Background:   

The City of Lubbock, per a mandate (June 3, 2002) by the Texas Natural Resources Conservation Commission (TNRCC) must submit a compliance plan (by August 6, 2002) which outlines planned actions to control the prairie dog population across the Lubbock Land Application Site (LLAS).   The City has sent out Requests for Proposals (RFP) from experienced firms or individuals to provide prairie dog control at the LLAS.   The affected area covers approximately 1,700 acres and the acreage is divided into at least 17 different plots.  The goal is 100% control of prairie dogs on each plot.  

According to the RFP, the issues of greatest concern to the City are (in order of importance):

    A.    Both the long and short-term impacts on the environment, including any
        negative impact on other species or their habitat.
    B.    The percent of control (of prairie dogs) that can be realized and guaranteed.
    C.    Cost
    D.    The estimated time necessary to achieve the desired results
    E.    Qualifications of the pest control operators

In an article on the topic (Lubbock Avalanche Journal, June 12, 2002), the prairie dogs were blamed for the removal of vegetation from the LLAS.  Overgrazing and burrowing by prairie dogs  were listed specifically as vehicles for the potential contamination of ground water.  TNRCC inspector Pat Cooke was quoted as stating “there’s already a history out there, we’re in ground water remediation now, and we want the city to maintain healthy crops out there.”  The article also made the point that, without sufficient vegetation, nitrate levels could become too high, vegetation being necessary to absorb the waste water sprayed onto the site. 

One point that is consistently missing from newspaper, TNRCC, and city reports, is the heavy cattle use of the LLAS.  Cattle grazing will remove and impact vegetation and excrement from the cattle will contribute significantly to the nitrate load on the sites. 



Prairie Dog Burrows:

The TNRCC claims that the presence of prairie dog burrows that descend into the soil column below the root zone allow a more rapid percolation of treated water to the ground water.  In the June 12, 2002 article in the Lubbock Avalanche Journal, Mr. Cooke was attributed as saying that prairie dog burrows are so prevalent that effluent is being sprayed directly into burrows, which extend more than 4 feet below the surface.  The article also stated that the water table is 50 to 90 feet below the surface. 

It is the opinion of the LEAS that the impact of prairie dog burrows on the potential contamination of ground water has not been scientifically determined.  If effluent is getting into prairie dog burrows located under application pivots, how much is in the burrows and how much is reaching the groundwater.  Is this amount significant?    Basing state mandates on anecdotal information and opinion is irresponsible at best.

Cattle and Prairie Dogs: 

The Llano Estacado Audubon Society (LEAS) is not insisting on the removal of the cattle from the LLAS.  We acknowledge the benefits the City can derive from receiving funds from lease agreements.  What LEAS is promoting is the fair and equitable allocation of blame to all of those animals that are removing vegetation from the LLAS.  

Prairie dogs and cattle can and do live harmoniously together.  Numerous scientific publications have noted that prairie dogs improve the forage for cattle.  Both cattle and prairie dogs have demonstrated a preference for grazing together, just as bison and prairie dogs have historically preferred each other’s company.   Additionally, the action of prairie dogs on the health of the soil and vegetation has been shown.  Specifically:

    -Prairie dog burrowing activity works to loosen and churn up the soil, increasing its
        ability to sustain plant life.
    -Their foraging and feeding practices enable a more nutritious, diverse and nitrogen-rich
        mixture of grasses and forbs (broad-leafed vegetation) to grow
    -The enriched vegetation attracts an array of wildlife to a prairie dog town

Canada Geese:

Canada geese concentrate on the LLAS November through February.  The geese appear to use areas where effluent has been applied.   The birds feed on grasses during their time on the Southern High Plains and may be pulling grasses up by the roots and contributing significantly to exposed soils.  Their impact to the removal of vegetation from the LLAS should also be investigated.  


Considerations:

It is the opinion of LEAS that the following considerations must be made before a compliance decision is made:
    A.    Evaluate, scientifically, the impact on LLAS vegetation by prairie dogs.
    B.    Determine the impact on vegetation by cattle using the same site.
    C.    Determine the nitrogen waste produced by cattle using the site.
    D.    Determine the fate of nitrogen once it is applied to the land - considering:
            1.    Plant uptake
            2.    Animal consumption
            3.    Volatilization/change of chemical form
            4.    Percolation through the soil including
    E.    Determine, scientifically, the impact of prairie dog burrows on the
        movement of water through the soil column; considering:
            1.    Does the presence of the burrows increase the rate of
                percolation of treated water to the ground water?
            2.    Does the treated water reach the ground water at all?

LEAS Suggestions for TNRCC Compliance:

    Consider management of the LLAS as a prairie ecosystem.

            1.    Seed with prairie vegetation that would thrive with 1.5“ of water
                each week.  This same vegetation would thrive under high
                nitrogen conditions.

            2.    Maintain an active and health prairie dog ecosystem - coexisting
                with cattle grazing on the LLAS.  Population control of the prairie
                dogs when necessary.  The treated water is applied in circles via
                the center pivot system.  As such, those prairie dogs located
                outside the circles should not be of concern to TNRCC since water
                will not enter prairie dog holes outside the circles.  If, and when,
                control prairie dogs is deemed necessary, it should be limited to
                where water is being applied, thus sparing the expense of control
                outside the circles.  Complete elimination of prairie dogs from
                LLAS is not necessary nor is it cost efficient.

            3.    Have the Texas Parks and Wildlife Department,
                U.S. Fish and Wildlife Service, and the U.S. Department
                of Agriculture cooperatively develop a management plan for the
                site - free of charge.  This plan could include cost-sharing
                opportunities for the City and would detail specifically what
                vegetation would thrive under the conditions at LLAS and would
                provide preferred forage for cattle. 
    Benefits of this plan:
            1.    This plan could serve as a model for similar communities
                around the United States and the City would be commended
                for promoting a healthy, balanced ecosystem.

            2.    Grazing would be allowed, indeed, it would be part of the plan.

            3.    Taxpayers would save money.  By controlling but not eliminating
                prairie dogs, the taxpayers would not have to continually
                pay for the yearly, and probably futile, prairie dog elimination
                efforts. 

            4.    Concerns regarding control of prairie dogs without impact on
                the burrowing owls would be lessened, if not eliminated.  The City
                would simply not have to worry about it. 

            5.    This plan would have the full support of the country’s
                environmental and scientific communities.


Reviewed by:
    Dr. David Haukos, Wildlife Biologist, U.S. Fish and Wildlife Service, Adjunct Professor,
        Department of Range, Wildlife and Fisheries Management, Texas Tech University

    Leanna Smith, M.S., Assistant Professor, Biology Department, South Plains College

    Dr. Lloyd Urban, Director, Water Resources Center, Texas Tech University.

    Dr. Mark Wallace, Associate Professor, Department of Range, Wildlife and Fisheries
        Management, Texas Tech University

    Dr. Phillip Zwank, Professor, Department of Range, Wildlife and Fisheries Management,
        Texas Tech University

References:
    Collens, D. et al. 1984. “An Economic Analysis of Black-Tailed Prairie Dog Control.”
        Journal of Range Management 37(4):358-361.
    Fuquay, John. February 1, 2002.  “City’s plan to kill prairie dogs rocks boat.” Lubbock
        Avalanche Journal.
    Fuquay, John. June 12, 2002. “Prairie dogs blamed for violation.” Lubbock Avalanche
        Journal.
    Jaggers, James E.  June 3, 2002.  Letter to The Honorable Marc McDougal, Mayor, City
        of Lubbock.  Re: Notice of Violation for the Comprehensive Compliance
        Investigation at: City of Lubbock Wastewater Treatment Facilities, Lubbock,
        (Lubbock County), Texas TNRCC ID No.: 10353-002.
   
    Klatt, M. and D. Hein. 1978. “Vegetative Differences Among Active and Abandoned
        Towns of Black-Tailed Prairie Dogs.” Journal of Range Management 31(4):315-
        317.
    Request for Proposal #086-02/BM. April 25, 2002. City of Lubbock, Texas
    Texas Black-tailed Prairie Dog Working Group. March 2001. Texas Black-tailed Prairie
        Dog Conservation and Management Plan - Draft.
    Uresk, T.A. 1985. “Effects of Controlling Black-Tailed Prairie Dogs on Plant
        Production.” Journal of Range Management 38(5):466.468.
    Van Pelt, W.E. 1999. The Black-tailed Prairie Dog Conservation Assessment and
        Strategy-Fifth Draft. Nongame and Endangered Wildlife Program. Arizona
        Game and Fish Department, Phoenix, Arizona.



Prairie Dog Biology

Fact Sheet

Scientific Name:   
Cynomys ludovicianus

Habitat:   
Found on plains and plateaus of North America from southern Saskatchewan to northern Mexico.

Diet:   
Herbivorous; eats mostly grasses and forbs.  Forbs, often called weeds, are dicotyledons and include individual plants from many families.  The general term forb, refers to any herbaceous, broadleaf plant without regard to family classification.

Profile:
The black-tailed prairie dog is not a dog, but a stout, burrowing ground squirrel named for its barking call.  These “dogs” live in the western U.S. in ten states:  Colorado, Kansas, Montana, Nebraska, New Mexico, North Dakota, Oklahoma, South Dakota, Texas, and Wyoming.  It is extirpated form Arizona.  Roughly half of the U.S. prairie dog population lives in South Dakota, Montana and Wyoming.  Black-tailed prairie dogs occupy less than 1 percent of the land they once occupied a century ago (Miller et al. 1994).

The prairie dogs excavate elaborate systems of burrows in flat prairie lands and create “towns” comprised of thousands of animals.  the burrows are easily identified because of the large mound of dirt surrounding the entrance, providing a vantage point to spot approaching predators as well as flood protection. 

Life and Reproduction:
Prairie dogs have a low rate of reproduction compared with other small mammals.  They become reproductively viable at two years of age, breed only once a year, and the average litter size is three to four pups.  Their lifespan is typically 4-5 years in the wild

Prairie Dogs as “Keystone Species”
The black-tailed prairie dog is a “keystone species” - which is defined as one whose presence and activities are critical to the entire ecosystem.  Black-tailed prairie dogs create an environment around their colonies - huge complexes of tunnels and mounds surrounded by short-clipped grass that provide homes and shelter for a myriad of creatures.  The black-tailed prairie dog is a critical food source for a number of animals - including several birds of prey.  Since black-tailed prairie dogs are the only prairie dog species, and one of only a few rodents that do not hibernate in the winter, they are vitally important winter food sources for prairie predators.

Biologists have concluded that nine prairie species are dependent on prairie dogs (Kotliar et al. 1999), an additional 20 species opportunistically take advantage of prairie dog colonies, and a total of 117 species have some relationship with prairie dog colonies (Reading et al. 1989).

Those species that are considered dependent on prairie dogs are:

        -Black-footed ferret
        -Mountain plover
        -Burrowing owl
        -Ferruginous hawk
        -Golden eagle
        -Horned lark
        -Deer mouse
        -Grasshopper mouse
        -Swift fox

The Western Association of Fish and Wildlife Agencies stated in their Black-Tailed Prairie Dog Memorandum of Understanding  (1999) that:  “All member affected agencies agree that black-tailed prairie dogs are an important natural component of the short to mid-grass ecosystem.  As such black-tailed prairie dogs serve as an indicator of the overall health of this important habitat type in western North America.  Further, the presence and abundance of black-tailed prairie dogs reflects humankind’s commitment to maintaining all natural components of the short to mid-grass ecosystem so that all uses of this type are sustainable over time.”

References:
Kotliar, Natasha B., Bruce W. Baker, April D. Whicker, Glenn Plumb. 1999. “A critical review
    of assumptions about the prairie dog as a keystone species.” Environmental Management
    24 (2): 177-192.
Miller, B., G Ceballos, and R.P. Reading. 1994. “The Prairie Dog and Biotic Diversity.”
    Conservation Biology 8:677-681.
Reading, R.P. et al. 1989. “Attributes of Black-Tailed Prairie Dog Colonies in Northcentral
    Montana, with Management Recommendations for the Conservation of Biodiversity.”         The Prairie Dog Ecosystem: Managing for Biological Diversity. Montana BLM Wildlife
    Technical Bulletin No. 2.
Western Association of Fish and Wildlife Agencies.  1999. Black-tailed Prairie Dog Memorandum
    of Understanding. 
Llano Estacado Audubon Society
P.O. Box 6066
Lubbock, TX  79493-6066

June 26, 2002


Mr. Dan Dennison
Director, Environmental Compliance
City of Lubbock
P.O. Box 2000
Lubbock, TX  79457

Dear Mr. Dennison,

The Llano Estacado Audubon Society (LEAS) has developed the attached Position Statement regarding the proposed control program for black-tailed prairie dogs on the Lubbock Land Application Site (LLAS).  This position statement has been developed utilizing the scientific resources available to us:  wildlife managment professionals familiar with prairie dog biology and management and documented scientific literature.

We hope that the City of Lubbock will consider incorporating all or portions of this position statement during the development of a plan to maintain compliance with  the TNRCC.  

The LEAS is available to provide comment or assistance throughout this compliance process and we appreciate the efforts the City of Lubbock and yourself have taken to include our organization in this project. 

Sincerely,



Jill Haukos
Conservation Chair
haukos(at)aol.com


cc:   Hon. Marc McDougal, Mayor
Lubbock City Council
TNRCC -- Regional and State Directors
Ruben Cantu, Reg. Director Texas Parks & Wildlife Department
Rick Gilliland, Wildlife Services, U.S. Department of Agriculture
Tom Cloud, Ecological Services, U.S. Fish & Wildlife Service