Prairie Dog Action Letter

July 19, 2002

City of Lubbock Planning to Control Prairie Dogs

The City of Lubbock is planning a large-scale poisoning of prairie dogs on city land and the Llano Estacado Audubon Society (LEAS) has come forward in opposition of this plan.   What LEAS opposes is the complete lack of science behind the decision to kill the prairie dogs.  If you are unfamiliar with the history of this issue, read the “Background” section. 

The City of Lubbock and the Texas Natural Resources Conservation Commission has, so far, ignored the concerns of LEAS and the wildlife management community (U.S. Fish and Wildlife Service (USFWS) and Texas Parks and Wildlife (TPWD)).  We have proposed the creation of a collaborative management plan that would recognize the importance of the prairie dog in a grassland ecosystem.  This plan would include cost-sharing incentives (TPWD and USFWS shouldering some of the costs, thus saving the City money) and could serve as a model for similar situations across the county (putting a positive national spotlight on the City).  So far, we had nothing but stony silence from the City.  

We need your help! The City will continue to ignore us unless they hear from the citizens of Lubbock.  If you are concerned with this issue, please consider printing, signing and sending the form letter below.  The only way we can make a difference is by showing the City that we care!


Please help by sending this letter to (either a hard copy or an e-mail):



Honorable Marc McDougal, Mayor
City of Lubbock
1625 13th St.
P.O. Box 2000
Lubbock, TX 79457
e-mail:  MMcdougal@mail.ci.lubbock.tx.us 

Same Mailing Address for Councilmen and the Mayor:
Councilman Tom Martin
e-mail:  TMartin@mail.ci.lubbock.tx.us 

Councilman Victor Hernandez
e-mail:  VHernandez@mail.ci.lubbock.tx.us 

Councilman TJ Patterson
e-mail:  TPatterson@mail.ci.lubbock.tx.us 

Councilman Frank Morrison
e-mail:  FMorrision@mail.ci.lubbock.tx.us 

Councilman Alex “Ty” Cooke
e-mail:  TCooke@mail.ci.lubbock.tx.us 

Councilman Gary Boren
e-mail:  GBoren@mail.ci.lubbock.tx.us 






Honorable Marc MacDougal, Mayor
City of Lubbock
1625 13th St.
P.O. Box 2000
Lubbock, TX 79457

Dear Mr. Mayor,

I am writing you today, as a citizen of Lubbock, to oppose the complete lack of science behind the decision to kill prairie dogs on the Lubbock Land Application Site (LLAS). 

The Texas Natural Resources Conservation Commission (TNRCC) did not use scientific means to allege that prairie dogs are increasing groundwater pollution by either their burrowing action or through loss of vegetation.  

The City of Lubbock stands only to lose if it continues to ignore the voices of the biologists and  citizens.  Lubbock leadership will be viewed regionally and nationally as backward and regressive -- especially in light of the offers by the Texas Parks and Wildlife Department and the U.S. Fish and Wildlife Service to provide a prairie dog management plan that would include cost-sharing incentives.  Why turn a blind eye to a balanced, scientific approach that could save the City money and put Lubbock in a favorable national spotlight?

As a citizen, I demand that the City work with state and federal wildlife management agencies to collaborate on a scientific and sound prairie dog management plan.   The prairie dogs are an essential part of a healthy prairie ecosystem and I insist that the City of Lubbock consider that aspect when making management decisions.

Sincerely,



Your Name



[End of Letter]




Background:

In response to a Notice of Violation from the Texas Natural Resources Conservation Commission (TNRCC), the City of Lubbock is making plans to control prairie dogs living on the Lubbock City Farm land located east of town between 4th Street and 50th Street.  The City Farm encompasses approximately 6,000 acres, of which 2,500 acres is targeted for prairie dog
control. 

The City Farm is used by the City of Lubbock as a site for wastewater effluent application.  The effluent is applied by pivot irrigation sprinklers over the ground; vegetation root systems absorb the water effectively filtering and using much of the nitrogen (a large component of wastewater) and other nutrients.  The soil provides another filtering mechanism, absorbing nutrients directly to the soil particles before it reaches the groundwater.  Both the City and the TNRCC are concerned about the amount of nitrogen that reaches the groundwater.

The TNRCC claims that the presence of the prairie dogs (eating vegetation) and prairie dog burrows (which extend below plant root systems) is evidence that partially treated wastewater effluent is more directly reaching groundwater.    It is the contention of the Llano Estacado Audubon Society, the U.S. Fish and Wildlife Service, and the Texas Parks and Wildlife Department that the TNRCC may be wrong.  There is no scientific evidence that the presence of prairie dogs increases the rate of travel of effluent to the groundwater.   Further, there is no evidence that the prairie dogs are decimating the vegetation at the site.   The City has claimed to have evidence of this fact but have yet to provide this evidence.  LEAS submitted a Freedom of Information request for the City’s data on nitrogen fate at the City Farm, and we have yet to receive anything from that request. 

Prairie Dog Biology

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).

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.

Updated 19 July 2006 .