JASON LILLEGRAVEN
Perspective

I believe testable evidence, not political expediency, should guide management of public lands.

This column is intended to alert citizens that the U.S. Forest Service, in its Draft Environmental Impact Statement titled "Thunder Basin National Grassland Prairie Dog Management Strategy and Land and Resource Management Plan Amendment No. 3," appears to do the opposite.

The DEIS is disjointed in presentation, and much relevant, peer-reviewed literature is overlooked. Misleading statements, emphasizing recovery of prairie dog populations, are contradicted by data from the same report.

The native grasslands of northeastern Wyoming, and of the Great Plains generally, are severely damaged. Deterioration began late in the 19th century. The main damage came through domestic overgrazing and conversion of native grasslands to cropland or coal mines or complexes for hydrocarbon extraction.

Decimation of prairie dog populations figured importantly in grassland degradation. Massive subsidies for poisoning colonies, encouragement of "recreational" shooting of prairie dogs, and introduction of bacterial plagues heightened the loss. Original benefits from prairie dogs included soil aeration, trapping precipitation deeper and more efficiently, acceleration of chemical recycling, adding habitat through burrowing, contributing their own bodies as food for predators, reduction of woody vegetation, and nutritional enhancement of forage for other grazers.

Black-tailed prairie dog populations across America’s Great Plains have been reduced by at least 98 percent. They no longer serve their ecologically beneficial original roles, evolved over millions of years, as keystone and foundation species. They are now "functionally extinct" within the grassland ecosystem. Furthermore, they are officially designated as "Sensitive Species" and "Management Indicator Species" and were "warranted for listing" in 2007 under the Endangered Species Act.

It is within that context that the U.S. Fish and Wildlife Service was charged with re-introduction of North America’s most endangered mammal, the black-footed ferret. Thunder Basin National Grassland is one of only seven sites designated as possible for ferret re-introduction.

Despite that grim situation, the U.S. Forest Service is promoting taxpayer-financed resumption of poisoning (from the existing policy of highly restricted poisoning) and encouragement of shooting in most colonies of prairie dogs on public lands of TBNG. Their decision derived from a 2004 letter to the USFS from U.S. Department of Agriculture Undersecretary David Tenny: "Specifically, I am instructing the (Forest Service) to work with local interests and landowners to use the full suite of management tools available to them to reduce the potential for prairie dog colonies to expand onto adjacent non-federal lands." This exemplifies the "good neighbor policy," applied to blocking dispersal of prairie dogs onto non-federal lands using lethal controls.

Resumption of poisoning is introduced in the DEIS as follows: "The Forest Service has identified a need to manage prairie dog complexes and colonies on the TBNG to provide habitat for black-footed ferrets and other species associated with prairie dog habitat and to be a good neighbor by preventing unwanted colonization of prairie dogs onto adjacent private lands."

Why are black-tailed prairie dogs, an ecological keystone species native to American grasslands, so "unwanted" adjacent to TBNG? The DEIS does list potential problems, including: public health threats; damage to infrastructure; effects on vegetative condition; unattractiveness of colonies; increased erosion; and competition with livestock for forage. Not one of those potential problems is supported by consequential evidence. Associated text either invalidates each issue or ignores contradictory information. Therefore I ask why the USFS recommends a poorly justified "preferred alternative," filled with environmental risk (through distributing poisons and contaminating the food-chain with lead) and huge public expense, as based upon folklore rather than scientific evidence?

The best way for the USFS to be a "good neighbor" with surrounding communities would be to restore healthy grasslands. But that cannot be done without substantial populations of prairie dogs, the most important "ecological engineers" of American grasslands.

The core of this DEIS was based on an unpublished report akin to a college-level term paper. The report acknowledges financing by a local (Thunder Basin) landowners’ organization. The USFS then used this report, nearly verbatim (including duplication of typographical errors), as the heart of its prairie dog "Management Categories." This is ethically questionable and at best creates an appearance of gross conflict of interest.

U.S. citizens expect their governmental documents to exhibit integrity, analytical competence, and professionalism. So who in this case is watching the store? We citizens are! Fortunately, opportunities still exist for oversight of many documents by a conscientious public.

I consider the preferred action (Alternative 2) scientifically and economically indefensible and biologically irresponsible. Alternative 3 in all probability is illegal. Only Alternative 1, the "No Action" alternative, is scientifically realistic. I urge you to personally study the DEIS and provide comments to the USFS by March 24.

Jason Lillegraven is an Emeritus Professor from the University of Wyoming. E-mail him at bagpipe@uwyo.edu.