1) Recommend that staff implement modifications to the management approach of reducing
prairie dog conflict on irrigated agricultural properties beginning in 2024 including:
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.
Staff has entirely eliminated any mention of the Categories that came under such
withering scrutiny at the June meeting. But reportedly, such categorization is still used
internally. This has the unfortunate effect of making Staff judgments about each
project property entirely opaque. It would have been sufficient to retain the categories,
clarify the conflicting definitions, and explicitly state that they were “descriptive and
not prescriptive.” We had commented that they were a potentially useful
communication and management tools if used right, but now we have nothing to peer
into bureaucratic abyss. Hence, we repeat our recommendation that Staff publish on-
line concise (no more than 1 page each) narratives for each property, identifying key
statistics, status, biological indicators, planned and ongoing activities and investments,
irrigation issues, and barriers to prairie dog control. See below for suggested narrative
content.
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.
First, an important quibble. These are really two separate proposals, and should be
separated here into separate bullets.
On the first point, we oppose the expansion of the program outside the northern project
area unless there is a promise to make a firm commitment that between 50% and 65%
of the prairie dog control acreage remain in the northern project area, and that lethal
control be increased. Otherwise, our neighborhood’s needs risk being ignored.
The second point, to allow more liberal burrow disturbance, has our full support.
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.
This is a good development. It should enable increasing lethal control to the full 200
acres per year approved by the Council. Given the difficulties, costs, and relative
ineffectiveness of relocation, the Board and Staff should make this commitment.
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.
This is not really a policy statement. It is merely a statement of reality that makes a
commitment to lethal control over 200 acres per year essential.
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.
This is also not really a policy. It is merely a statement of a job that the Staff should be
doing on a regular basis.
What is needed is a commitment to restore irrigation to match or improve on irrigation
in place when the property was purchased. Rent, lease, buy, exchange, or move water
rights and upgrade water systems for properties that are short of water in the north
project area. Do not remove or release existing water rights. The Staff should prepare
an assessment of these needs by the end of this year, in time to submit for funding
commitments for 2024 work.
We have recently learned from a neighbor that OSMP inaction on irrigation
infrastructure makes it impossible for him to irrigate and manage his own property.
This is unacceptable.
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.
This again seems to be merely a restatement of ongoing practice, not a new policy.
Nonetheless, until irrigation infrastructure and other challenges are met, it is premature
to change property designations in the northern project area, especially since some
resources are now being diverted from the northern project area.
2) Recommend that City Council approve modifications to the geographic scope of the
program, to expand implementation of the project, including the use of lethal control, beyond
the previously defined northern project area to encompass irrigable agricultural properties
system-wide that are designated as transition and removal areas. This approval should
include replacement of the existing burrow disturbance rule to allow burrow disturbance to a
depth of 6 inches or 12 inches with prior notification, system-wide on irrigated agricultural
properties.
This is a restatement of item 1 (b) for purposes of Council action. The first part is
unacceptable without the commitments requested above.
Neighbor relations
Entirely missing from the Staff’s proposal is an explicit policy reestablishing good neighbor
relations. The Board needs to set policy in this regard. Specifically, legal impediments must be
overcome to immediately implement a barrier cost-sharing program. Weeds and erosion must
be effectively managed on all OSMP agricultural properties. We recently saw OSMP mowing
weeds on some (but not all) of Bennett and Steele properties. This was the first time we’ve
seen this done in years. We pray it was not merely a cynical move to look good in the face of a
planned field trip to the properties. Finally, Staff needs to more effectively communicate and
collaborate with neighbors. We have knowledge and ideas we can share to ease their work and
increase their effectiveness.
Per-property on-line narrative
Here are some details about what would be useful to see in an on-line narrative for each
property. Members of the public have attempted to compile some of this information,
sometimes with difficulty, and sometimes being told that information they found was out-of-
date or inaccurate. If we are to have a productive conversation, we need up-to-date
information on the history and status of each property. We envision not more than one page or
so of information concisely stated.
Name of property, location, overall size of property or portion if segmented, acquisition
cost.
Who manages it?
Agricultural lessee (if any), crops, acreage of each.
Condition of property when acquired.
Water rights when acquired.
Acreage historically irrigated.
Acreage with prairie dogs, and irrigated acreage overlapping with prairie dogs
Current prairie dog population
Control goal of management classification
Current control and/or management activities
Future control and/or management activities
Estimated cost of achieving stated control goal, itemizing principal components (PERC,
barriers, infrastructure, water rights, plowing)
Specific management challenges
Irrigation infrastructure
Water rights
Biological conflicts
Other issues
Neighbor issues, requests, conflicts
Alternative proposal
For your convenience, here is an alternative to the staff proposal that addresses our concerns.
Additions or modifications to the Staff recommendation are in boldface.
1) Recommend that staff implement modifications to the management approach of reducing
prairie dog conflict on irrigated agricultural properties beginning in 2024 including:
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. In support of better communication with the public and with other
agencies, make available and keep up-to-date a concise on-line narrative for each
property, identifying key statistics, status, biological indicators, planned and ongoing
activities and investments, irrigation issues, and barriers to prairie dog control.
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 area so long as at least between 50% and 65% of the prairie dog
control acreage remain in the northern project area.
c. 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.
d. 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, and increase lethal control to the full 200 acres per year approved by the
Council with the cost savings made possible by the in-house capacity and to make up for
the loss of relocation acreage.
e. 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.
f. By the end of 2023, identify funding and capacity to address irrigation infrastructure needs
ahead of prairie dog removal on properties where irrigated agriculture is limited by irrigation
infrastructure. Obtain funding commitments necessary to restore irrigation to at least
match irrigation capacity in place when the property was purchased.
g. Continue to apply Grassland Plan management designation criteria to properties where
conditions have changed to ensure management designations are up-to-date and appropriate,
but delay any redesignations in the northern project area until infrastructure and other
challenges are resolved.
h. Improve neighbor relations, by determining how to overcome legal impediments for a
barrier cost-sharing program and implement such a program, by effectively managing
weeds and erosion, and by more effectively communicating and collaborating with
neighbors.
2) Revise the part of the motion regarding Council action consistent with 1 (b).
Thank you for considering our views. Thank you in advance for becoming better neighbors.
Kevin Markey