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HomeMy WebLinkAboutCOUNCIL - AGENDA ITEM - 02/07/2017 - FIRST READING OF ORDINANCE NO. 021, 2017, AMENDINGAgenda Item 8 Item # 8 Page 1 AGENDA ITEM SUMMARY February 7, 2017 City Council STAFF Rebecca Everette, Senior Environmental Planner Cameron Gloss, Planning Manager John Stokes, Natural Resources Director SUBJECT First Reading of Ordinance No. 021, 2017, Amending Land Use Code Section 3.4.1, Natural Habitats and Features. EXECUTIVE SUMMARY The purpose of this item is to consider potential changes to various Land Use Code requirements related to the protection and mitigation of impacts to prairie dog colonies, sensitive and specially valued species, and other natural habitats and features on development sites. STAFF RECOMMENDATION Staff recommends adoption of the Ordinance on First Reading. BACKGROUND / DISCUSSION Since the original Land Use Code (LUC) provisions regarding prairie dog colonies were adopted in 1997, there has been considerable change in the size and characteristics of prairie dog colonies within the Growth Management Area, best practices for fumigation and relocation, and citywide development patterns. Based on the latest research on the ecosystem value of prairie dog colonies and current best management practices, staff proposes a number of LUC updates regarding prairie dog management and the protection of natural habitats and features on development sites. CURRENT LAND USE CODE REQUIREMENTS Development activities that have the potential to impact natural habitats and features are regulated by Section 3.4.1 of the LUC. In some cases, prairie dog colonies are considered a special habitat feature that warrants protection or mitigation, but provisions for prairie dog management vary depending on the site:  For colonies over 50 acres in size, the developer must either protect and buffer the colony or, if the colony will be removed, replace the resource value lost to the community through some form of mitigation. Mitigation requirements are determined on a case-by-case basis, and may include the creation of grassland habitat, relocation of prairie dogs, donation of euthanized prairies dogs to support black-footed ferret or raptor recovery programs, or payment-in-lieu to fund grassland restoration or prairie dog management elsewhere in the community.  For colonies less than 50 acres in size, no protection or mitigation of impacts to prairie dogs is required. If prairie dogs will be left on-site, and depending on the nature of the project, fencing, underground barriers, or other mechanisms may be required to reduce conflicts between wildlife and the development project.  Before the commencement of grading or other construction on the development site, any prairie dogs inhabiting the site must be relocated or eradicated by the developer using City-approved methods.  If prairie dogs will be removed from the site, they must be humanely relocated or eradicated using City- Agenda Item 8 Item # 8 Page 2 approved methods and, in some cases, methods approved by Colorado Parks and Wildlife and/or the Humane Society. Fumigation may be used to eradicate prairie dogs, but only by an exterminator or fumigator that is properly licensed by the State of Colorado. Trapping of prairie dogs is permitted, provided that any animals trapped are released or disposed of in the manner required by the Humane Society and the Colorado Parks and Wildlife. PROPOSED LAND USE CODE CHANGES Prairie Dog Management Since the original LUC provisions regarding prairie dog colonies were adopted, there has been a considerable reduction in the size and change in characteristics of prairie dog colonies within the Growth Management Area and citywide development patterns. The proposed LUC changes include: 1. Size threshold - Reduce the size threshold for protection and/or mitigation of prairie dog colonies from 50 acres to 1 acre to better align with the current scale and distribution of prairie dog colonies within the Growth Management Area. Prairie dog colonies greater than 1 acre in size would be considered special features during the development review process and therefore treated similarly to other significant resources. The 1-acre threshold would include the majority of remaining prairie dog colonies on private land throughout the City, but would allow for flexibility for smaller areas of prairie dog encroachment on a site. See Attachment 1 (Colony Size Threshold Options) for additional analysis. Attachment 2 illustrates the differences between the current and proposed development review process for sites containing prairie dogs. 2. Mitigation - Continue to determine mitigation requirements (on-site improvements, off-site improvements, relocation, trap and donate, or payment-in-lieu) on a case-by-case basis for development projects, but for prairie dog colonies greater than 1 acre in size. The significance and ecological value of a prairie dog colony would be determined by staff and/or the Director during the development review process. Staff would rely on the general standard in 3.4.1(C) to determine mitigation requirements, and requirements would be applied consistently to applicable development projects. 3. Reporting - Require a report that documents the timing and methods used for prairie dog relocation or eradication for all prairie dog removal activities on development sites. 4. Fumigation (Lethal Control) of Prairie Dogs: Local regulation of the use of fumigants and other pesticides on private property is specifically preempted by state law. As such, no changes to the allowable methods for fumigation are proposed at this time. However, staff will encourage applicants to use carbon monoxide-based methods for lethal management on development sites because it is considered more humane than other fumigants (e.g., aluminum phosphide). This is consistent with the management practices utilized by the Natural Areas Department, and carbon monoxide fumigation services are offered by multiple Northern Colorado exterminators. Sensitive and Specially Valued Species Sections 3.4.1(F)(1) and 3.4.1(N)(4) of the Land Use Code speak to Sensitive and Specially Valued Species. These sections currently reference an outdated list of “Species of Concern” in LUC section 5.1.2 (Definitions). The definition for “sensitive and specially valued species” references a document published by the State of Colorado in 1996, which has subsequently been updated numerous times and includes a number of species without any legal protection by the state or federal government. This document is updated by Colorado Parks and Wildlife staff administratively, rather than by the State legislature, and relates to the state as a whole and in some cases is not directly relevant to the habitats found in and around Fort Collins. The Fort Collins Natural Areas Department maintains a more relevant list of species that warrant local consideration or protection (Attachment 3). Additionally, LUC 3.4.1(F)(1) mandates protection not only for species with state and federal legal protections (threatened or endangered species), but also for those identified as “species of concern” or “sensitive natural Agenda Item 8 Item # 8 Page 3 communit[ies].” As a result, there is little to no flexibility for a developer if such a species is identified on their property, even if there are no other local, state or federal legal protections for that species. A more current list of Sensitive and Specially Valued Species may include species such as black-tailed prairie dogs, which are considered valuable native species but for which protection may not always make sense in an urban context; in some cases mitigation may be a more appropriate option. Staff proposes the following updates related to Sensitive and Specially Valued Species: 1. Definition of Threatened or Endangered Species - Add a new definition that specifically addresses plant and wildlife species considered to be threatened or endangered by the state or federal government. Species that are included in this definition are subject to additional state and federal protections. 2. Definition of Sensitive and Specially Valued Species - Update the definition for "Sensitive and Specially Valued Species" to reflect the current City of Fort Collins Species of Interest list, which is maintained and updated by the Fort Collins Natural Areas Department. See Attachment 3 - Species of Interest list. 3. Protection of Threatened or Endangered Species - Create a separate standard in 3.4.1(F) that specifically addresses threatened or endangered species, which generally warrant additional protection than sensitive or specially valued species. Habitat for such species shall not be disturbed or diminished. 4. Protection of Sensitive and Specially Valued Species - Update the standard in 3.4.1(F) that describes protections for sensitive and specially valued species. The development plan shall protect, enhance or mitigate impacts to sensitive and specially valued species to the extent reasonably feasible. This would allow for some flexibility and/or mitigation of impacts to species of interest, including prairie dogs, rather than mandating protection in all cases. This is consistent with the Natural Areas Department's wildlife management practices on City-owned properties. Miscellaneous Code Changes A number of other minor updates to Code language throughout LUC section 3.4.1 are proposed to clarify wording, accurately refer to City departments and outside agencies, and reflect current practices. 1. Natural Habitats and Features - Natural resources, habitats and features that warrant protection under LUC section 3.4.1 have been clarified in 3.4.1(A) - Applicability. 2. Colorado Parks and Wildlife - All references to the Colorado Division of Wildlife have been updated to reflect the current name of the agency, Colorado Parks and Wildlife. 3. Natural Areas Policy Plan - The Natural Areas Policy Plan (NAPP) is no longer a relevant guidance document for the City of Fort Collins. References to this document have been updated to more generally reference the City of Fort Collins Natural Areas Department (NAD). 4. Wetlands - There is language in LUC section 3.4.1(E)(1)(d) regarding the protection of wetlands that conflicts with other sections of 3.4.1. This language has been updated to clarify that wetlands of any size warrant consideration as a natural habitat or feature. 5. Definitions - various definitions in LUC section 5.1.2 have been updated for consistency with the other proposed updates described in this staff report. CITY FINANCIAL IMPACTS If the proposed changes are adopted, additional staff time may be required to review ecological reports, determine appropriate mitigation requirements, and work with developers to meet the new standards. Additional staff time may also be needed to research, set, and periodically update the fee for payment-in-lieu mitigation. This is already within the typical duties for the City’s environmental planners, so no additional staffing would be needed. Agenda Item 8 Item # 8 Page 4 BOARD / COMMISSION RECOMMENDATION The Planning and Zoning Board and the Land Conservation and Stewardship Board have reviewed the proposed LUC changes:  The Planning and Zoning Board considered the proposed LUC changes at its January 12, 2017, hearing. The board unanimously recommended adoption of the Code changes related to sensitive and specially valued species, as well as the miscellaneous Code changes (Attachment 4). However, in a split vote (2-4), the Board did not recommend adoption of the prairie dog code changes. The perspective from some board members was that the Code changes did not create sufficient protection for prairie dogs, others expressed a concern that the changes would result in additional costs and processing for developers, and two board members were supportive of the changes. (Opposed: Carpenter, Schneider, Hansen, Rollins; Supportive: Hobbs, Whitley; Absent: Heinz).  The Land Conservation and Stewardship Board discussed the proposed changes at its July 13, 2016, meeting. The board was generally supportive of the changes, including the reduced colony size threshold and reporting requirement. The Board did not take a vote, but Board members generally expressed support for removing the 50-acre threshold for protection and/or mitigation (Attachment 5). PUBLIC OUTREACH Staff in Community Development & Neighborhood Services and the Natural Areas Department conducted outreach to community members and affected stakeholders throughout 2016 and early 2017, including the following:  Professional workshop with representatives from other Colorado communities to discuss best practices and lessons learned related to prairie dog regulation and management (March 22, 2016)  Open house and meetings with prairie dog advocates regarding the relocation of prairie dogs from a development site to the Cathy Fromme Prairie Natural Area (April 19, 2016)  Discussion of proposed changes at three Planning & Zoning Board work sessions (May and December 2016, January 2017)  Discussion of proposed changes with the Land Conservation and Stewardship Board (July 13, 2016)  Open house and panel discussion related to potential Land Use Code changes, relocation considerations, and prairie dog management on Natural Areas properties (July 28, 2016)  Memo to City Council in lieu of a work session (September 2016)  One-on-one conversations with developers, property owners, and prairie dog relocation advocates (ongoing) The results of the community engagement activities are summarized in Attachments 6 and 7. ATTACHMENTS 1. Colony Size Threshold Options and Map (PDF) 2. Prairie Dog Management Flow Charts (PDF) 3. City of Fort Collins Species of Interest (PDF) 4. Planning and Zoning Board Minutes, January 12, 2017 (PDF) 5. Land Conservation Stewardship Board Minutes, July 13, 2016 (PDF) 6. Public Comment Received To-Date (PDF) 7. Public Engagement Results Summary (PDF) 8. Memo to City Council, September 14, 2016 (PDF) Prairie Dog Code Changes – Size Threshold Options 1 Background Staff is currently evaluating options for updating Land Use Code requirements regarding the protection and management of prairie dog colonies on development sites. Under current standards, for colonies over 50 acres in size the developer must either protect and buffer the colony or, if the colony will be removed, replace the resource value lost to the community through some form of mitigation. However, to staff’s knowledge there are no longer any colonies on private property that are 50 acres or larger in size, so this requirement is unlikely to be triggered. Staff recommends setting a lower threshold for considering impacts to prairie dog colonies to ensure that the ecological value provided by these colonies is accounted for in the development review process. Land Use Code Change Options Option 1: Reduce Threshold to a Specific Acreage – STAFF RECOMMENDATION There is no specific acreage that can be directly correlated to the viability or significance of a prairie dog colony. Depending on the characteristics of a site, a colony can adapt to both small and large sites, so it is difficult to identify a threshold at which a colony can be considered “healthy” or “sustainable.” However, we can observe the conditions that currently exist throughout Fort Collins. Staff in the Natural Areas Department recently conducted a coarse analysis to estimate the location and size of prairie dog colonies on private land within the Growth Management Area. The analysis included a review of aerial photography, rather than field investigation, so it provides a rough but generally representative estimate of the extent of prairie dog colonies across the city. Analysis of Prairie Dog Colonies on Private Lands (2016)* Estimated Number of Colonies 72 Total Acreage 356 ac Average Acreage 4.95 ac Median Acreage 2.24 ac Minimum Acreage 0.15 ac Maximum acreage 39.43 ac *All values are estimated based on analysis of aerial photography. Based on this analysis, more than half of the remaining colonies on private lands are greater than 2 acres in size, and at least 75 percent are greater than 0.88 acres. While the size of a colony can fluctuate greatly over time, this distribution accurately reflects observations staff has made in the field. While the ecological benefits offered by prairie dogs are greater in an undisturbed grassland ecosystem than in an urban context, there is value in retaining prairie dog colonies within the city, particularly to support predators (e.g,. eagles and hawks) and species that are dependent on prairie dogs (e.g., burrowing owls). The majority of the existing prairie dog colonies in the city offer these ecological benefits to some extent. ATTACHMENT 1 1 Prairie Dog Code Changes – Size Threshold Options 2 Staff recommends adjusting the size threshold for considering protection and/or mitigation for prairie dog colonies to better match the size of colonies typically seen in Fort Collins. Staff believes this option will fulfill the purpose of Land Use Code Section 3.4.1, Natural Habitats and Features, regarding the protection of natural habitats and features while also accounting for the needs of proposed development. A size threshold of 1 acre or greater would account for the majority of prairie dog colonies throughout the city without placing an unreasonable burden on development projects. The draft Land Use Code provisions for Planning and Zoning Board consideration incorporate this option. Option 2: Reduce Threshold to a Specific Number of Animals Another option for determining whether a prairie dog colony warrants protection and/or mitigation is setting a threshold at a defined number of individual prairie dogs. The Natural Areas Department recently updated their Wildlife Management Guidelines, which specify that the City will only consider the relocation of prairie dogs to Natural Area properties for groups of 60 prairie dogs or greater. This number was determined based on the success of past prairie dog relocation efforts and requirements in other Front Range municipalities, including Boulder, CO. This same number of prairie dogs (60 individuals) could be used to determine whether the requirements in Land Use Code Section 3.4.1 should be triggered, which would be consistent with the Wildlife Management Guidelines, though it would also present some practical challenges. First, prairie dog colony densities are inconsistent and wide-ranging from one site to another, with densities in communities along the Front Range observed to be as low as 4 animals per acre to as high as 30 animals 0 5 10 15 20 25 30 35 40 45 Acres Prairie Dog Colonies on Private Lands (Rough Estimate) Colonies (72 total) 1st Quartile (0.88 ac) Median (2.24 ac) 3rd quartile (6.25 ac) Prairie Dog Code Changes – Size Threshold Options 3 per acre. As such, two development sites of the same size could theoretically be subject to different environmental protection requirements depending on the density of a colony on the property. Second, counting individual animals would require more intensive field survey techniques, which could increase the cost of ecological studies for development applicants. If this option is determined to be the most appropriate, the City would need to develop and provide a standard methodology for ecological consultants to survey for prairie dogs, and more ongoing staff time would be required to verify the surveys conducted by outside consultants. This option is not recommended by staff. Option 3: Remove Threshold Entirely This option would remove any size thresholds for considering impacts to prairie dog colonies, and would instead require staff and decision-makers to consider the ecological value of sites containing prairie dogs (of any size) on a case-by-case basis. A suite of site characteristics and criteria could be used to evaluate the significance of prairie dog colonies on specific sites. Considerations would likely include: x Vegetation type, quality and diversity (e.g., native vs. non-native plant species) x Vegetation coverage and bare spots (indicating overgrazing and erosion issues) x Soil type and depth x Slope and topography x Presence of other species associated with prairie dogs (e.g., predators, burrowing owls, dependent species) Each of these characteristics could be evaluated qualitatively for a development site containing prairie dogs. However, staff has not found a set of standard criteria or metrics for determining whether a colony is “significant,” “healthy,” or “viable.” Establishing a set of consistent, quantitative criteria that can be applied to all development projects (e.g., minimum vegetation coverage of XX%) would require additional research effort beyond staff’s current capacity and expertise. The support of an academic researcher, consultant, or outside organization would be needed to complete a full literature review and any additional research to develop specific metrics. As such, this option is not recommended by staff. Option 4: Keep 50-acre Threshold (Status Quo) If the current code requirement is kept as is, it is unlikely that protection and/or mitigation for impacts to prairie dog colonies will be required on any development sites in the city, as staff has not observed any colonies greater than 50 acres in size on private property. Staff contends that the 50-acre threshold no longer meets the intent of Land Use Code Section 3.4.1, Natural Habitats and Features, regarding the protection of natural habitats and features on development sites. Therefore, this option is not recommended by staff. Prairie Dog Colonies (not including Fort Collins Natural Areas) Printed: December 28, 2016 Legend Approximate Locations of Prairie Dog Colonies (data collected 2016) 00.511.52 Miles © Path: S:\CDNS\Planning\Current Planning\Environmental PlannerNatural Resources\2_Environmental Planning Guides\2 - Maps\EP_BaseMapMaster.mxd NAD_1983_StatePlane_Colorado_North_FIPS_0501_Feet Is a development project proposed? No City review required for removal Protect colony in place (buffer from conflicting uses) Relocate Private Property (work with property owner) City Natural Areas (work with Natural Areas Fumigate Dept)* (using City-approved methods) Is the prairie dog colony >50 acres? Prairie dogs must be removed prior to construction Relocate Private Property (work with property owner) City Natural Areas (work with Natural Areas Dept)* Fumigate (using City-approved methods) Natural resource protection standards apply Protect colony in place (with an appropriate buffer) If removed, replace the habitat value lost through mitigation On-site habitat enhancements (for other species) Off-site habitat enhancements (for prairie dogs or other species) Payment-in-lieu (for prairie dog mgmt or grassland restoration) Live trap & donate prairie dogs NO YES Prairie Dog Management in Fort Collins – Development Review Process & Options NO YES Management Options Management Options CURRENT LAND USE CODE STANDARDS Mitigation Options Relocation Options Is a development project proposed? No City review required for removal Protect colony in place (buffer from conflicting uses) Relocate Private Property (work with property owner) City Natural Areas (work with Natural Areas Fumigate Dept)* (using City-approved methods) Is the prairie dog colony >1 acre? Prairie dogs must be removed prior to construction Relocate Private Property (work with property owner) City Natural Areas (work with Natural Areas Dept)* Fumigate (using City-approved methods) Natural resource protection standards apply Protect colony in place (with an appropriate buffer) If removed, replace the habitat value lost through mitigation On-site habitat enhancements (for other species) Off-site habitat enhancements (for prairie dogs or other species) Payment-in-lieu (for prairie dog mgmt or grassland restoration) Live trap & donate prairie dogs NO YES Prairie Dog Management in Fort Collins – Development Review Process & Options NO YES Management Options Management Options PROPOSED LAND USE CODE CHANGES Mitigation Options Relocation Options City of Fort Collins Natural Areas Department, 2016 1 City of Fort Collins Plant Species & Plant Communities of Interest List of plant taxa documented in the Fort Collins Natural Areas. Synonymy follows USDA, NRCS. 2015. The PLANTS Database (http://plants.usda.gov, 21 December 2015). National Plant Data Team, North Carolina . * Includes augmentation, reintroduction, and ex-situ conservation. Scientific Name Common Name Global Rank State Rank Tracked by CNHP? ESA Status FC Natural Areas Status Priorities for Restoration* Fern and Fern Allies Argyrochosma fendleri Fendler's false cloak fern G3 S3S4 Y Documented Azolla mexicana Mexican mosquitofern G5 S4 N Documented Zone 1 Marsilea vestita Hairy waterclover G5 S4 N Documented Aquatics (Submerged or Floating) Callitriche heterophylla Two-headed water-starwort G5 S1 Y Documented Hippuris vulgaris Common mare's tail G5 SNR N Documented Lemna minuta Least duckweed G4 SNR N Documented Ruppia cirrhosa Spiral ditchgrass G5 SNR N Documented Zone 1, 2 Sparganium eurycarpum Broadfruit bur- reed G5 S2 Y Documented Zone 1, 2, 5 Wolffia columbiana Columbian watermeal G5 S4 N Documented Zone 1, 2 Shrubs and Trees Ribes americanum American black currant City of Fort Collins Natural Areas Department, 2016 2 Scientific Name Common Name Global Rank State Rank Tracked by CNHP? ESA Status FC Natural Areas Status Priorities for Restoration* Carex sprengelii Sprengel's sedge G5 S2 Y Documented Cyperus bipartitus Slender flatsedge G5 SNR N Documented Zone 1 Cyperus lupulinus Great plains flatsedge G5 SNR N Documented Cyperus squarrosus Bearded flatsedge G5 SNR N Documented Zone 1 Dichanthelium acuminatum var. sericeum Tapered rosette grass G5TNR S1 Y Documented Zone 1 Eleocharis atropurpurea Purple spikerush G4G5 SNR N Documented Zone 5 Lipocarpha aristulata Smallflower halfchaff sedge G5? SNR N Documented Sporobolus heterolepis Prairie dropseed G5 SNR N Documented Wildflowers and Forbs Agalinis tenuifolia Slender false foxglove G5 SNR N Documented Zone 1 Agrimonia striata Roadside agrimony City of Fort Collins Natural Areas Department, 2016 3 Scientific Name Common Name Global Rank State Rank Tracked by CNHP? ESA Status FC Natural Areas Status Priorities for Restoration* Penstemon eriantherus Crested-tongue beardtongue G4 S1 Y Documented Phacelia denticulata Rocky mountain phacelia G3 SU Y Documented Physaria bellii Front Range twinpod G2G3 S2S3 Y Documented Zone 3 Sisyrinchium pallidum Pale blue-eyed grass G3 S2 Y Documented Sium suave Hemlock waterparsnip G5 SNR N Documented Oligoneuron album Prarie goldenrod G5 S1 Y Documented Spiranthes diluvialis Ute lady’s tresses G2G3 S2 Y LT Documented Zone 1, 2, 3, 4, 5 Stephanomeria runcinata Desert wire lettuce G5 SNR N Documented Triodanis leptocarpa Slimpod venus' looking-glass G5? S1 Y Documented Zone 3 City of Fort Collins Natural Areas Department, 2016 4 Scientific Name Common Name Authority Global Rank State Rank Tracked by CNHP? ESA Status FC Natural Areas Status Gymnocarpium dryopteris Western oakfern (L.) Newman, G5 S2S3 N Potential Pellaea atropurpurea Purple cliffbrake (L.) Link G5 S2S3 N Potential Pellaea glabella ssp. occidentalis Western dwarf cliffbrake (E.Nels.) Windham G5T4 SNR N Potential Pellaea glabella ssp. simplex Simple cliffbrake (Butters) A. & D. Love G5T4? S2 Y Potential Polypodium saximontanum Rocky mountain polypody Windham G3? S3S4 Y Potential Selaginella weatherbiana Weatherby's spikemoss R. Tryon G3G4 S3S4 W Potential Aquatics (Submerged or Floating) Elatine triandra Threestamen waterwort Schkuhr G5 S2 Y Potential Heteranthera limosa Blue mudplantain (Sw.) Willd., G5 SNR N Potential Myriophyllum verticillatum City of Fort Collins Natural Areas Department, 2016 5 Scientific Name Common Name Authority Global Rank State Rank Tracked by CNHP? ESA Status FC Natural Areas Status saximontana mountain sedge Carex torreyi Torrey's sedge Tuck. G4 S1 Y Potential Cyperus acuminatus Tapertip flatsedge Torr. & Hook. ex Torr. G5 SNR N Potential Juncus brachycephalus Smallhead rush (Engelm.) Buchenau G5 S1 Y Potential Juncus brevicaudatus Narrowpanicle rush (Engelm.) Fernald G5 S1 Y Potential Juncus tweedyi Tweedy's rush Rydb. G3Q S1 Y Potential Juncus vaseyi Vasey’s rush Engelm. G5? S1 Y Potential Schizachne purpurascens False melic (Torr.) Swallen, G5 SNR N Potential Schoenoplectus saximontanus Rocky mountain bulrush (Fernald) Raynal G5 S1 Y Potential Wildflowers and Forbs Agastache foeniculum Blue giant hyssop (Pursh) Kuntze G4G5 S1 Y Potential Aletes humilis Colorado aletes Coult & Rose G2G3 S2S3 Y Potential Anagallis minima Chaffweed (L.) Krause G5 S1 Y Potential Anemone virginiana var. alba Virginia anemone L., (Oakes) Alph. Wood G5 SNR N Potential Apios americana Groundnut Medik. G5 S1 Y Potential City of Fort Collins Natural Areas Department, 2016 6 Scientific Name Common Name Authority Global Rank State Rank Tracked by CNHP? ESA Status FC Natural Areas Status Claytonia rubra Redstem springbeauty (Howell) Tidestr. G5 S1 Y Potential Crassula aquatica Water pygmyweed (L.) Schoenl. G5 SH Y Potential Cryptantha cana Mountain cat's eye (A. Nelson) Payson G5 S2 Y Potential Cypripedium parviflorum var. pubescens Yellow lady’s slipper Salisb., (Willd.) Knight G5 S2 Y Potential Desmodium obtusum Stiff-tick trefoil (Muhl. Ex Willd.) DC G4G5 S4 N Potential Erigeron nematophyllus Needleleaf fleabane Rydb. G3 S2 Y Potential Eriogonum exilifolium Dropleaf buckwheat Reveal G3 S2 Y Potential Gentiana andrewsii Closed bottle gentian Griseb. G5? SNR N Potential Geranium bicknellii Bicknell’s cranesbill Britton G5 S2 Y Potential Helianthemum bicknellii Hoary frostweed City of Fort Collins Natural Areas Department, 2016 7 Scientific Name Common Name Authority Global Rank State Rank Tracked by CNHP? ESA Status FC Natural Areas Status primrose Oonopsis wardii Ward's false goldenweed (A. Gray) Greene G3 S1 Y Potential Packera debilis Weak groundsel (Nutt.) Weber & A. Love G4 S1 Y Potential Parthenium alpinum Alpine fever- few (Nutt.) Torr. & A. Gray G3 S3 Y Potential Pediomelum cuspidatum Largebract indian breadroot (Pursh) Rydb G4 S1 Y Potential Penstemon gracilis Slender beardtongue Nutt. G5 SNR N Potential Penstemon laricifolius ssp. exilifolius Larch-leaf beardtongue Hook. & Arn., (A. Nelson) D.D. Keck G4T3Q S2 Y Potential Penstemon radicosus Mat-root beardtongue A. Nelson G5 S1 Y Potential Potentilla ambigens Southern rocky mountain cinquefoil Greene G3 S2 Y Potential City of Fort Collins Natural Areas Department, 2016 8 Scientific Name Common Name Global Rank State Rank Tracked by CNHP? ESA Status FC Natural Areas Status Atriplex canescens / Bouteloua gracilis Shrubland Shortgrass Prairie G3 S2 Y Documented Bouteloua gracilis - Buchloe dactyloides Herbaceous Vegetation Shortgrass Prairie G4 S2? P Documented Carex nebrascensis Herbaceous Vegetation Wet Meadows G4 S3 P Documented Carex simulata Herbaceous Vegetation Wet Meadow G4 S3 P Documented Carex utriculata Herbaceous Vegetation Beaked Sedge Montane Wet Meadows G5 S4 P Documented Catabrosa aquatica - Mimulus ssp. Spring Wetland Spring Wetland GU S2 Y Documented Cercocarpus montanus - Rhus trilobata / Andropogon gerardii Shrubland Mountain Mahogany - Skunkbush / Big Bluestem Shrubland G2G3 S2 Y Documented Cercocarpus montanus / Achnatherum scribneri Shrubland Foothills Shrubland G3 S2 Y Documented Cercocarpus montanus / Elymus lanceolatus ssp. lanceolatus Shrubland Mountain Mahogany/Griffith's Wheatgrass Shrubland GU S2 Y Documented Cercocarpus montanus / Hesperostipa comata Shrubland Mixed Foothill Shrublands G2 S2 Y Documented Cercocarpus montanus / Hesperostipa neomexicana Shrubland Foothills Shrubland G2G3 S2 Y Documented City of Fort Collins Natural Areas Department, 2016 9 City of Fort Collins Wildlife Species of Interest *Documented or potentially occurring on natural areas, *ESA- Endangered Species Act or federal listing status, *State- state listing status Common Name Scientific Name Globa l Rank State Rank Document ed or Potential* Tracked by CNHP/CPW? ES A* Stat e* Mammals Abert's squirrel Sciurus aberti G5 S5 Documented SWAP Tier 2 Bighorn sheep Ovis canadensis G4 S4 Documented SWAP Tier 2 Bison Bison bison G4 SX Documented/ reintroduced SWAP Tier 2 Black-footed ferret Mustela nigripes G1 S1 Documented/ reintroduced CNHP full/ SWAP Tier 1 E E Black-tailed prairie dog Cynomys ludovicianus G4 S3 Documented CNHP partial/ SWAP Tier 2 SC Dwarf shrew Sorex nanus G4 S2 Potential CNHP full/ SWAP Tier 2 Fringed myotis Myotis thysanodes G4 S3 Documented CNHP full/ SWAP Tier 1 Hoary bat Lasiurus cinereus G5 S5B Documented SWAP Tier 2 Northern pocket gopher Thomomys talpoides agrestis G5T3 S3 Potential CNHP partial Olive-backed pocket mouse Perognathus fasciatus G5 S3 Documented CNHP full/ SWAP Tier 1 Preble's meadow jumping mouse Zapus hudsonius preblei G5T2 S1 Documented (historic) CNHP full/ SWAP Tier 1 T T River otter Lontra canadensis G5 S3S4 Documented SWAP Tier 2 T Sagebrush vole Lemmiscus curtatus G5 S1 Potential CNHP full/ SWAP Tier 2 Swift fox Vulpex velox G3 S3 Documented CNHP full/ SWAP City of Fort Collins Natural Areas Department, 2016 10 Common Name Scientific Name Globa l Rank State Rank Document ed or Potential* Tracked by CNHP/CPW? ES A* Stat e* Brewer's sparrow Spizella breweri G5 S4B Documented SWAP Tier 2 Burrowing owl Athene cunicularia G4 S4B Documented CNHP watch/ SWAP Tier 1 T Cassin's finch Peucaea cassinii G5 S5 Documented SWAP Tier 2 Cassin's sparrow Aimophila cassinii G5 S4B Documented CNHP watch/ SWAP Tier 2 Chestnut-collared longspur Calcarius ornatus G5 S1B Documented CNHP full/ SWAP Tier 2 Ferruginous hawk Buteo regalis G4 S3B, S4N Documented CNHP full/ SWAP Tier 2 SC Flammulated owl Otus flammeolus G4 S4 Documented SWAP Tier 2 Forester's tern Sterna forsteri G5 S2B, S4N Documented CNHP full Golden eagle Aquila chrysaetos G5 S3S4B, S4N Documented SWAP Tier 1 Grasshopper sparrow Ammodramus savannarum G5 S3S4B Documented SWAP Tier 2 Greater sandhill crane Grus canadensis tabida G5T4 S2B, S4N Potential CNHP full/ SWAP Tier 1 SC Lark bunting Calamospiza melanocorys G5 S4 Documented SWAP Tier 2 Lazuli bunting Passerina amoena G5 S5B Documented SWAP Tier 2 Least tern Sterna antillarum G4 S1B Documented CNHP full/ SWAP Tier 2 E E Lewis's woodpecker Melanerpes lewis G4 S4 Documented CNHP full/ SWAP Tier 2 Loggerhead shrike Lanius ludovicianus G4 S3S4B Documented SWAP Tier 2 Long-billed curlew Numenius americanus G5 S2B Documented CNHP full/ SWAP City of Fort Collins Natural Areas Department, 2016 11 Common Name Scientific Name Globa l Rank State Rank Document ed or Potential* Tracked by CNHP/CPW? ES A* Stat e* Short-eared owl Asio flammeus G5 S2B Documented CNHP full/ SWAP Tier 2 Snowy egret Egretta thula G5 S2B Documented CNHP full Swainson's hawk Buteo swainsoni G5 S5B Documented SWAP Tier 2 Upland sandpiper Bartramia longicauda G5 S3B Documented SWAP Tier 2 Veery Catharus fuscescens G5 S3B Documented CNHP watch/ SWAP Tier 2 Virginia's warbler Oreothlypis virginiae G5 S5 Documented SWAP Tier 2 Western snowy plover Charadrius alexandrinus nivosus G3T3 SB1 Documented CNHP full T SC White-faced ibis Plegadis chihi G5 S2B Documented CNHP full/ SWAP Tier 2 Willet Catoptrophorus semipalmatus G5 S1B Documented CNHP full Willow flycatcher Empidonax trailii G5 S4B Potential CNHP watch Wilson's pharalope Phalaropus tricolor G5 S4B, S4N Documented CNHP full Fish Brassy minnow Hybognathus hankinsoni G5 S3 Documented CNHP full/ SWAP Tier 1 T Common shiner Notropis cornutus G5 S2 Documented CNHP full/ SWAP Tier 1 T Iowa darter Etheostoma exile G5 S3 Documented CNHP full SC Northern redbelly dace Phoxinus eos G5 S1 Documented CNHP full/ SWAP Tier 1 E Orangespotted sunfish Lepomis humilis G5 S5 Documented SWAP Tier 1 Plains topminnow Fundulus sciadicus G4 S4 Documented SWAP Tier 1 Reptiles and Amphibians Northern leopard frog Lithobates pipiens G5 S3 Documented (historic) CNHP full/ SWAP Tier 1 SC City of Fort Collins Natural Areas Department, 2016 12 Common Name Scientific Name Globa l Rank State Rank Document ed or Potential* Tracked by CNHP/CPW? ES A* Stat e* Dusted skipper Atrytonopsis hianna G4 S2 Potential CNHP full Hairy sallfly Alloperla pilosa G3 S2 Potential CNHP full Hops blue Celastrina humulus G2 S2 Documented CNHP full Larimide sallfly Suwallia wardi G3 S2 Potential CNHP full Lusk's pinemoth Coloradia luski G4 S1 Potential CNHP full Modest sphinx moth Pachysphinx modesta G4 S2 Potential CNHP full Morrison's skipper Stinga morrisoni G4 S3 Potential CNHP full Moss' elfin Calliphorys mossii schryveri G4T3 S2 Documented CNHP full Mottled dusky wing Erynnis martialis G3 S2 Potential CNHP full Ottoe's skipper Hesperia ottoe G3 S2 Documented CNHP full Plains snowfly Mesocapnia frisoni G5 S1 Potential CNHP full Regal frittilary Speyeria idalia G3 S1 Documented CNHP full Rhesus skipper Polites rhesus G4 S2 Documented CNHP full Sandhill fritillary Boloria selene sabulocollis G5T2 S1 Potential CNHP full Simius roadside skipper Amblyscirtes simius G4 S3 Potential CNHP full Smoky eyed brown Satryodes eurydice fumosa G5T3 S1 Documented CNHP full Stevens' torticid moth Decodes stevensi GNR S1 Potential CNHP full Two-banded skipper Pyrgus ruralis G5 S3 Potential CNHP full Two-spotted skipper Euphyes bimacula G4 S2 Documented CNHP full *Northern Bobwhite- There is some uncertainty if the birds seen in the area are native as there were reintroductions across the state historically. City of Fort Collins Natural Areas Department, 2016 13 Key to Wildlife Species of Interest Colorado Natural Heritage Program (CNHP) Ranking (not a legal designation) Level Description G/S-1 Critically imperiled globally/state because of rarity (5 or few occurrences in the world/state; or very few remaining individuals), or because of some factor of its biology making it especially vulnerable to extinction. G/S-2 Imperiled globally/state because of rarity (6-20 occurrences), or because of other factors demonstrably making it very vulnerable to extinction throughout its range. G/S-3 Vulnerable through its range or found locally in a restricted range (21-100 occurrences). G/S-4 Apparently secure globally/state, though it might be quite rare in parts of its range, especially at the periphery. G/S-5 Demonstrably secure globally, though it may be quite rare in parts of its range, especially at the periphery. GNR Not yet ranked globally. G#T# Trinomial rank (T) is used for subspecies ranked on the same criteria as G1-G5. S#B Refers to the breeding season imperilment of elements that are not permanent residents. S#N Refers to the non-breeding season imperilment of elements that are not permanent residents. Where no consistent location can be discerned for migrants or non-breeding populations, a rank of SZN is used. SZ Migrant whose occurrences are too irregular, transitory, and/or dispersed to be reliably identified, mapped, and protected. Notes: # represents rank (1-5). Where two numbers appear in a state or global rank (e.g., S2S3), the actual rank of the element falls between the two numbers. State/Federal Status (legal designation) Level Description SE State Endangered--those species or subspecies of native wildlife whose prospects for survival or recruitment within Colorado are in jeopardy, as determined by the Colorado Parks and Wildlife (CPW). ST State Threatened--those species or subspecies of native wildlife which, as determined by the CPW, are not in immediate jeopardy of extinction but are vulnerable because they exist in such small numbers, are so extremely restricted in their range, or are experiencing such low recruitment or survival that they may become extinct. City of Fort Collins Natural Areas Department, 2016 14 SC State Special Concern--species or subspecies of native wildlife which have been removed from the State threatened or endangered list within the last 5 years; are proposed for Federal listing (or are Federal listed “candidate species”) and are not already State listed; have experienced, based on available data, a downward trend in numbers or distribution lasting at least 5 years which may lead to a threatened or endangered status; or are otherwise determined to be vulnerable in Colorado, as determined by the CPW. E Federal Listed Endangered--defined by the U.S. Fish and Wildlife Service as a species, subspecies, or variety in danger of extinction throughout all or a significant portion of its range. T Federal Listed Threatened--defined as a species, subspecies, or variety likely to become endangered in the foreseeable future throughout all or a significant portion of its range. Colorado Parks and Wildlife (CPW) State Wildlife Action Plan (SWAP) listed or Colorado Natural Heritage Program (CNHP) tracking Level Description SWAP Tier 1 SWAP species are Species of Greatest Conservation Need as determined by CPW. Tier 1 species are a higher relative priority for conservation efforts than are Tier 2 species. Tier 1 species are of highest conservation priority in the state of Colorado. SWAP Tier 2 SWAP Tier 2 species are species in which conservation is important in stalling population trends but the urgency for these species is considered less than for Tier 1 Species. See the CPW State Wildlife Action Plan for more detailed information on Tier1 and Tier 2 Species. CNHP Full Tracked For a species to be fully tracked it has the following ranks: (G1, G2, G3, G4 and G5) with the state rank combo of S1 or S2. CNHP watchlist CNHP maintains information on these species so that if a declining trend becomes apparent, watchlisted species can be changed back to tracked species in the database. CNHP Partial Tracked Partial tracking is only used for the most common plant communities in Colorado. Animals and plants are not partially tracked by CNHP. Planning & Zoning Board January 12, 2017 Page 2 x While the City staff provides comprehensive information about each project under consideration, citizen input is valued and appreciated. x The Board is here to listen to citizen comments. Each citizen may address the Board once for each item. x Decisions on development projects are based on judgment of compliance or non-compliance with city Land Use Code. x Should a citizen wish to address the Board on items other than what is on the agenda, time will be allowed for that as well. x This is a legal hearing, and the Chair will moderate for the usual civility and fairness to ensure that everyone who wishes to speak can be heard. Planning Director Gloss reviewed the items on the Consent and Discussion agendas, as well as the tow items under “Other Business”, for the audience. Public Input on Items Not on the Hearing Agenda: None noted. Consent Agenda: 1. Draft Minutes from December 15, 2016, P&Z Hearing Public Input on Consent Agenda: None noted. Member Hobbs made a motion that the Planning and Zoning Board approve the January 12, 2017, Consent agenda. Member Carpenter seconded the motion. Vote: 6:0. Discussion Agenda: 2. Gateway at Prospect Rezoning and Overall Development Plan 3. Land Use Code Changes Related to Natural Resources and Prairie Dog Management 4. Copperleaf PDP Project: Land Use Code Changes Related to Natural Resources and Prairie Dog Management Project Description: Since the original Land Use Code provisions regarding prairie dog colonies were adopted, there has been considerable change in the size and characteristics of prairie dog colonies within the Growth Management Area, best practices for fumigation and relocation, and citywide development patterns. Based on the latest research on the ecosystem value of prairie dog colonies and current best management practices, staff proposes a number of Land Use Code updates regarding prairie dog management and the protection of natural habitats and features on development sites. Recommendation: Approval Project: Land Use e Code Cha Changes Related to Natural Resources and Prairie Dog Management ATTACHMENT 4 Planning & Zoning Board January 12, 2017 Page 3 Applicant Presentations Planner Everette provided a detailed presentation of this recommendation, discussing protection of prairie dog colonies and mitigation of impacts for those colonies greater than 50 acres in size. For colonies less than 50 acres in size, no mitigation or protection is required. Based on aerial photography, staff estimates that there are about 72 colonies remaining on private property throughout the city, totaling approximately 356 acres. She showed maps of the growth management areas, showing general distribution and size of these colonies and explained how they could impact future potential annexation areas. Staff is proposing several changes: x a reduction to the size threshold in order to be more in line with actual colony sizes; x mitigation requirements based on those threshold sizes; and x the addition of a reporting provision that requires documentation of all prairie dog removal activities on development sites. She discussed certain terminologies: “species of concern” and “specially-valued species” (including threatened or endangered). Staff is proposing the addition of a new code provision and a definition that helps clarify a section of the LUC that also aligns with State and Federal definitions. The standard 3.4.1 has been updated for clarification for species that don’t have State and Federal protections (there is some flexibility on protections and impact mitigations). She added that there will be a number of “clean- up” items included (i.e.: updated names and clarification of some terms and references). Public Input Bob Miller, 3611 Richmond Drive, is not in favor of this recommendation, saying that he feels these regulations will burden the private sector. Rob Haas, 1994 Kinnison Drive, is opposed to these regulations, saying that additional regulations add to housing costs and result in more negotiations with the City. Eric Sutherland stated his concern that prairie dogs could be an indicator of our environmental health and would like to see more sustainable approaches to development. Rich Maroncelli, 1013 Fox Hills Drive, would like to see a prairie dog reduction, but he is unclear as to the LUC classification of these animals. He isn’t convinced that they should be protected, as they are very invasive. Board Questions and Staff Response Interim Vice Chair Hansen asked if any public lands within City limits were surveyed; Planner Everette believes that Natural Areas may have an estimate, but there is nothing specific for lands within City limits. Member Hobbs asked if a private citizen with a development proposal must also do an inventory of plants and animals to survey for sensitive and specially-valued species; Planner Everette responded that, if City believes there is such a concern, they will require an Ecological Characterization Study (ECS) to be performed, but it isn’t required for all development proposals. Member Rollins inquired as to why the acreage was reduced from 50 to 1 acre; Planner Everette responded that the 50 acres was out of context with the private property communities; therefore, the proposed threshold captures the majority of development sites with prairie dog colonies. Interim Chair Schneider asked if there is an established threshold that would indicate a healthy acreage for prairie dog colonies; Planner Everette said that studies have not identified a standard acreage as such. He also asked what staff’s original concerns were; Planner Everette responded that prairie dogs were treated differently from other resources (i.e. Planning & Zoning Board January 12, 2017 Page 4 foxes, coyotes, birds, raptors). Prairie dogs are considered to be a valuable species that aren’t being acknowledged like other species, so Staff’s purpose was to update the code to be more specific and inclusive. Member Rollins asked what the cost would be to mitigate a prairie dog colony. Based on the colony size, the main cost would be cost of mitigation ($500-800 for an ECS), payment in lieu mitigation approach ($900/acre), and fumigation costs would vary. Member Carpenter asked if there are any places where prairie dogs are endangered; Planner Everette responded that the Black-Tailed prairie dog is a “species of concern” and is dwindling in population. Member Whitley asked if they are a food source for threatened or endangered species; Planner Everette responded that they are a food source for a number of threatened species of raptors, eagles, and owls. Member Hobbs asked if mitigation will always be an option to an Applicant; Planner Everette confirmed that is the case, including sensitive species in some cases. Interim Chair Schneider asked if circumvention of this policy will occur as a way for developers to avoid paying fees; Planner Everette admitted that this is a concern, however, the regulation goal is to set reasonable mitigation requirements to encourage property owners to maintain the prairie dogs rather than eradicate them, thereby retaining some ecological value. He also asked if there is another plan for determining an appropriate acreage size. Staff had discussed the option of reducing the current threshold to 2 acres in order to capture the majority of properties with prairie dogs. Member Rollins questioned the reasonableness of requiring an ECS and asked if lowering the costs might result in more Applicant participation. Planner Everette responded that the ECS applies to many ecological features in the community, so removing that requirement would be inconsistent with other development requirements. Member Carpenter asked if there was an actual relocation site for prairie dogs, and Planner Everette stated that Natural Areas has been reluctant to accept prairie dogs onto their properties but are now considering several suitable habitats. There was more discussion on how to vote on the various topics within this proposal. Assistant City Attorney Yatabe provided some counsel on how to make a motion with conditions. Board Deliberation Member Carpenter made a motion that the Planning and Zoning Board recommend to City Council denial of the Land Use Code changes for the Prairie Dog Management section, based upon the findings of fact contained on page 3-4 in the staff report that is included in the agenda materials for this hearing and the board discussion on this item. Member Rollins seconded. Member Hobbs is not sure the proposed LUC changes will properly protect the prairie dogs, but determines how the prairie dogs are eradicated in a reasonable and humane way. Member Carpenter asked to clarify about the methods of mitigation for this motion; Assistant City Attorney Yatabe stated that the proposed LUC changes do not address the method by which prairie dogs can be exterminated; rather, the City is preempted under State statute for mitigation methods. Interim Chair Schneider does not see the benefit of regulation, and it appears that it will result in higher development costs. Interim Vice Chair Hansen agrees, adding that this would simply establish more hurdles for developers. Vote: 4:2, with Members Hobbs and Whitley dissenting. Member Hobbs made a motion that the Planning and Zoning Board recommend to City Council approval of the proposed Land Use Code changes relating to “sensitive and specially-valued species” as defined in the staff report for the Prairie Dog Management section. Member Carpenter seconded. Vote: 6:0. Member Hansen made a motion that the Planning and Zoning Board recommend to City Council approval of the miscellaneous LUC pertaining to the natural habitats and definitions along with wetlands for the Prairie Dog Management section, based upon the findings of fact contained in Planning & Zoning Board January 12, 2017 Page 5 the staff report that is included in the agenda materials for this hearing and the board discussion on this item. Member Whitley seconded. Vote: 6:0. Cameron Gloss, Planning Director Chair Land Conservation and Stewardship Board July 13, 2016 ATTACHMENT 5 Dear Members of the Board: A few of us from the Fort Collins Prairie Dog Relocation Group had the opportunity to attend your meeting on May 6 and hear the discussion about changes to the current LUC related to prairie dogs. We’d like to provide you with a little more information to consider as you weigh city staff’s recommendations. The Fort Collins Prairie Dog Relocation Group took shape last year as we sought a relocation site for prairie dog colonies along Lemay Ave., between Vine and Lincoln. Many of us have enjoyed watching these colonies for years. When we saw the development signs go up, we couldn’t bear the thought of seeing yet another lively prairie dog community destroyed. In January 2016, we succeeded in our appeal to the Fort Collins City Council, and space within the Cathy Fromme Prairie Natural Area was designated as a receiving site for these colonies. We’ve received our permits from the city and Colorado Parks and Wildlife and will relocate one colony in the May-June timeframe and another in mid to late August. For decades prairie dogs in Fort Collins have been routinely poisoned to make way for development. We’re working to end that practice and create a new precedent and process to relocate rather than kill our last remaining urban colonies. We know these animals can’t stay where they are, but while extermination is the most expeditious and affordable solution, we believe it’s the wrong one. We shouldn’t be killing our remaining black-tailed prairie dogs when: x It’s widely acknowledged that the species is in decline throughout the west due to poisoning, shooting and plague. x Relocations have taken place for more than 20 years, and current methods are thorough and effective. x We believe there is ample space within city-owned natural areas suitable for receiving the remaining urban colonies. x These colonies could augment populations supporting the black-footed ferret that have been hit by plague in recent years. x This keystone prairie species has a complex community life and language. x Many of the poisons used, such as aluminum phosphide, cause the creatures that inhale or ingest them great pain and suffering. x Relocation provides an opportunity to educate the public about the important role prairie dogs play in a healthy prairie ecosystem and demonstrate that preservation of wildlife is a community value. x Many citizens in this community want to see these animals moved instead of poisoned. At Friday’s meeting Natural Areas Director John Stokes told you that an aerial survey indicates we have something in the neighborhood of 300 acres of prairie dog colonies remaining within the GMA. Natural Areas manages more than 40,000 acres of land. ATTACHMENT 6 Currently only about 2,000 acres have prairie dogs. Four thousand acres at Soapstone Prairie have been designated as a prairie dog conservation area, and right now prairie dogs occupy only about 1,500 acres there. Mr. Stokes also told you that relocated prairie dogs have only a 20-40 percent survival rate, and the cost to relocate is between $150 and $400 per prairie dog. First, while data is scant because it’s very difficult to tag and recapture prairie dogs to do an accurate count, experienced relocation professionals in the region report relocation success rates—that is the number that survive the relocation process—as high as 90-95 percent. More data is needed to determine longer term survival rates. But we would argue that that’s all the more reason to do more relocations. As to the cost, it’s significantly less expensive to place prairie dogs into existing, vacant burrows, like those that are likely plentiful at Soapstone, than to build artificial burrows, as we’re doing for the relocation to Cathy Fromme. The cost also drops depending on the time of year; the best time to move prairie dogs is in late summer or early fall when the population is full grown, numbers are stable and the animals are most easily trapped. Representatives of the Humane Society’s Prairie Dog Coalition say the cost for the relocations is closer to $50 to $150 per animal, or $1,000 to $3,000 per acre. The cost to exterminate can run between $500 and $1,000 per acre. For our relocation this summer, we’re making good use of volunteers and fundraising. There will be no cost to taxpayers. Going forward, we think that modest mitigation fees for developers, as some cities have, will be key to covering relocation costs. At your meeting, Rebecca Everette shared several staff recommendations for changes to the LUC. We agree with some and feel others fall short of what is needed. As representatives of a citizen group involved in prairie dog relocation and eager to see real and lasting improvement in the way we manage urban prairie dogs in Fort Collins, we ask you to consider the following: x We agree with staff that the 50-acre threshold for mitigation is arbitrary and no longer applicable given the sizes of remaining colonies. We believe the city should “eliminate the threshold and require consideration of all prairie dog colonies.” Just as the LUC requires mitigation for other natural features, it should require mitigation for prairie dogs. x Given that the city has adequate space within its natural areas to receive the remaining colonies in the GMA and there are professionals available to perform successful relocations, we believe that developers should be required to explore relocation prior to other mitigation techniques and that professional relocation should become the primary means of removing prairie dogs from a development site. x In the event that fumigation is necessary, we agree that the city should require the use of carbon monoxide fumigation methods and forbid the use of all other fumigants, long known to inflict a cruel and painful death. x We agree that the city should “require a report to be submitted documenting the timing and methods used to remove prairie dogs.” x We believe that the LUC should be updated to reflect the current Species of Concern List and that the list, whether it is the city’s or the state’s, should include the black-tailed prairie dog. We reject the view that the only “value” these urban colonies have is as a food source for predators and habitat for burrowing owls and other animals. We believe prairie dogs themselves have inherent value as native wildlife worthy of our appreciation and humane management. The indiscriminate extermination of these animal communities has gone on far too long. We want to teach people about these remarkable animals, instill a sense of community pride in how we manage them, and ultimately make relocation the standard rather than the exception. To do that we believe we need a commitment from Natural Areas to provide the relatively small amount of land needed to receive remaining colonies in the GMA and modest economic incentives for developers to relocate rather than exterminate. Thank you for your consideration of our position on these issues. If you’d like to know more about prairie dogs and the relocation process, you’ll find excellent information at the Humane Society’s Prairie Dog Coalition website www.humanesociety.org/about/departments/prairie_dog_coalition/ and at www.growingideas.tv. Sincerely, Helen Taylor (970) 556-3994 Helentaylor3@comcast.net Fort Collins Prairie Dog Relocation Group 1 June 7, 2016 Dear City Staff, RE: Recommendations regarding the City of Fort Collins Natural Areas Department Prairie Dog Management Review Workshop, March 22, 2016, as prepared by Pam Wanek with the Prairie Dog Coalition Thank you for the opportunity to participate in the Workshop and provide comments on the City’s Urban Prairie Dog Management element as found in the 2007 Natural Areas Wildlife Management Guidelines. Our recommendations for changes to your guidelines pertain to: 1. Local connectivity to statewide goals 2. Emphasis on the value of prairie dogs in urban environments 3. Vegetative influence 4. Population and landscape dynamics 5. Disease 6. Local government legal tools 7. Lethal Control 8. Non-lethal Control 9. Mitigation 10. Conclusion As a species, prairie dogs have continuously been one of the most controversial and widely persecuted wildlife species since early European settlement of the North American Grasslands. Prairie dogs have been criticized as destructive rodent pests but also regarded as an essential keystone species for healthy grasslands ecosystems. Agricultural crop conversion, livestock grazing, energy and oil and gas development, urban/ex-urban development, shooting, poisoning, and plague have decimated their numbers and resulted in a 98% loss of their historic range. Therefore, the conservation of this species will be important, not only because of the intrinsic value of prairie dogs, but for the protection of all species that depend on prairie dogs and their habitats for survival. 1. Local connectivity to statewide goals The goal of prairie dog plans should be to adopt policies and land use planning strategies that are consistent with state and local laws for the protection, management, and participation of statewide and region-wide persistence of prairie dogs and associated species, to protect biodiversity for today’s and future generations. 2 Black-tailed prairie dogs (BTPDs) are known to exist in 11 states across the continental U.S.1 Historically in Colorado, BTPDs occupied about 7 million acres.2 In 2003, the state adopted a “Conservation Plan for Grassland Species in Colorado” as a cooperative action with the United States Fish and Wildlife Service (USFWS) to avoid species listing. The plan details objectives, population monitoring and a commitment for a shared responsibility among other states to ensure long-term viability of the prairie dog and associated species to avoid listing under the Federal Endangered Species Act. This plan may be used as a basis for applying for an umbrella Candidate Conservation Agreement with Assurances (CCAA) that would apply to all landowners in the state. By securing a CCAA, the state ensures control, management and conservation of grassland species. Species included in the CCAA application would remain unaffected by a federal ESA listing as long as the CCAA terms were met. Landowners can also apply for individual CCAAs. The plan commits the participant to monitoring occupied BTPD habitat on a county by county basis every 3 years. Contained within the state Grassland Plan are 12 objectives that include but are not limited to: working directly with city and county open space departments to encourage statewide persistence and establishing a shared responsibility for prairie dog conservation along the Front Range and eastern plains.3 BTPDs are classified by the Colorado Parks and Wildlife (CPW) as "other small game," and by the Colorado Department of Agriculture as a "destructive rodent pest." These classifications provide little protection. In addition, landowners, (or an agent of the landowner) may hunt, trap, or kill prairie dogs when they are causing damage to crops, real or personal property or livestock. 4 Statewide, BTPDs are listed as a Species of Special Concern statewide and a Species of Greatest Conservation Need in the 2015 State Wildlife Action Plan. As such, prairie dog persistence and “occupied acreage” is a matter of statewide concern. Recommendations: x Adopt local plans that connect to statewide goals x Remain current on the listing status of prairie dogs and associated species by reviewing the State Wildlife Action Plan, and the Colorado Natural Heritage Program (CNHP) and CPW websites. These agencies are state funded to help local governments, developers and private landowners with guidance to protect wildlife and wildlife habitat. 2. Emphasis on the value of prairie dogs in urban environments Prairie dogs are a keystone species because their impact on plant and animal communities is unique and is disproportionately large relative to their abundance; this is critical to the integrity of the grassland ecosystem.5 6 On the landscape, prairie dogs meet two criteria as ecosystem engineers: 1). They create a patch in the landscape with a 1 Luce, R.J. 2003. A Multi-State Conservation Plan For The Black-tailed Prairie Dog, Cynomys ludovicianus, in the United States – an addendum to the Black-tailed Prairie Dog Conservation Assessment and Strategy, November 3, 1999. 2 Gillette, C.P. 1919. 10th Annual Report of the State Entomologist of Colorado. Fort Collins, Colorado. 56 pp. Retrieved from EDAW Inc., (2000) Black-Tailed Prairie Dog Study of Eastern Colorado, October 27, 2000 3 Conservation Plan for Grassland Species in Colorado 2003. http://cpw.state.co.us/Documents/WildlifeSpecies/Grasslands/wholeplan.pdf#search=grassland%20plan Retrieved 4/6/2016 4 http://cpw.state.co.us/learn/Pages/SOC-Black-tailedPrairieDogRelocationFacts.aspx 5 Hoogland, J.L. 2006. 6 Kotliar, N.B., B.W. Baker, A.D. Whicker, and G. Plumb. 1999. A critical review of assumptions about prairie dogs as a keystone species. Environmental Management 24:177-192 3 combination of conditions that are not present elsewhere in the landscape, and 2). Other species that live in the engineered patches are not present in patches unmodified by the engineer.7 Research published by Magle and Crooks (2008) on 54 fragmented urban colonies throughout the Denver metropolitan area suggests that the urban prairie dogs may still provide a keystone and ecosystem engineering function; however, more studies will need to be conducted for that determination. Magle noted that prairie dog disturbance of vegetation on urban colonies was similar to disturbances on rural colonies; where prairie dogs removed grasses, reduced plant litter and increased bare ground and forbs. Similar to rural populations, urban prairie dog colonies also retained some ecological function. In conclusion, their report suggests that if future findings indicate that prairie dogs function as a keystone species in urban systems, their conservation will be an important step in maintaining functional grassland systems in urban environments.8 Also, Magle et al showed in 2014 that, “Overall, rates of coyote conflict appeared elevated in proximity to undeveloped land, but these rates were highest near habitat fragments where prairie dogs were absent, and 15–45% lower within 400 m of fragments colonized by prairie dogs.”9 Urban raptor studies were conducted by Dave Weber and CPW (2004) to implement an initiative to protect or replace prairie dog towns being lost to development as Denver expands. Their studies indicated that winter raptor use on urban prairie dog colonies was substantially higher than on rural areas. While it would seem that raptors would be much more likely to hunt in more undisturbed areas, this study revealed that raptors were uninhibited by urban disturbances. “The amount of urbanization did not seem to impact raptor use at all. Raptor use seemed more contingent on the number of prairie dogs within each town, more prairie dogs, more raptors.” Four species of raptors were most commonly observed: ferruginous hawks 39.1%, red-tailed hawks 22.5%, bald eagles 15.3%, golden eagles 6.4%, and other/unidentified 16.7%. There was high variability in raptor use from one town to the next, ranging from a high of 12.0/hour to a low of 0.5/hour. The study included a broad spectrum of urban colony sizes from 50 to 300 active burrows. 10 Avian densities may also be higher on prairie dog colonies because prairie dogs create a vegetative patchiness that results in lower amounts of mulch and lower vegetative height, which may result in greater visibility of macroarthropods and seeds.11 Recommendations: x Science supports that urban prairie dogs do play a beneficial role in supplying a food source for wintering raptors x Additional research is needed to determine if urban prairie dogs and colonies may have a keystone role in the urban grassland system x To reduce conflicts with coyotes and domestic animals, urban prairie dog colonies are needed. 3. Vegetative Influence 7 Wright, J.P, Jones, C.G., Flecker, A. S. 2002 An ecosystem engineer, the beaver, increases species richness at the landscape scale. Oecologia (2002) 132:96–101 8 Magle, S. B and Crooks, K.R. 2008. Interactions between black-tailed prairie dogs (Cynomys ludovicianus) and vegetation in habitat fragmented by urbanization, Journal of Arid Environments 72 (2008) 238-246. 9 Magle, S., Poessel, S.A., Crooks, K.R., and Breck, S.W. 2014. Landscape & Urban Planning. More dogs less bite: The relationship between human–coyote conflict and prairie dog colonies in an urban landscape. Urban Wildlife Institute, Department of Conservation and Science, Lincoln Park Zoo, 2001 N. Clark Street, Chicago, IL 60614, USA. 10 Weber, D. 2004. Winter raptor use of prairie dog towns in the Denver, Colorado vicinity, Proceedings 4th International Urban Wildlife Symposium. Shaw et al., Eds. 2004 11 Agnew, William, Daniel W. Uresk, Richard M. Hansen. 1986. “Flora and Fauna Associated with Prairie Dog Colonies and Adjacent Ungrazed Mixed-grass Prairie in Western South Dakota.” Journal of Range Management 39(2), March l986 4 Prairie dogs not only support a predator/prey relationship, but their influence on the grasslands creates patches of vegetation that are dramatically different by altering graminoids (monocots) towards predominately forb and dwarf shrub (dicots) species; thus, increasing plant diversity supportive of a wide range of animal species. Studies by Detling, J. K., and Whicker, A. D. (1987) noted that these unique patches allow for a greater diversity of plant species to thrive and provide favorable habitat patches for other animals, thus increasing habitat diversity for other wildlife species. Grazing by prairie dogs removes aging plant matter and stimulates the growth of new plant tissue that generally has higher concentrations of nitrogen and greater digestibility than ungrazed plants. Burrowing and grazing activities of prairie dogs may also influence below-ground plant dynamics. Some estimates indicate that most of the energy flow in grassland systems occurs belowground and that soil invertebrate may consume as much or more plant biomass than cattle on the mixed grass prairie.12 Studies conducted on prairie dog occupied sites of mixed grass prairie in South Dakota noted that rapid changes occurred within the first two years following colonization but by the third year bare ground had stabilized at 35% and litter cover had decreased to less than 10%.13 Prairie dogs increase the benefit of soils to plants and soil organisms by adding organic matter and nutrient salts to soils, improving soil structure and increasing water filtration.14 Prairie dog grazing and burrowing also changes the structure of individual plants and plant composition. Over time, plant composition and heterogeneity can change. There are distinct zones on prairie dog occupied sites where the core of a colony that has been occupied the most is predominately comprised of forbs, annuals and shrubs. In transition zones, or newly colonized areas, the composition is a mixture of perennial grasses, short grasses and forbs.15 Burrowing and grazing activities by prairie dogs mixes soils and regulates vegetation diversity. Prairie dogs alter soil structure and chemical composition by their addition of excrement and plant material. Their activities result in the aeration, pulverization, granulation and transfer of soil. When compared to uncolonized grasslands, prairie dog colonies were richer in nitrogen, phosphorus and organic matter.16 Vegetative studies of urban versus rural colonies conducted by Lehmer, E.M., et al. on 8 colonies in Boulder in 2010, indicated that although prairie dogs impose substantial changes in vegetation structure upon the landscape; these changes do not seem disproportionate in areas that occur outside of their traditional habitats, and they do not necessarily convert suitable habitat patches into unsuitable patches.17 While prairie dogs prefer graminoids over forbs, their diets will adjust to forage availability.18 Their diet varies with season, location on towns, and vegetative composition.19 And prairie dogs still seemed to thrive on nonnative vegetation.20 12 Detling, J. K., and Whicker, A. D. 1987. "Control of Ecosystem Processes by Prairie Dogs and Other Grassland Herbivores" (1987). Great Plains Wildlife Damage Control Workshop Proceedings. Paper 57. http://digitalcommons.unl.edu/gpwdcwp/ 13 Ibid. 14 Koford, C.B. 1958. Prairie dogs, whitefaces, and blue grama. Wildlife Monographs 3:1-78. 15 Slobodchikoff, C.N., Perla, B.S., Verdolin, J.L.2006. Prairie Dogs, Communication and Community in an Animal Society. Harvard University Press 16 Sharps, Jon C.,Uresk, Daniel W. 1990. “Ecological Review of Black-tailed Prairie Dogs and Associated Species in Western South Dakota,” Great Basin Naturalist 50(4), pp339-345 17 Lehmer, E.M., L. Hartley, J. Lanci and C. Kolb. 2010. Evaluating the Impacts of Black-tailed Prairie dogs on Vegetation in Traditional and non-traditional habitat 18 Fagerstone, Kathleen, A. l981. “A Review of Prairie Dog Diet and its’ Variability Among Animals and Colonies” Great Plains Wildlife Damage Control Workshop Proceedings. Paper 118 http://digitalcommons.unl.edu/gpwdwp/118 19 Koford, C.B. 1958. 20 Magle, S. B and Crooks, K.R. 2008. 5 As prairie dogs have a tendency to keep vegetation short within colonies, prairie dog grazing behaviors may mitigate the proliferation of undesirable weedy species. John Hoogland noted that the following plants were either clipped or consumed by prairie dogs: black nightshade, brome, cocklebur, deathcamus, false pennyroyal, fescue, foxtail, horseweed, knotweed, lambsquarters, milkvetch, mullein, pepperweed, phlox, pigweed, plantain, prairie dog weed, ragweed, Russian thistle, scurfpea, skeleton weed, sorrel, spiny buffalo bur, spurge, stickseed, thistle, threeawn, tumblegrass and verbena.21 Clippinger also observed that prickly lettuce, goosefoot and kochia were either consumed or clipped by prairie dogs.22 Here prairie dogs benefit land managers by removal of nonnative weeds. Best land use practices should only focus on weeds that are problematic and not consumed by prairie dogs. Boulder County reports indicate that opportunistic weedy species were given the chance to establish themselves in the absence of prairie dogs. Weeds were highly likely to germinate each year in areas of colony disturbance, but when prairie dogs were present, they were eaten as sprouts. This not only sustains the prairie dog, but prevents the weeds from growing to heights that would exceed the prairie dogs’ comfort zone. Although introduced weeds are perhaps not welcome from an aesthetic and weed-seed production point of view, the cover they provide is positive from the standpoint of erosion control.23 Prairie dogs are not only beneficial for reduction of weeds, but they also play a role in the creation of firebreaks where land managers want to control vegetative heights.24 Understanding prairie dog influence on vegetation may help determine what, if any, action should be taken to reestablish vegetation on prairie dogs colonies to reduce weeds and erosion. John Vickery, a land resource officer located in Denver, has documented certain features of native plants that prairie dogs seem to avoid: 1. Are poisonous and/or have a disagreeable taste (milkweeds, snakeweed); 2. Are foul smelling or have a strong odor (fetid marigold, cleomes, sage, rabbitbrush, pennyroyal); 3. Are prickly (rosa species, yucca, prickly poppy, prickly pear, purple three-awn); 4. Have an abundance of hairs (blazing star, golden rod, aster, vervain); 5. Are prostrate or abided by clipping behavior (bracted vervain, salt and pepper, wild parsley, wooly plantain, buffalograss); 6. Are sticky or gummy (gumweed and bee plant).25 After working over 20 years in the field on multiple prairie dog relocations and having great desire to protect native plant species, I have also observed plants that seem to withstand prairie dog presence. However, I would not necessarily recommend removal of prairie dogs to reestablish plants. Removing prairie dogs could exacerbate a weedy situation, and if prairie dogs are consuming nonnative weeds, this may reduce grazing pressure on newly introduced native species. In cooperation with funding from the City of Boulder and the Prairie Dog Coalition, Wanek and Wold, J. inter-seeded a mixture of 15 to 20 different forbs, some dwarf shrubs and selected graminoids species on plots located in five active colonies during early winter 2016. While it is still too early to tell what will occur, it is nevertheless a pioneering effort to work with prairie dogs instead of against them. It is important to recognize that many native plants thrive on prairie dog occupied sites. These native plant species are a valuable commodity that are not readily available from commercial markets. These seeds should be harvested and preserved as heirloom seeds for reintroduction into prairie dog occupied sites. Additionally, many open space sites are essentially damaged by troublesome introduced grazing grasses, such as bromes. Bromes are a cool season turf spreading grass that are virtually impossible to remove without extensive manmade interventions (herbicides, manual removal). Since, overtime, these mid-height grasses will succumb to intense grazing pressures, prairie dogs can play a beneficial role by exhausting plant reserves. However, prairie dogs 21 Hoogland, J. 1995. 22 Clippinger, Norman W. l989. Habitat Suitability Index Models: Black-tailed Prairie Dog. US Department of Interior, Fish and Wildlife Service, Biological Report 82(10.156) July l989 23 Boulder County Grasslands Management Plan, Prairie Dog Habitat Element, Boulder County, Colorado 2009 24 Kotliar, N.B., B.W. Baker, A.D. Whicker, and G. Plumb. 1999. 25 Vickery, J. ND. Vegetation Management in Urban-to-Exurban Prairie Dog colonies: Context, Issues and Native Plan ‘Survivors’, Power Point. JVickery@MCG,net 6 cannot replace the native plants that once thrived before human’s altered native prairie. In these cases, it would be prudent for resource managers to inter-seed a mix of native short-grasses and forb species into the remaining stubble of bromes before erosion is allowed to occur. Here, prairie dogs have two benefits, one is the removal of an aggressive nonnative grass species and second, maintenance of desirable compatible grassland plant species. Recommendations: x Prairie dogs influence shifts predominately graminoid landscapes towards forb and shrub species x Prairie dog diets adjust to forage availability x Prairie dogs consume many Eurasian weeds x Short vegetative heights are preferred by prairie dogs making colonies useful as firebreaks x Many native plant species are avoided by prairie dogs x Commercial availability of some native plant species varies, thus, native plants on existing colonies are valuable and in some cases priceless x If prairie dogs are not desired in an area, do not mow or reduce the forage height. x Planning in advance of prairie dog colony expansion and migration with tall grass plantings, tall grass or shrub buffers can help prevent conflict. 4. Understanding population and landscape dynamics in managing prairie dogs Understanding natural behaviors of prairie dogs on a landscape will help conservation officers determine the best management direction needed to support prairie dog populations. This section will review how biological and environmental factors influence the birth, death, population size and dispersal of BTPDs. BTPDs are a highly social prey species that lives in family groups called coteries. Coteries usually contain one adult male and several genetically related adult females (mothers, daughters, granddaughters, sisters, nieces and so forth). Coteries can range in size from 1 to 26 individuals where physical coterie boundaries may range from .12 acres to 2.5 acres with an average of about 0.8 acres.26 Colonies are comprised of multiple coteries; extremely large colonies may contain hundreds of coteries. Colony density can range from 10 adults and yearlings per acre, before juvenile emergence, to 20 adults, yearlings and juveniles after emergence. Individual populations can vary in response to vegetation, habitat restrictions, age of colony and predation.27 A study of density in 22 urban colonies in Colorado indicated a range of 13 – 49 prairie dogs per acre.28 Visual counting of prairie dogs is the best method for determining populations of prairie dogs because there is no absolute correlation between density and the number of burrows.29 A metapopulation is a population of populations, in other words, a group of several, interacting local populations or subpopulations that are linked together by immigration or emigration.30 “Colonies must be connected by dispersal so that the negative impact of extinction may be counterbalanced by recolonization management.” And since prairie dog colonies are typically located in swales and seasonal lowlands, they will use natural drainages as dispersal corridors, which increase the likelihood of them encountering other colonies. Potential dispersal corridors, such as drainages, should be maintained to ensure recolonization of unoccupied colonies and continual dispersal among colonies. 26 Hoogland, J. 1995. The Black-tailed Prairie Dog, Social Life of a Burrowing Animal, The University of Chicago Press. 27 Hoogland, J. 2006. 28Johnson, W.C., and S.K. Collinge. 2004. Landscape effects on black-tailed prairie dog colonies. Biological Conservation 115:487-497. 29 Hoogland, J. 1995 and 2006. 30 Gottelli, N.J. 1998. A Primer of Ecology. 2nd ed. Sunderland, MA: Sinauer and Associates. Retrieved from Slobchikoff, C.N., et al. 2009 7 Management of other colonies will have impacts on nearby colonies.31 Spacing between colonies will be important as prairie dogs commonly disperse 1 – 2 miles, but sometimes as far as 4 miles.32 Connectivity between colonies significantly influences the ebb and flow of single species populations, metapopulations, and ultimately the species as a whole. The influence of corridors carries both positive and negative potential by providing gene flow, resource flexibility and pathways to population expansion but may also allow for disease pathways; therefore, in some cases, connectivity should be avoided.33 Understanding the function of coteries, colonies and metapopulations can help land managers create effective land use plans for prairie dogs. In some cases you may want connectivity and other populations may need to be more sequestered from plague. In Colorado, probably the largest single conservation efforts of contiguity of lands among multiple local governments are the flood plains. Since prairie dogs are known to use seasonal dry drainages as dispersal corridors, FEMA maps could be an invaluable land use tool for the purpose of creating metapopulation connectivity as these maps indicate natural drainage areas. Prairie dogs breed one time per year, typically February for BTPDs, where female estrus lasts about 4 hours. After a gestation period of approximately 34 days, they give birth to one litter ranging from 1 to 6 individuals; the most common litter size is 3. The pups are born underground and do not appear above ground for approximately 6 weeks. Prairie dogs are aged from the time they first appear from the natal burrow. When prairie dogs have been above ground for less than 9 months they are called pups or juveniles, yearlings are at least 9 months but less than 21 months and adults are at least 21 months old.34 Therefore, from a time period of about February to May or early June, impregnated females and juveniles are the most vulnerable. BTPDs are not commonly sexually mature until they are two years old. However, other prairie dogs species, such as Gunnison’s, Utah and White-tails are sexually mature as one year olds. Some BTPDs females will delay conception until they are three year olds, and not all females that are sexually receptive conceive or they may abort. In these cases, they must wait an entire year to potentially become impregnated.35 The life span of BTPDs varies. Surviving the first year is the biggest hurdle; mortality in the first 12 months averages 53% for males and 46% for females. Males that survive the first year typically live two to three years and females may live four to five years. The three main causes of mortality in prairie dogs are predation, infanticide and the inability to survive the winter.36 The inability to survive the winter is generally caused by a prairie dog’s inability to store enough accumulated fat during late fall, winter and early spring. Middle-aged prairie dogs are heavier and older and are more likely to survive than younger individuals.37 Infanticide among prairie dogs occurs when an adult kills a juvenile. Most killers are lactating females, and most victims are the offspring of close kin.38 Males that invade a territory with juveniles are also infanticidal.39 In some species infanticide is a response to overcrowding, but John Hoogland's documentation of infanticides occurred at colony that did not have an unusually high density.40 "This bizarre behavior [of infanticide] means that prairie dogs are sometimes their own worst enemy," opines Hoogland.41 31 Roach, J.L., Stapp, P., Van Horne, B., and Antolin, M.F. 2001 Genetic Structure of a Metapopulation of Black-tailed Prairie Dogs, Journal of Mammology, 82(4):946-959. 2001 32 Hoogland, J. 2006. 33 Slobodchikoff, C.N. et al. 2009 34 Hoogland, J. 2006. 35 Hoogland, J. 1995. 36 Hoogland, J. 2006. 37 Ibid. 38 Hoogland, J. 1995 39 Ibid. 40 Ibid. 41 Hoogland, J. 2006. Pg 35. 8 “Short reproduction windows, low litter sizes, and longer periods before sexual maturity make prairie dogs an exception in the rodent world and lead to comparatively lower population growth rates than other rodent species”42 Prairie dogs are not migratory animals, however, they can disperse, singly, not in groups. Most females remain within their natal coterie for life, most males remain in their natal coterie for only the first year, after which they disperse. Peak dispersal of yearling males occurs in May, June and July, a second peak occurs in February, just before breeding season.43 Incest is rare in prairie dog populations so older males also disperse after one or two years inhabiting a coterie, probably to avoid inbreeding with their daughters. Dispersals are more likely to occur within colonies than between or outside of them.44 45 Prairie dog colonies may also become stabilized to one area. Studies conducted outside of plague zones indicate that colonies can remain in the same approximate location for several decades to several centuries46 and prairie dogs show very little variation in burrow density over long periods. 47 In a fourteen year study of a 16 acre colony located on mixed grass prairie in South Dakota that was at least 35 years old, researchers mapped every burrow on the site and noted that although prairie dog densities would fluctuate up or down throughout the years, the physical area and number of burrows remained almost exactly the same.48 “In efforts to predict population dynamics, wildlife managers must evaluate whether colonies under consideration are old and stable or young and expanding. In stable colonies, showing little room for expansion, prairie dogs reproduce slowly. This is probably due to lower survivorship and increased competition for resources (food, suitable mates). Prairie dogs in younger, expanding colonies survive better, grow faster as juveniles, are more likely to mate at a younger age, and rear larger litters.” 49 Also, according to John Hoogland, “several studies have demonstrated that black-tailed prairie dogs survive better and have greater reproductive success following the reduction in colony size, for natural or unnatural reasons. Consequently, ‘thinning’ of prairie dog populations is often short-lived because populations can quickly rebound.”50 Recommendations: x Use FEMA maps as a guide for broad scale landscape planning for migration route corridors important for prairie dog dispersal and other wildlife species. x Designate corridors to be occupied and protected by prairie dogs. Some corridors may need to be sequestered from disease pathways. x Based upon the reproductive and dispersal patterns of prairie dogs, the best opportunity for management is late spring towards early November. x The best time to relocate prairie dogs is late summer into early winter. 42 Pizzimenti, J. J., and McClenaghan, L.R. 1974. Reproduction, growth and development, and behavior in the Mexican prairie dog. American Midland Naturalist 92:130-45. 43 Hoogland, J. 1995 44 Garrett, M.G., J.L. Hoogland, and W.L. Franklin. 1982. Demographic differences between an old and new colony of black- tailed prairie dogs (Cynomys ludovicianus). American Midland Naturalist 108-:51-59 45 Hoogland, J. (1995 and 2006). 46 Augustine, David J., Marc R. Matchette, Theodore P. Toombs, Jack F. Cully Jr., Tammi L. Johnson, and John G. Side. 2008. “Spatiotemporal Dynamics of Black-tailed Prairie Colonies Affected by Plague.” Landscape Ecol 23:255-267 47 Hoogland, J. et al. 1987. 48 Garrett, M.G., J.L. Hoogland, and W.L. Franklin. 1982. Demographic differences between an old and new colony of black- tailed prairie dogs (Cynomys ludovicianus). American Midland Naturalist 108-:51-59 49 Hoogland, J. 2006. 50 Hoogland, J. 2011. Personal communication, The Prairie Dog Coalition. 9 x Prairie dogs can remain in the exact same spot for decades if not centuries with very little change in burrow numbers. x Prairie dogs are not migratory; they disperse singly not in groups. x Short reproduction windows, low litter sizes, and longer periods before sexual maturity make prairie dogs an exception in the rodent world and lead to comparatively lower population growth rates than other rodent species. x Visual counting of prairie dogs is the best method for determining populations of prairie dogs because there is no absolute correlation between density and the number of burrows. 5. Disease Primary diseases of prairie dogs are sylvatic plague (Yersinia pestis) and tularemia. Sylvatic plague might pose the most formidable obstacle for long-term conservation of prairie dogs.51 Prairie dogs suffer an almost 100% mortality when exposed, and there is little evidence of their development of immune antibodies. Plague was introduced into the United States ground squirrel population in 1908. Since then, the disease has spread and can infect at least 76 species of rodents, rabbits, hares, shrews, ungulates and primates. Plague is primarily a disease of rodents and it affects each rodent species differently. Plague was first documented in black-tailed prairie dogs in 1946 in Texas. The disease has since infected most areas within the range of prairie dogs.52 Animal susceptibility to sylvatic plague varies. Some species are highly susceptible, for example the prairie dog, and others are more resistant (mice). Resistant species may play a role as reservoir hosts. Carnivores are commonly exposed to plague by eating infected rodents or by being bitten by rodent fleas, but many are resistant to plague. Studies demonstrate that infected domestic dogs, coyotes and foxes may indicate an antibody to plague, meaning they had been exposed, but rarely die from plague.53 For relatively small areas with plague-infected rodents, the use of insecticide dusting powder to kill fleas on rodents is effective. And since plague is in many other wildlife species, the elimination of prairie dogs will not remove plague from the ecosystem.54 Plague is largely controlled by the manual application of Delta-dust. According to D. Tripp, (2016) the best time of the year to apply Delta-dust is in the fall (September or October) or early spring (February or March). While plague can be present in fleas year round but most transmission occurs in early spring and late summer after temperatures drop. 55 A sylvatic plague vaccine (SPV) is indicating great promise in protecting prairie dogs from plague. Management of plague through SPV could prevent precipitous population declines that could lead to future ESA listing.56 A possible strategy to prevent large scale losses of prairie dogs to plague is the design of preserves. The risk of having preserve areas be too large is that a single plague epizootic could result in the demise of the entire preserve. Preserve 51 Cully, J.F., and E.S. Williams 2001. Interspecific comparisons of sylvatic plague in prairie dogs. Journal of Mammology 82:894- 905 52Luce, R. J. 2006 A Multi-state Approach to Prairie Dog Conservation and Management in the United States, Invited Paper, USDA Forest Service Proceedings RMRS-P-40.2006. 53 Biggens, D. E., M.Y. Kosoy. 2001. Influences of Introduced Plague in North American Mammals: Implications from Ecology of Plague in Asia, Journal of Mammalogy:82(4):906-916, 2001 54 www.cdphe.state.co.us 55 Tripp, D. (2016) Colorado Parks and Wildlife, personal comm. January 7, 2016. 56 http://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5426465.pdf 10 areas should be close enough to allow for animal dispersal between them, but not so close that plague epizootics can be easily transmitted.57 Another disease fatal to prairie dogs is tularemia.58 Tularemia, also known as rabbit fever, is a zoonosis affecting more than 150 wildlife species, including prairie dogs, squirrels, rabbits, cats, and humans. Transmission can occur from tick or deer fly bites, handling infected animals (sick or dead), eating undercooked meats of infected animals, and inhaling dusts or aerosols contaminated with the bacteria (farming and landscaping activities) of infected animals. Treatment involves antibiotic medications. Although symptoms may last for several weeks, most patients completely recover.59 Rodents and rabbits are almost never found to be infected with rabies and have not been known to transmit rabies to humans.60 And given the structure and ventilation system of burrows, hanta virus does not occur in prairie dogs.61 Recommendations: x Annual dusting of prairie dog colonies may be required until SPV is ready for regular use. x Plague management and abatement should occur in Natural Areas designated for prairie dog ecosystem conservation. As such, these areas should maintain occupancy by prairie digs via population augmentation or relocation if necessary. x Strategic land use planning to ensure that preserves are dispersed throughout land use areas rather than pooling all large colonies in one area. 6. Local government legal tools In Colorado, local governments have primary authority to protect wildlife habitats, but state wildlife officers have primary authority over the actual animal. It is very important that local governments understand this concept and utilize laws granted to them as part of a core foundation to protect wildlife habitats. Our research indicates that very few counties in Colorado have any conservation plan for prairie dogs and of those plans reviewed, none made reference to Colorado’s conservation strategies for prairie dogs. This disconnect is concerning, as local governments are granted primary authority to protect lands for wildlife under the state’s local land use laws.62 Far more municipalities than counties had conservation plans, yet of those counties that did have plans, none openly stated the importance of municipal, state, federal or private landowner participation in occupied prairie dog acreage. All of these external landowners and agencies play a huge role in county-wide occupied acres and are especially important to counties as they reduce associated prairie dog occupancy costs (land purchases, maintenance, revegetation, disease management and staffing) to county taxpayers. The fact that the majority of local governments have no conservation plan is a matter of statewide concern, as the state’s principal role to avoid federal listing is to ensure countywide occupancy of prairie dogs.63 64 57 EDAW 2000 Black-Tailed Prairie Dog Study of Eastern Colorado Study of Eastern Colorado, Retrieved 9/15 http://cpw.state.co.us/Documents/WildlifeSpecies/SpeciesOfConcern/BlackTailedPrairieDog/PDF/Entire_Report.pdf 58 Hoogland, J. 2006. 59 http://www.cdc.gov/tularemia 60 http://www.cdc.gov/rabies/exposure/animals/other.html 61 Pape, John. 2006. Colorado Department of Health and Environment. Personal Communication, P Wanek 62 Duerksen, C. J., Hobbs, N.T., Elliott, D. L., Johnson, E., and Miller, J.R. (n.d) Managing Development for People and Wildlife, A Handbook for Habitat Protection by Local Governments, Clarion Associates of Colorado, LLC and Colorado Division of Wildlife for The Great Outdoors Colorado Trust Fund. Retrieved from http://ndisdev2.nrel.colostate.edu/handbook/handbook.html 63 Luce, R.J. 2006. 64 Conservation Plan for Grassland Species in Colorado 2003 11 One of the conservation objectives of Colorado’s Grassland Plan is a shared responsibility to conserve occupied prairie dog habitat in both urban and rural communities.65 However, each of these environments presents entirely different financial and landowner situations. Development in Front Range counties and cities generates large sales taxes that in many cases includes open space taxes to protect lands from development for agricultural or wildlife habitat uses.However, these rapidly developing cities and counties do not normally plan to protect large acreages for prairie dogs; and many have no vision to protect any prairie dogs. As such, most urban prairie dogs live in unprotected isolated colonies that are rapidly disappearing. Most rural properties are privately owned, and these private holdings contain the bulk of prairie dog acreages in the state.66 Rural counties typically do not share in the economic wealth of their urban counterparts. They do not have open space taxes, nor do they have funding needed to hire resource managers educated in the importance of prairie dog conservation Some private landowners have received prairie dog conservation funding from the state, but the majority of private lands remain unprotected. Conservation plans are important for multiple reasons: x They set establish that prairie dog conservation is important to avoid ESA listing; x They educate politicians, staff and the community about the plight of the species; x They reduce management and maintenance of prairie dog habitat by locating habitats in areas more conducive to natural areas and natural dispersal routes; x They reduce costs to local governments and ultimately taxpayers by having coordinated and shared financial interests in federal, state, local and commercial funding to support prairie dog conservation and habitat protection; x They engender more decision-maker support for translocations of prairie dogs into designated areas; x They identify the legal procedural requirements and responsibilities for all parties involved; x They open the door for joint funding and management of prairie dog protected areas and the development of Inter-governmental agreements; x They create the shared responsibility of all political jurisdictions within the prairie dogs range; x They support region-wide diversity, thus protecting the prairie dog and dependent species by allowing for large scale land use conservation rather than pooling significant prairie dog populations into one area; x They increase efficiency of all resources (land and human); x They support both state and federal goals to conserve the species and protect associated and dependent species. x They promote voluntary conservation-incentive programs or regional conservation programs to prevent species from federal listing According to Duerkson, C. J., et al. the most powerful laws for local governments to protect habitats are known as 1034 and 1041 Powers. “In 1974, the state enacted the Local Government Land Use Control Enabling Act to ‘clarify and provide broad authority to local governments to plan and regulate the use of land within their respective jurisdictions.’ Those powers are codified at C.R.S. 29-20-101 and are sometimes known as 1034 powers. Two provisions under these powers are of particular importance when it comes to protecting wildlife habitat: ‘29-20-104. Powers of local governments. (1) Without limiting or superseding any power or authority presently exercised or previously granted, each local government within its respective jurisdiction has the authority to plan for and regulate the use of land by: 65 Ibid. 66 Colorado Grasslands Plan, 2003. 12 … (b) Protecting lands from activities which would cause immediate or foreseeable material danger to significant wildlife habitat or would endanger a wildlife species; … (h) Otherwise planning for and regulating the use of land so as to provide planned and orderly use of land and protection of the environment in a manner consistent with constitutional rights.’ This language should support the adoption of specialized city, town, or county regulations to protect wildlife habitat in ways that are not specifically prohibited or preempted by state statute. Colorado also enacted 1041 Powers that are found under C.R.S. 24-65.1-101 and grant local governments increased authority to adopt regulations controlling specific types of development and activity. The statute details large or broad effects on the surrounding area and then allows local governments to adopt specific criteria to regulate specific aspects of those development and activities. 1041 Powers address areas and activities of statewide interest. These interests include mineral resource areas, natural hazard areas, areas containing historical, natural or archaeological resources, areas around key facilities such as airports, interchanges involving arterial highways, major public facilities and mass transit terminals. This also includes efficient use of municipal and industrial water projects and site selection and construction of domestic water and sewage treatment and new communities. Under certain circumstances, local governments can designate areas or activities within their jurisdiction as matters of statewide concern.”67 Municipal growth is typically driven by some economic benefit to annex developable land. Potential annexations of lands from counties are submitted by local governments to affected counties through what are known as three-mile annexation plans. These plans provide counties the opportunities to render comments about the proposed annexations. In some cases, annexation “wars” may occur when more than one municipal government desires the same tract of land as another municipal government. These ‘wars’ potentially drive up the number of developments to offer the best financial deal for landowners wishing to sell their properties. Some may view these ‘wars’ as a major driver in over developed communities and the associated hindrance of local communities’ ability to protect habitats for wildlife. Additional information about three-mile annexation plans can be found under the Colorado Department of Local Affairs website: https://www.colorado.gov/pacific/dola/three-mile-plans In cases where municipalities annex lands, county government’s ability to effect conservation planning in annexed municipal lands may no longer be valid. According to C.R.S. 30-28-106: (1) “It is the duty of a county planning commission to make and adopt a master plan for the physical development of the unincorporated territory of the county… (2) (a)…but no such plan shall be effective within the boundaries of any incorporated municipality within the region unless such plan is adopted by the governing body of the municipality…” It is important to keep in mind that although many local governments have their own laws and regulations, they are not sovereign entities of the state, rather they are political subdivisions of the state, existing only for the convenient administration of the state government, created to carry out the will of the state.68 Recommendations: x Connect local policies with statewide goals. x Utilize laws under the local land use act as the key authoritative powers to protect local wildlife habitats. 67 Duerksen, C. J., Hobbs, N.T., Elliott, D. L., Johnson, E., and Miller, J.R. (n.d) 68 C.R.S 30-11-101 Powers of Counties case law. http://www.lexisnexis.com/hottopics/Colorado 13 x Keep Natural Areas designated as prairie dog areas occupied by prairie dogs. 7. Non-lethal Control – Non-lethal control of prairie dogs is definitely a safer alternative to lethal control, and in recent years many conservation groups are directing funds from lethal control methods towards non-lethal control choices. One method of non-lethal control is active relocation. While BTPD’s can be removed any time of the year, there are clearly better times than others. For example, birthing, inclement weather and torpor make relocations much more complicated. Generally, prairie dogs can be moved from about June 1st through the end of December. However, the best time to relocate prairie dogs is from September through about November 30th; relocations really should not start later than October. A Wild-to-Wild Relocation permit is secured between CPW and the local governing body. All take sites are required to be treated with delta-methrin (Delta-dust) at least one week prior to capturing the prairie dogs, as a sylvatic plague abatement measure. Active relocations may involve coterie mapping so family members are moved together, assessment of natural releasable burrows, installation of artificial burrows, pre-baiting take sites to trap animals and soapy water flushing if necessary. Additionally, there may be transport guidelines, acclimation and monitoring post released prairie dogs, and finally, reports submitted to CPW. Other methods of non-lethal control include more habitat-based methods. While these methods may not be as immediate as lethal control, non-lethal methods may over time produce better results. Some habitat methodologies include vegetation management such as delayed livestock grazing (cattle, goats and sheep); rotation of livestock tanks, deferred prescribed burns, changes in the type of agriculture crops and timing of harvest, introduction of tall, drought tolerant woodies (tall rabbitbrush, western sage, sumac, etc…). In very large areas, allowing mid-height grasses to grow between prairie dog colonies and urban developments may be a feasible alternative to dissuade prairie dogs from moving onto unwanted areas. However, homeowners may be concerned about potential grass fires next to their communities and so defensible space should be incorporated into these designs. A 200 to 300 foot buffer of mixed-height grasses next to colonies may discourage prairie dogs from moving or expanding into unwanted areas, a defensible space fire buffer may also be needed. Defensible space should include roads next to houses as well. Larimer County recommends the following defensible space for urban-wildland interface: Table 602. Required Defensible Space69 Urban-Wildland Interface Area Fuel Modification Distance (feet) Moderate hazard 30 High hazard 100 Extreme 200 Hardscaping may also discourage undesired animal occupancy. Consider using large cobble, pavers or landscaping stones. Fences such as electric, vinyl, privacy and PVC can be very effective, although some may need modifications. Even irrigation creates undesirable habitat for some wildlife. Another method of passive relocation is called Reverse Dispersal Translocation™ or RDT. The procedure works by successively closing down unoccupied burrows thus allowing the animal to move itself out of contentious areas into more hospitable habitat (where prairie dogs already exist). This method requires receiving burrows. What it does is 69 Farmer, David A. 1997. Colorado State Forest Service, Recommendations for Improving Wildfire Safety in Larimer County, p. 27. Retrieved 4/2016 https://www.larimer.org/wildfire/recommendations.pdf 14 push back colony expansion. Over time, prairie dog coteries can change in shape and size (smaller to larger and larger to smaller and extinct). Also, prairie dogs will frequently block their own burrows to protect natal nests, block off cold air, protect against predators and possibly to shift coterie boundaries. RDT progressively and sequentially blocks off burrows allowing the prairie dog to decide for themselves what coteries they belong in. Example: The represents four burrows that are moving out of the core colony. RDT progressively begins to block off these burrows causing prairie dogs to move back into the origination colony. This method is used instead of trapping and arbitrarily placing trapped prairie dogs into a colony. Using RDT, prairie dogs will hook up with old coterie members or move into less contentious burrows within the colony. Prairie dogs are much better at figuring out the social complexities of the coteries than humans. Before land managers decide to use any methods to eliminate prairie dogs they should carefully evaluate cost versus benefits. They should also carefully evaluate the negative effects for other species that depend on prairie dogs for survival.70 Recommendations: x Utilize non-lethal methodologies over lethal control first. Non-lethal control methods keep chemicals out of the environment and may help reduce prairie dog management costs over the long-term. x Generally, prairie dogs can be moved from about June 1st through the end of December. However, the best time to relocate prairie dogs is probably from September through about November 30th; relocations really should not start later than October. x Non-lethal methods may not be as immediate as lethal control; however, over time, habitat based methodologies may produce better long-term results. x Hardscaping may also discourage undesired animal occupancy. x Manipulation of vegetation such as introducing shrubs and mid-height grasses can help control prairie dog occupancy into unwanted areas. 8. Lethal Control Lethal control has long been used to exterminate prairie dogs. From about 1903 to 1912, poisoning killed 91% of Colorado’s prairie dogs (Black-tailed, Gunnison’s and White-tailed) and over the next 11 years, poisoning killed another 31 million prairie dogs in Colorado. The idea behind these exterminations was complete eradication of prairie dogs.71 70 Hoogland, J. 2006. 71 Hoogland, J. 2006. Pg 90. Origination Colony Burrows that are beginning to expand territory. 15 By 1915, the U.S. Federal Government began to assist landowners in control efforts. Control activities continue today on agricultural, urban and city lands.72 From the early 1900s through the late 1960s extensive eradication of prairie dogs by landowners and state and federal agencies was largely funded with federal money.73 Probably the biggest driver of exterminations was the perceived notion that prairie dogs are a major competitor of cattle for food; contemporary research indicates that prairie dogs can have a beneficial or neutral effect on livestock forage. According to Collins, et al., forage competition between black-tailed prairie dogs and livestock grazing on shortgrass rangeland dominated by blue grama and buffalograss was not significant enough to warrant control measures. They reasoned that higher forage quality compensated for reduced available forage. Their results indicated that due to prairie dog repopulation rates, prairie dogs would have to be re-poisoned every 3 years and that annual maintenance control costs would be greater than the annual value of AUMs (animal unit month) gained. Thus, prairie dog control was not economically feasible.74 According to the Colorado Department of Regulatory Agencies 2014 Pesticide Sunset Act, all individuals and businesses that apply restricted use pesticides are regulated by the Pesticide Applicator’s Act (Act) and only individuals and businesses who apply general use pesticides as a commercial endeavor are regulated by the Act. The Commissioner regulates Commercial, Limited Commercial, Public, and Private pesticide applicators. The level of regulation is dependent on multiple factors including the type of pesticide being applied and the physical and economic environments in which it is applied.75 Regulations are necessary because pesticides used to control insects, rodents, weeds, and other forms of life contain toxic substances which may pose a serious risk to public health and safety. The regulation of pesticide applicators is necessary to prevent adverse effects to both individuals and the environment. Because pesticides contain toxic substances that can endanger the public, it is necessary to regulate the individuals that apply pesticides commercially.76 Integrated Pest Management (IPM) strategies should always look at alternatives that utilize non-chemical approaches first and only consider using pesticides as a last resort. Since FIFRA does not fully preempt state, tribal or local law, each state, tribal and local government may also regulate pesticide use; as long as the local authority does not attempt to, directly or indirectly, regulate or prohibit pesticide application by individuals regulated under the Act or federal law. And while state regulations prevent local jurisdictions from enacting and implementing greater notification requirements on regulated applicators, local jurisdictions retain the authority to impose any notification requirements upon private individuals, property owners, and the general public concerning pesticide applications.77 78 In this case, a local government cannot prohibit pesticide use, but they can place restrictions to seek non-lethal control alternatives first before permitting lethal control. While federal and state governments regulate toxicant use, it is the role of the consumer that either directly applies toxicants or hires companies that exterminate to determine whether or not toxicants are necessary. Some questions to ask: x What measures of exclusion have been tried first? Barriers, vegetative buffers, reduced grazing? x Has extermination occurred in the past? If so, what were the long-term and short-term results? 72 Conservation Plan for Grassland Species in Colorado. 2003. 73 Luce, B. 2006. 74 Collins, A. R., Workman, J.P., Uresk, D.W. l984 An Economic Analysis of Black-tailed Prairie Dog [Cynomys Ludovicianus] Control Journal of Range Management 37(4), July 1984 75 Colorado Department of Regulatory Affairs (DORA). 2014. 2014 Sunset Review Pesticide Applicators Act, Office of Policy, Research and Regulatory Reform 76 Ibid. 77 Ibid. 78 C.R.S. 30-10-112-3 16 x What non-target wildlife species could be impacted? x How does this chemical control the target species? Is this considered euthanasia? x What type of notifications does the state require on the property and what do those look like? x Exactly where will the notifications be posted? x Is the property fenced or is it an open field? x How close is the property to schools, open space areas, parks or other areas that may have high human interaction? x What additional notification can be provided to avoid accidental exposure? x Will the on-site applicator be an agent with necessary and relevant information for questioning citizens regarding the process or chemicals used? x Will minor children be employed as laborers? x What additional measures will be used to keep people and pets off of the property during and after toxicant uses? x Does the local government have an IPM program and are there any requirements to seek non- lethal alternatives? Products used, toxicity and humaneness: This section reviews the most commonly used methods for lethal control: aluminum phosphide, zinc phosphide, Kaput and Rozol, carbon monoxide cartridges, carbon dioxide, igniting underground explosive gas, and live burial by construction equipment. Carbon Dioxide (CO2) – is commonly used to kill prairie dogs, which are then used as donations to wildlife recovery centers for black-footed ferrets and birds of prey. In both cases there is specific timing, storage and procedures that must be followed by each facility. In most cases, prairie dogs will be lethally controlled by capturing the animal and then placing them into carbon dioxide filled chambers. Hawkins, et al. (2006) states that although many laboratory animals, especially rodents, are killed using CO2 according to a variety of protocols, there is currently no definitive guidance on whether and how CO2 can be administered humanely. There is also uncertainty about the feasibility of using alternative gaseous euthanasia agents, with respect to both animal welfare and human health safety. 79 Conlee, K.M, et al. (2005) indicated that the use of carbon dioxide alone did not follow the guidelines of euthanasia as the animals were clearly distressed and recommend that the use of CO2 should only be considered if it were used with a pre-anesthetic.80 Only competent and caring individuals should administer CO2. They should make absolutely sure the animal is dead prior to removing it from the chambers, as individual rodents may become apneic (temporary suspension of breathing) at certain CO2 concentrations giving the false impression that death has occurred. Standard tests used to determine death include a toe pinch, dilated pupil (lack of response to touch on eye), and absence of heartbeat; cessation of breathing is not a sufficient criterion when CO2 is used. Therefore, to ensure death, decapitation should follow after the use of CO2 to be assured that the animal does not revive. Younger animals, such as neonates, are more resistant to CO2 and may require longer exposure for efficacy.81 79 Hawkins, P., L. Playle, H. Golledge, M. Leach, R. Banzett, P. Danneman, P. Flecknell, R. Kirkden, L. Niel and M. Raj. 2006. Newcastle Consensus Meeting on Carbon Dioxide Euthanasia of Laboratory Animals, University of Newcastle upon Tyne, UK 9 August 2006 80 Conlee K. M., Stephens, M.L., Rowan, A.N., and King, L. A. (2005) Carbon dioxide for euthanasia: concerns regarding pain and distress, with special reference to mice and rats The Humane Society of the United States, Animal Research Issues, 2100 L Street NW, Washington, DC 20037, USA; Linacre College, Oxford University, St Cross Road, Oxford OX1 3PS, UK, Laboratory Animals (2005) 81 Gannon, W.L., Sikes, R.S. 2007. And The Animal Care and Use Committee of the American Society of Mammalgists. Guidelines 17 Also, because animals may become distressed due to physical discomfort, anxiety in atypical social settings and physical surroundings, pheromones or odors from nearby or previously euthanized animals, and the presence of humans, euthanasia should be done outside of the perceptive range of other captive animals. CO2 is widely used in laboratories and in the field because most inhaled agents are explosive, for example, carbon monoxide, when discharged into an enclosed chamber .82 While CO2 may be less of a safety hazard to workers, it is not necessarily the most humane choice because it is not a euthanasia. Carbon Monoxide (CO) – are nonrestrictive use cartridge fumigants that are lit and then placed down inside prairie dog burrows. Since carbon monoxide induces unconsciousness before death, it is considered as a euthanasia.83 However, because smoke and heat emits dirty particles that are inhaled into the lungs and nasal passages it is questionable whether this is truly a humane method for the death of animals. Some local governments have accepted CO as a primary agent for field euthanasia of prairie dogs and are using PERC™ (Pressurized Exhaust Rodent Controller) machines that deliver pressurized carbon monoxide down prairie dog burrows. While we do not endorse the death of any declining species, we are encouraged that some communities have accepted that prairie dogs feel pain too and that euthanasia and care during the death of any species is a better approach than inhumane killing. Aluminum Phosphide – is a restricted use fumigant registered for burrowing mammal control in the U.S. in 1981. Aluminum phosphide reacts with moisture in burrows to release phosphine gas. The gas is absorbed through the respiratory passages of burrow residents and enters the bloodstream to block physiological processes in cells and alter hemoglobin. Aluminum phosphide is a potent mammal toxicant. At a concentration of 1000 ppm, phosphine gas is lethal to humans after just a few breaths. Primary non-target poisoning involves the exposure of non-target animals in burrows of target species. It is generally assumed that burrow fumigants will kill all animals residing in treated burrows, so it is important to verify that burrows are occupied only by target animals. Animals potentially affected by primary poisoning include non-target burrowing rodents, burrowing owls, reptiles and amphibians, rabbits, raccoons, foxes, weasels, and skunks. No secondary hazards exist with burrow fumigants because the gases rapidly dissipate. Bio-accumulation does not occur in dead animals.84 In poisoned rodents, phosphine gas gives rise to similar signs of respiratory irritation and pain and other forms of discomfort; displaying face-washing movements suggestive of eye and respiratory irritation, shivering, piloerection, clinging to the walls of the cage, protruding eyeballs, convulsions, and hind limb paralysis followed by full paralysis and death. In laboratory settings, animals may not start being symptomatic until 30 min after exposure, and die usually within 2 h; the range being 50 min to 3 h, depending on dose.85 However, in the field, the time between exposure and death is not well studied. Death by aluminum phosphide is not considered as euthanasia.86 87 Trade names for aluminum phosphide products include Phostoxin, Fumitoxin, PH3, and Weevil-cide. Use is prohibited on residential properties and nursing homes, schools (except athletic fields), daycare facilities and hospitals. It must of The American Society of Mammalogist For The Use of Wild Mammals in Research. Journal of Mammalogy, 88(3): 809– 823. 82 AVMA Guidelines for the Euthanasia of Animals: 2013 Edition Copyright © 2013 by the American Veterinary Medical Association, 1931 N. Meacham Road, Schaumburg, IL 60173 83 Ibid 84 K.A. Fagerstone, K.A. and Witmer, G.W., Eds. 2003 THE USE OF TOXICANTS IN BLACK-TAILED PRAIRIE DOG MANAGEMENT: AN OVERVIEW Proceedings of the 10th Wildlife Damage Management Conference. 85 Mason, G. and Littin, K.E. 2003. THE HUMANENESS OF RODENT PEST CONTROL, Animal Welfare 2003, 12:000-000 86 Ibid. 87 AVMA 2013 18 not be applied into a burrow system within 100 feet of a building that is, or may be, occupied by humans, and/or domestic animals.88 Aluminum phosphide can be used for prairie dog control only on agricultural areas, orchards, non-crop areas (such as pasture and rangeland), golf courses, athletic fields, airports, cemeteries, rights-of-way, earthen dams, parks and recreational areas and other non-residential institutional or industrial sites. Pellets or tablets must be applied directly to underground burrow systems and the burrows must be sealed with newspaper or soil. Prior to treatment, the applicator must prepare and provide a fumigation management plan (FMP) to the customer. Applicators must post a sign at each application site containing the signal word DANGER/PELIGRO skull and crossbones, the name and EPA registration number of the fumigant, and a 24 hour emergency response number. When used in athletic fields or parks, the signs must be posted at the entrances to the treated site and can be removed within 48 hours of initial treatment.89 Even though the state and EPA have now taken some precautions to avoid unintentional exposure to people or pets with these products, it is difficult to ascertain how chemicals work in the field as opposed to laboratory settings. According to Snider, C. several factors that influence this product are: burrow temperatures, burrow humidity, burrow length and configuration, soil porosity, wind speed and direction, and species specific behavior characteristics.90 Prairie dog burrows probably have temperatures of 5 – 10 C in winter (41F – 50F), and 15 – 25 C (59F – 77F) in summer.91 According to the Fumitoxin instruction manual, phosphide gas exposure periods vary with temperatures. Not only may phosphine gas remain lethal for longer than the 2 day EPA sign warning sign minimums but it may remain toxic for up to 10 days. While we do not support any application of phosphine gas, we also believe that the minimum 2 day warning signs are inadequate, particularly on properties that are not necessarily parks but open space areas where people may hunt, hike or exercise their pets. And while local governments cannot require additional posting and warning requirements on a hired exterminator, they could require additional restrictions on the landowner; for example, larger signs and longer posting periods. Excerpt from the Fumitoxin Manual Operator Instructions (06/2013)92, below: “EXPOSURE CONDITIONS FOR ALL FUMIGATIONS: The following table may be used as a guide in determining the minimum length of the exposure period at the indicated temperatures: Minimum Exposure Periods for FUMITOXIN Temperature Pellets Tablets 40°F (5°C) Do not fumigate Do not fumigate 41°-53°F (5-12°C 8 days (192 hours) 10 days (240 hours) 54°-59°F (12-15°C) 4 days (96 hours) 5 days (120 hours) 60°-68°F (16-20°C) 3 days (72 hours) 4 days (96 hours) above 68°F (20°C) 2 days (48 hours) 3 days (72 hours)” 88 Andelt W.F., and Hopper S.N. 2012 Managing Prairie dogs, Colorado State University Fact Sheet No. 6.506, Colorado State University Extension Office 89 Ibid. 90 Snider, Carl, "Use of Aluminum Phosphide Fumigants For Burrowing Rodent Control" 1983. Great Plains Wildlife Damage Control Workshop Proceedings. Paper 292. http://digitalcommons.unl.edu/gpwdcwp/292 91 Hoogland, J. 1995. 92 Fumitoxin Applicators Manual. 2013. http://www.pestgon.com/PDF/MSDS- Labels/fumitoxin%20Label%202013.pdf 19 Zinc Phosphide – is the most commonly used rodenticide worldwide and it acts by producing phosphine gas in the stomach.93 It was introduced into the U.S. during World War II when other imported rodenticides were unavailable. It is an acute (single feeding) rodenticide usually formulated into a pelleted bait or used as a coating on grain. The gas is absorbed through the respiratory passages and enters the bloodstream to block physiological processes in cells and alter hemoglobin. Zinc phosphide is highly toxic to both mammals and some birds. Non-target hazards include the direct consumption of zinc phosphide baits (primary hazard) or indirect exposure by the consumption of animals that have consumed the zinc phosphide bait (secondary hazard). Deaths can conceivably occur if predators consume undigested grain in rodent cheek pouches or gastro-intestinal tracts.94 To reduce exposure to non-target species, dead carcasses should be buried or removed from applicator sites. Zinc phosphide can only be used for prairie dogs on rangeland, rangeland and pasture, or rangeland and adjacent non- crop areas (depending on the specific product label). Zinc phosphide application is restricted to July 1 through early winter.95 Unlike fumigants, zinc phosphide exposes only those species that are in direct consumption of the bait, either from the ground or the consumption of another species that has recently consumed the baits. Additionally, dependent young in their nests that do not consume baits will be left to die. Zinc phoshide is not euthanasia. 96 97 Kaput and Rozol - are anticoagulant baits Chlorophacinone (Rozol Prairie Dog Bait) or Diphacinone (Kaput-D Prairie Dog Bait). Both Rozol and Kaput-D Prairie Dog Baits are federally restricted use pesticides. They can be used only for control of black-tailed prairie dogs on rangeland and adjacent non-crop areas. This species is found on the eastern plains of Colorado. It cannot be used on the species found west of the front range of Colorado, Gunnison’s prairie dogs or white-tailed prairie dogs.98 There are now enforceable endangered species bulletins for anticoagulant prairie dog baits for several Colorado counties. You must check the EPA website to obtain any county bulletins no less than 6 months before applications are to occur. Product can only be applied between October 1 and March 15 of the following year. (In some counties, product cannot be applied until November 1, see endangered species protection bulletins for your county). The applicator must return to the site within 4 days after bait application, and at 1 to 2 day intervals, to collect and properly dispose of any bait or dead or dying prairie dogs found on the surface. Any dead or dying non-target species of animals must be reported as described on the product label. Continue to conduct these searches for at least 2 weeks, but longer if carcasses are still being found. Carcass searches must be performed using a line-transect method that completely covers the baited area. Transect center lines must be 200 feet or less apart (less in more densely vegetated sites). 99 The purported advantage of using Kaput and Rozal is that these products do not require pre-baiting, thus reducing labor and field personnel costs. The disadvantage is that personnel or private property owners are required to monitor and dispose of any carcasses and this increases field time. According to Vyas (2013), applicators have openly admitted that they are not following label guidelines to Fish and Wildlife Service personnel. Applicators feel it is too costly and difficult to recover carcasses. Since these products are mostly used on private lands, it is difficult to completely assess how many non-target species have died from the consumption of carcasses. In one study, non-target mortalities included the deaths of two bald eagles, one ferruginous hawk, one great horned owl, two wild turkeys, one western meadowlark, two thirteen-lined ground squirrels and two American badgers. And while this list seems small, Vyas believes that these mortalities represent the “tip of the iceberg.” Vyas, and many in the conservation community, 93 Mason, G. and Littin, K.E. 2003 94 Fagerstone, K.A. and Witmer, G.W., 2003 95 Andelt W.F., and Hopper S.N. 2012 96 Mason, G. and Littin, K.E. 2003 97 AVMA 2013 98 Andelt W.F., and Hopper S.N. 2012 99 Ibid 20 question how the EPA and FIFRA can continue to allow the use of the product, especially when applicators have openly admitted they do not follow the product label instructions that is the letter of the law for all pesticides approved by the EPA.100 During the 2006 EPA registration review for Rozol and Kaput, the Colorado Department of Agriculture (CDA) received written documents by both the Colorado Division of Wildlife and the USFWS that these products should not be approved for registration for the following reasons: significant data gaps in toxicity data to non-target wildlife species including the sub-lethal exposure effects on survival and reproduction; unconvinced that poisoned animals would remain underground posing primary and secondary poisoning risks to non-target species; searching, collection and disposal of carcasses will not be conducted; reporting requirements of non-target kills by the applicator and the threat of continued use of the product and therefore compliance will be minimal; and based on the potential risks to extensive mammalian and avian predators and scavengers, including state and federally listed species, there is a lack of demonstrated need for these specific compounds.101 Despite these concerns, the EPA approved registration of these products and the CDA approved them for use in the state. Underground ignited explosive gasses and live burial – in lieu of exterminations or donations to animal recovery programs, many developers and ranchers resort to other inhumane methods to kill prairie dogs; namely the use of explosive underground devices or bulldozing prairie dogs directly into the ground thereby suffocating them to death. Both practices are not considered as euthanasia.102 The most notable device used to explode burrows and prairie dogs is the Rodenator™ which pumps a mixture of propane and oxygen into an animal tunnel and then is lit to create an underground explosion. The explosion travels at about 5000 feet per second and creates a concussion of about 10,000 PSI in the tunnels. In conversations with Rodenator™ sales staff, some of the drawbacks of the device are that it is difficult to measure the concentration of propane and oxygen in the tunnel so “you must use a common sense approach.” Also, the device was never meant for use on prairie dogs because their tunnels are too difficult to collapse, additionally, there is no guarantee that the explosion kills prairie dogs and some may just become maimed.103 Yet, the device is readily advertised to eliminate prairie dogs and collapse tunnels but there are no scientific studies that back this claim. Despite these inadequacies, the CDA approved this product for use in Colorado. The Rodenator may also be a fire hazard; therefore, it may be prudent to contact local fire departments regarding its’ usage. In Canada, men using the device to kill gophers did not realize the device was capable of starting a blaze, they said they read the manual and watched the instructional DVD before using the device. According to sources, “the blaze spread rapidly through tinder-dry prairie grass.” Several residents fled their homes, though fire crews managed to stop the flames from damaging houses. Damage has been estimated at $215,000 to barns, sheds and vehicles, while another $40,000 was spent to fight the fire (The Edmonton Journal, March 28, 2008). Recommendations: x Adopt ordinances and policies that reduce the use of toxicants on public and private lands x Adopt a notification system wherein the use of toxicants is a choice of last resort and provide a reasonable notification period prior to toxicant use. x Support private landowners that want to conserve prairie dogs or are willing to pay into mitigation funding programs for lost occupied habitat 100 Vyas, B. Nimish,2013 Untested Pesticide Mitigation Requirements: Ecological, Agricultural, and Legal Implications. Drake Journal of Agricultural Law, Volume 18, No. 2, Summer 2013 101 Colorado Division of Wildlife (2006) Response to Laura Quakenbush, Colorado Department of Agriculture, Subject: 24C Request to review ROZOL Prairie dog Bait (EPA Reg. No 7173-184), and Kaput-D Prairie Dog Bait (EPA reg. No. 72500-9). 102 AVMA. 2013. 103 Wanek, P. 2010 Personal Communication with Rodenator Sales Representative 21 x Consider whether the chosen method is truly a humane decision x Local government cannot prohibit pesticide use but they can place restrictions to seek non-lethal control alternatives first before permitting lethal control. x And while local governments cannot require additional posting and warning requirements on a hired exterminator, they could require additional restrictions on the landowner; for example, larger signs and longer posting periods. x In many cases, aluminum phosphide is not a choice if prairie dog are located within 100 feet of a building that is, or may be, occupied by humans, and/or domestic animals. x While we do not endorse the intentional extermination of any declining species, we are encouraged that some communities have accepted that prairie dogs feel pain too and that euthanasia and care during the death of any animal is a better approach than inhumane killing. 9. Mitigation – CCAA, Endowment Fees, Separation of Fees from General Fund Unlike mitigation plans for wetlands, mitigation for prairie dogs is still in its infancy. Local communities are hard pressed to charge mitigation fees to private landowners for fear that this may encourage more exterminations of prairie dogs; however, along the Front Range, prairie dogs are routinely killed for development and developers often pay no mitigation. Not only are these practices inhumane, they also preclude economic opportunity costs to fund mitigation plans that are desperately needed to protect or replace local prairie dog populations. Many developers would readily pay mitigation fees for prairie dogs located on their properties if it moves the construction project along. Some urban developments are too small to support prairie dogs, and, as a result, surviving prairie dogs are pushed into adjacent properties, roadways, medians or killed on site. However, in some cases larger developments can incorporate small prairie dog populations. Each site should be evaluated for its own merits regarding BTPD mitigation or protection. Since local governments receive a tax benefit for developed properties to begin with, it may seem obvious that local governments should also play a role in supplying lands for displaced prairie dogs. Good mitigation plans by local governments can help offset habitat and local species losses. Some local governments already charge mitigation fees for prairie dogs. In some cases the monies are returned to the private landowner if more humane lethal control measures are taken, and in others, monies are collected regardless of what the developer does with the animals. Monies collected are generally used to operate prairie dog mitigation plans. The funds collected should be kept separate from the city’s general fund. Local governments should set goals for their prairie dog mitigation funds. Some of those goals may include the same broad language used in Candidate Conservation Agreements with Assurances (CCAAs), such as below: “• protecting and enhancing existing populations and habitats; • restoring degraded habitat; • creating new habitat; • augmenting existing populations; • restoring historic populations; and • not undertaking a specific, potentially impacting/damaging activity.”104 104 U.S. Fish & Wildlife Service Candidate Conservation Agreement. 2011. https://www.fws.gov/endangered/esa- 22 To implement mitigation programs, local governments must be very clear on how the money is used and adopt court- defensible language that can be codified into ordinances. Recall 1034 Powers and that local government authority is based on habitat protection, not the animal itself; therefore, local governments must be able to quantify the value of prairie dog colonies. The Prairie Dog Coalition is cooperatively working with other agencies, including CPW to develop a mitigation tool that is very similar to the one already used for mule deer and sage grouse. However, the tool is still in the development and testing phase. In the interim, it may be possible for local governments to use the best science available now to begin a mitigation program. Most simply, attempts to quantify the value of prairie dog habitat are based upon the value of each burrow. First, costs associated with prairie dogs must be established. Take translocation fees as an example. Translocation fees are those costs to replace occupied habitat. Fees can vary from site to site, but the general range to translocate prairie dogs is anywhere between $50 to $200 per prairie dog. In some cases prairie dogs are much more costly to move and in others much less. In this case, let’s assume that on average it costs about $125 per prairie dog. Based upon the best available science, during birthing months, from April through the end of June, prairie dog populations can double in size counting juveniles. However, as the season progresses, this population can drop by half. These population trends offer local government some choices on addressing timing of development. If a developer wants prairie dogs removed or exterminated in the earlier part of the spring or summer when populations are higher, they will be charged more because obviously the burrow is worth more. If they wait until later in the season, they will be charged less. Next, is to determine, on average, the number of burrows utilized by prairie dogs. Using the Johnson, W.C., and S.K. Collinge, 2004 study, they sampled 36 colonies during the months of June-August in 2000, and 40 colonies during September - January in 2001, in Boulder, Colorado. They found on average 255 active* burrow entrances per hectare or 103 per acre, and the average number of prairie dogs was 68 per hectare or 28 prairie dogs per acre. This equates to about 4 active burrows per prairie dog. At $125 per translocation cost per prairie dog, this means that each active burrow is worth about $31 ($125/4). Or on average, 103 burrows x $31 = $3,193 per acre. *active burrow entrances are those with fresh scat and does not include all burrows As referred to earlier, if counts were done in early May to early June specifically, the populations may have almost doubled because of pups, this means the fee could be up to $6,400 per acre. The City may want to negotiate this fee. For example, if the developer is willing to pay for translocation costs to City open space, which is a benefit to the City because taxpayers to do not pay relocations costs, you may want to waive the fee but instead charge fees for use of the land, say $1000 per acre. If they want to donate to ferrets or birds of prey, which is a more humane death than aluminum phosphide, you may give them a credit for this, especially because this alternative is much more costly to the developer than aluminum phosphide. Other studies support these numbers and provide a solid foundation for this mitigation tool and support a mitigation fee based on burrows or habitat lost. Finally, a science team made up of non-governmental organizations, scientists and agencies have worked together to develop a Habitat Quantification Tool (Tool) that quantifies the value of black-tailed prairie dog habitat. This Tool will be used to create mitigation transactions similar to the Colorado Habitat Exchange, currently, the Tool is available to library/pdf/CCAs.pdf 23 use on one off pilot transactions as prairie dog ecosystem conservation creditors have been identified to be purchased by prairie dog ecosystem debtors.105 Recommendation: x Engage private landowners and landowner actions as critical to prairie dog conservation, both from an environmental and financial standpoint. x Charge mitigation fees for loss of prairie dogs and for the use of city lands for prairie dog relocation x Realize that private landowners can mitigate costs to the city by re-augmenting previously plagued prairie dog colonies on municipal open space, reducing the cost to the city staff and taxpayers to retain “occupied acres.” x Understand that all landowners within counties contribute to “occupied acres” this includes city, state, federal and private landowners. x Require prairie dog ecosystem debtors to mitigate the ecosystem debits they create by contacting the Prairie Dog Coalition to be a part of a pilot mitigation transaction with the HQT Science Team. 10. Conclusion Finally, we would like to thank your staff and the City of Fort Collins for its desire to incorporate the best land use practices for your colonies. Overall we would like to see the following: 1. Decrease defensible space around prairie dog buffer zones and incorporate mid-height grasses as a buffer against the colonies. The City currently uses a 300’ cleared vegetative buffer; per Larimer County fire recommendations in the urban/wildland interface the maximum distance is 200 feet. 2. Adopt a mitigation system based on habitat and what it costs to replace occupied habitat; this should be applicable to private landowners and require or recommend participation in the conservation transactions for black-tailed prairie dogs as described in section 9, page 22. 3. Use FEMA maps to help create broad scale landscape planning for prairie dog metapopulations to protect dispersal corridors. 4. Remove the 50 acre minimum as a measure of prairie dog value; all occupied acres are important. 5. Update plans that incorporate statewide objectives. 6. Utilize habitat protection laws under 1034 and 1041 Powers. 7. Experiment with forb-based planting into active prairie dog colonies. 8. Reconsider “thinning” prairie dog populations and extermination as maintenance tools. Instead use habitat- based alternatives and non-lethal control strategies. 9. Add regulations about permitting for lethal control. According to the Pesticide Applicators Sunshine Act, alternatives should always be considered first before the use of pesticides. 10. Keep prairie dog conservation areas occupied by prairie dogs. 11. Remain flexible and open to new ideas and strategies. 105 Sterling-Krank, L. 2016. Personal Communication 24 1 Rebecca Everette From: Rebecca Everette Sent: Tuesday, July 26, 2016 1:23 PM To: 'lori_nitzel@yahoo.com' Subject: FW: New Wildlife Management Comment Hello,  WereceivedthecommentbelowontheWildlifeManagementGuidelinesandLandUseCodechangesrelatedtoprairie dogmanagement.Yourfeedbackisveryhelpfultothisprocess,soIappreciateyoutakingthetimetoshareyour thoughts.Iwantedtofollowupwithoneclarificationinresponsetothecommentsbelow.Currently,theLandUseCode requiresdeveloperstoremoveoreradicateprairiedogsfromadevelopmentsitepriortoanyconstructionactivity.The CitydoesnotpermitdeveloperstodigordisturbprairiedogcoloniesuntiltheCityhasreceivedconfirmationthatall prairiedogshavebeenremovedoreradicated.  ThisrequirementcanbefoundinSection3.4.1(N)(6)oftheFortCollinsLandUseCode (https://www.municode.com/library/co/fort_collins/codes/land_use): “Prairie Dog Removal. Before the commencement of grading or other construction on the development site, any prairie dogs inhabiting portions of the site within the LOD shall be relocated or eradicated by the developer using city-approved methods as set forth in Chapter 4 of the City Code and, when applicable, using methods reviewed and approved by the Colorado Division of Wildlife.”  ThechangestotheLandUseCodethatarecurrentlyproposedincluderequiringmitigation(compensation)fortheloss ofprairiedogsonadevelopmentsiteandlimitingthetypeoffumigantsthatareallowedtobeused.Additional informationcanbefoundhere:http://www.fcgov.com/naturalareas/pdf/wmgͲsummary.pdf.  Thankyouagainforyourinput.Ifyouhaveanyadditionalquestionsorcomments,pleasedon’thesitatetocontactme byemailorphone.  Sincerely,  Rebecca Everette Senior Environmental Planner Planning Services | City of Fort Collins reverette@fcgov.com | 970.416.2625 direct  Begin forwarded message: From: SurveyGizmo <notifications@surveygizmo.com> Date: July 25, 2016 at 2:30:20 PM MDT To: Zoe <zshark@fcgov.com> Subject: New Wildlife Management Comment PAGE 1 QUESTIONS: 2 PAGE 2 QUESTIONS: 1. Please share your thoughts on the proposed Natural Areas Wildlife Management Guidelines. I wholeheartedly support protecting prairie dogs in the city and requiring all developers to relocate prairie dogs. If relocation is not possible, humanely euthanizing colonies is the only acceptable way for developers to move forward with construction. At this point they are just digging right into colonies, which results in much suffering for these sentient beings. 2. Please share your thoughts on the proposed Land Use Code changes. See above. I will also note that I find the city's lack of prairie dog protections to be very much at odds with what I see throughout town - e.g., the museum encourages protection and prairie dogs are painted on city property. It's hypocritical. 3. Any other comments? 4. Are you a Larimer County resident? Yes 5. How did you hear about this project? City email newsletter 6. If you would like to stay involved as the Wildlife Management Guidelines and Land Use Code changes are developed, please share your email address. We will only contact you about this project. lori_nitzel@yahoo.com 1  Wildlife and Prairie Dog Management Public Engagement Results August 10, 2016 This document includes an overview of the Open House and Forum that was held July 28, responses to questions posed there, as well as a list of online comments received through August 10. More information is available at: • Wildlife Management Guidelines proposed updates: www.fcgov.com/naturalareas • Proposed Land Use Code updates: www.fcgov.com/planning  Open House and Forum Purpose and Format The open house and forum’s goal was to get input on proposed updates to policies and share the City of Fort Collins’ philosophy for wildlife protection and management, with an emphasis on prairie dog management. Poster stations (pdf) provided an overview of proposed changes to both theNatural Areas Wildlife Management Guidelines that impact public lands and the Land Use Code that regulates development on both public and private lands (Land Use Code posters pdf). A panel discussion provided information on prairie dog management (see below). The evening allowed time for participants to ask questions and share ideas with planners, as well as to provide feedback via comment forms. Participants were encouraged to submit additional comments at fcgov.com/naturalareas . While feedback is appreciated any time, comments received by August 10 are included here. Prairie Dog Forum The panelists included: • John Stokes, City of Fort Collins Natural Areas Department • Rebecca Everette, City of Fort Collins Planning Services • Tina Jackson, Colorado Parks and Wildlife (CPW) • Lindsey Sterling Krank, Prairie Dog Coalition of the Humane Society of the U.S.(PDC) In their opening remarks, the panelists highlighted the following information: CPW: • Colorado is one of only 11 states with black-tailed prairie dogs. There is a significant range- wide effort to conserve them including CPW’s goal to conserve 255,000 acres within the state. The state’s plans are outlined in its 2003 Grassland Management Plan. The last survey that was done in 2006-2007 documented 814,000 acres of prairie dog colonies, which is well above the management plan goal. A new 2016 survey is underway. • Researchers at CPW are working to develop a sylvatic plague vaccine. • CPW is working with the US Fish and Wildlife Service and USDA National Resources Conservation Service (NRCS) to provide land owner incentives as part of black-footed ferret conservation efforts. Prairie Dog Coalition: • The Prairie Dog Coalition’s mission is to help conserve prairie dogs as they have been in significant decline. The Coalition’s main goal is to focus on prairie dogs with the largest ATTACHMENT 7 2  conservation value such as larger, often rural, areas with contiguous colonies and associated species (Soapstone Prairie Natural Area is an example).They attempt to address potential conflicts with prairie dogs by developing non-lethal solutions such as working with adjacent land owners to prevent migration within buffers, redirecting prairie dogs, etc. The Prairie Dog Coalition has recently worked with the City of Fort Collins Natural Areas Department on a project to relocate prairie dogs from a private site in east Fort Collins to Cathy Fromme Prairie Natural Area. City of Fort Collins Natural Areas Department: • The Natural Areas Department’s management approach includes conservation in the following contexts: ƒ A regional context at the Soapstone Prairie Natural Area and Meadow Springs Ranch (property managed jointly with the Fort Collins Utility Department). The intent at Soapstone Prairie is to have 3,000-4,000 acres of prairie dogs (currently approximately 1,600 acres). Prairie dog colonies are being treated for plague in collaboration with CPW. The department’s capacity to treat colonies for plague is about 3,000 acres a year. ƒ Urban natural area sites host about 400 acres occupied by prairie dogs. These areas are more constrained, posing significant management challenges. For a historical perspective, in the mid-2000’s drought caused a lot of problems when prairie dog grazing denuded the land creating areas prone to wind erosion and dust storms. • The Natural Areas Wildlife Management Guidelines initially were adopted in 2007 and are now in the process of being updated. One significant change being proposed is that the city, under certain circumstances, could accept relocation of prairie dogs to Soapstone Prairie Natural Area. Fort Collins Planning Services: • The City is proposing updated land use code requirements related to prairie dog management on properties coming through the development review process. Two potential changes are to 1) eliminate the requirement that a private property must have at least a 50 acres or larger colony for additional protections and mitigation and 2)further restrict lethal management methods for development sites to carbon monoxide only (considered the most humane method and consistent with Natural Areas Department practice).   Forum questions and verbal responses From your perspective, what is the most significant challenge in Fort Collins related to prairie dog management? 1) loss of habitat, especially in constrained urban areas where there are high densities of prairie dogs, 2) plague, which is a significant range-wide issue and may not be as relevant in smaller urban areas, and 3) interface between land with prairie dog colonies and other property owners. How do you define suitable habitat? What are your goals for occupied acres? Suitable habitat is grassland that would have traditionally supported prairie dogs excluding upland sites with rare plants, shrublands, wetland areas and grassland restoration areas. City of Fort Collins Natural Areas Department’s intent is a 10-20% occupation of suitable habitat in natural areas. Are the population numbers for all states set by USFWS a starting point? Is there any guarantee that these numbers will insure long term survival of species? Colorado Parks and Wildlife's goal is 255,000 acres of prairie dogs statewide. The 2006 statewide survey found 814,000 acres of occupied colonies. In the 2016 survey, CPW will implement updated 3  survey methods that should yield a more accurate count. CPW is also working on a sylvatic plague vaccine for prairie dogs and offers land owner incentives to maintain prairie dog colonies. Describe the difference between CPW and the city’s jurisdiction. States have management authority of wildlife species except for species that migrate over state lines or are threatened or endangered under the Endangered Species Act. Prairie dogs are managed by the stateas a non- game, general species. Cities cannot be less restrictive, but can be more restrictive, than the state. Prairie dogs can be controlled on private lands by land owners. Those interested in relocation must go through a CPW permit process. What are the proposed changes to Fort Collins’ relocation policy? Could Soapstone Prairie be a relocation site? The Natural Areas Department got away from relocation in the 2000’s because conservation goals were being met without relocation, prairie dogs were causing damage in urban natural areas, and relocation is an expensive, complicated process that requires a lot of labor and expertise. The Natural Areas Department is now proposing to consider prairie dog relocation at Soapstone Prairie under specific conditions. The Department’s intent is to sustain 3,000 acres of active prairie dog colonies. Relocation of prairie dogs to Soapstone could occur if the population needed to be supplemented, and if required conditions were met including the presence of existing unoccupied burrows, and financing of all costs by private property owners or proponents. How do you determine if a site is good for relocation? If/how does relocation impact prairie dog social structures? If you give prairie dogs food, shelter and their family structure, they won’t leave an area. Replicating the layout of the colony is important to relocation success. Behavioral observations should be collected beforehand to understand family structures so that they can be recreated at the receiving site. Existing burrows are helpful on receiving relocation sites if used sooner rather than later because the tunnels can collapse with time. Existing burrows can make it more difficult to replicate the same burrow and family structure layout as the donating site. In order to prevent plague, it is often required that the take site and receiving site are both dusted with insecticide. What are typical success rates for relocation? There is a lot of debate about success rates. The Prairie Dog Coalition does not collect data to measure its success rates. How does a private property owner get started with relocation? The Natural Areas Department can provide advice on contractors that can relocate prairie dogs. The most significant challenge is finding a place to put them. Private property owners will have to get a permit from the state and follow the state protocols, which are listed on the CPW website. The Prairie Dog Coalition has a website with more information. How much does relocation cost? What is the cost to developers or other private property owners? The Prairie Dog Coalition shared that relocation costs vary and a rough estimate is $100/ prairie dog. City of Fort Collins estimates $150 to $400 per prairie dog. For development properties, other mitigations could include on-site mitigation or payment into a bank that funds off-site mitigation. Mitigation costs have not been determined. Fumigation is typically under $10/burrow. The Prairie Dog Coalition and CPW have been working on an incentive program involving a habitat quantification tool to assess conservation net gain so property owners can purchase conservation credits. How is the relocation of the Lemay Ave prairie dogs going? The Prairie Dog Coalition reports that all but one nest box is being used which is a good sign. The PDC doesn't track success rates. What is the future of prairie dogs at Cathy Fromme Prairie Natural Area? If the prairie dogs cross Taft Hill Rd, would you allow them to recolonize? 4  Natural Areas is seeing good population and relocation success. Staff will continue to watch and monitor the colonies. There are areas east of Taft Hill Road that host rare plants, quality grasslands and ecological restoration sites where prairie dogs will not be allowed. At this time there is only a small amount of available habitat east of Taft Hill Road on Cathy Fromme Prairie Natural Area. Please provide more detail on the plague vaccine that is being developed.Could you describe the relationship between high density of prairie dogs and increase in plague cases? Plague is a disease transmitted by fleas onto prairie dogs and other species. Plague typically emerges in the summer. Flea density plays a role in the spread of plague; when there are higher numbers of fleas, plague tends to spread more rapidly. The more dense the burrows of the prairie dog colony are, the more rapid the spread of fleas carrying plague. Plague can kill an entire prairie dog colony. At the same time, plague may be present without effecting populations at all. CPW currently kills fleas by dusting colonies. It costs approximately $30/acre and lasts about 9 months. Research on a sylvatic plague vaccine is underway. The vaccine doesn’t kill the fleas; it protects (inoculates) the prairie dogs. It is being tested at Soapstone Prairie and there have been positive results. CPW is currently ramping up production of the vaccine bait, with a goal of being able to treat 10,000 acres per year. Focus areas will be black-footed ferret conservation sites and Gunnison prairie dog sites in southern and western Colorado. What is the prairie dog’s experience when fumigation is used? Carbon monoxide is considered the most humane fumigant and is recommended as the only allowable lethal control for development sites in the update to the Land Use Code. Carbon monoxide is the only lethal control method used by the Natural Areas Department. Other fumigants are allowed on private property not undergoing development review. What prairie dog education is currently available? The Prairie Dog Coalition has a goal of reaching 1,000 students per year using a wide range of strategies from puppet shows to presentations on college campuses. The Prairie Dog Relocation Group also is working on an educational video. CPW has an education section that does a lot to teach the public about grasslands, including a video. They’ve been doing a lot of education with private land owners related to black-footed ferret conservation and prairie dogs on their properties. The City of Fort Collins Natural Areas Department provided over 300 educational activities last year to 18,000 people, many of which focused on the shortgrass prairie ecosystem. Are there opportunities to include Watchable Wildlife Areas as an educational tool? Fort Collins’ City Council adopted a Nature in the City Strategic Plan which coordinates with multiple city departments. There are several natural areas around town that provide prairie dog viewing such as The Coterie Natural Area. Additional Forum Questions Due to time limitations, not all questions were addressed at the Forum. These additional questions were submitted on post-it notes. 5  Question/ Comment Response Please explain how the current relocation project was approved? By one person, by a committee, by the City Council? Why was there not a vote by the citizens near this site offered? The relocation to Cathy Fromme Prairie Natural Area was approved by the City of Fort Collins Natural Areas Department and Colorado Parks and Wildlife after a public engagement process that included mailings to neighbors and Home Owner Associations within 1/8 mile of the natural area, a trailhead flyer, social media posts, a press release, an article in Natural Areas Enewsletter, posts on the Natural Areas Department webpage, listing on electronic event calendars, emails to City Council, City leadership, Land Conservation and Stewardship Board, and requests for feedback were mailed to Larimer County Commissioners, Larimer County Health Department, and US Geological Survey. An open house was held on April 19 and attended by 70 people. Comments were accepted at the Open House and online; 165 comments were received; 29 concerned, 5 no objections and 131 in support. I recently read in the Coloradoan that policy toward the prairie dogs has changed from "management" (i.e. killing) to relocation. Please comment on the changes. In the update to the Guidelines that is being proposed, lethal control will still be used, especially in urban natural areas where prairie dogs are near exclusion zones that host rare flora or fauna, are near residential developments or are in active grassland restorations. The Natural Areas Department’s intent is to sustain approximately 10%- 20% occupation of suitable habitat. Please note that occupation is only partly influenced by the City, independent factors such as climate and disease play a major role. In certain locations, occupation may be below or above these percentages. Only carbon monoxide is used for lethal management as it is the most humane method. So, if Soapstone Prairie Natural Area has 3,000 or less occupied acres of prairie dogs, other prairie dogs could be augmented or relocated into SSN? In the update to the Guidelines that is being proposed, Soapstone Prairie Natural Area could be a relocation site under certain conditions. City of Ft Collins has an active prairie dog program, but does Larimer County? Is anyone here from County Government? No representatives from Larimer County were present to respond as the Forum was hosted by City of Fort Collins. Are the intentions of the City and Larimer County to grow the number of acres of prairie 6  Question/ Comment Response the prairie dog colonies? (Such as 2007 -2009 - has photos of Cathy Fromme) Will prairie dogs be added to the city's list of species of special concern? The list is yet to be determined, future public outreach will include the opportunity to provide input on the species of concern list. Mitigation for developers is set at $900/acre of disturbed prairie dogs. Will that cost stay the same? In one recent example, a value of $900/acre was required for mitigation of the loss of a prairie dog colony on a development site. However, mitigation requirements for various natural resources are determined on a case-by-case basis and depend on the value of the resource or habitat that is lost. The City of Fort Collins has not yet determined whether a set cost would be applied for the loss of prairie dog colonies, what the appropriate amount would be, and if other mitigation options may be allowable (e.g., relocation instead of eradication, on-site habitat enhancements for other species, etc.). The mitigation strategy will be finalized throughout this process, with ongoing opportunities for community input. Could developers be forgiven paying mitigation if they agree to relocate? The City is currently exploring this as a mitigation option for developers that could be used instead of other forms of mitigation (e.g., payment- in-lieu for habitat loss). Staff is supportive of this option as an alternative form of mitigation for the loss of prairie dog colonies assuming relocation sites can be found. What other incentives could you give developers to use non- lethal means of controlling prairie dogs? Options could include requiring contributions into a "bank" that funds prairie dog relocation or grassland restoration or allowing relocation in place of mitigation requirements. In some cases, prairie dogs may be able to persist on a portion of a development site that remains undeveloped, which may be encouraged by the City in some situations. In addition, the Prairie Dog Coalition is working on a habitat quantification tool to assess habitat value, if the tool were implemented in Fort Collins then conservation credits could be purchased, which could be another option for developers. How many acres of prairie dogs are living on private lands in the city? The Natural Areas Department has used aerial photography to determine that there are approximately 300 acres of prairie dogs on private lands within the City's Growth Management Area. 7  Question/ Comment Response Is Fort Collins doing anything to limit how much development is happening in the city? In recent years, there has been significant population growth in communities all along the Front Range, including in Fort Collins - this is something that nearly every nearby community is dealing with. Growth and development in Fort Collins can be directly tied to the quality of jobs and quality of life within our community. The community's comprehensive plan, City Plan, provides guidance for how and where development should occur, and seeks to balance the values and priorities of our community with the private property rights of landowners. In addition, the City has established a fixed Growth Management Area to limit outward growth toward other communities. While the City cannot infringe upon the inherent rights of property owners to develop and increase the value of their properties, the City does have extensive regulations that restrict the type and character of the development that occurs. Community residents are strongly encouraged to participate at all stages of the development review process, as well as in long-range planning efforts, such as future updates to City Plan. Are prairie dog den holes dangerous to livestock? Is there any conclusive data? The Forum panel is not aware of resources to answer this question. The City of Ft Collins kills the prairie dogs on their land by the dam off of Frontage Road of I25 and 392. Why do they do that? This spot may be managed by North Poudre Irrigation Company (private land owner), or it may be Fossil Creek Reservoir Natural Area- we are not sure from the description. In the natural area, prairie dogs are lethally managed to maintain the current occupation rate and prevent erosion and overgrazing. Written Comment Forms A paper comment form was available at the Open House that asked: • Please share your thoughts on the proposed Natural Areas Wildlife Management Guidelines • Please share your thoughts on the proposed Land Use Code changes • Any other comments? • Are you a Larimer County resident? (circle one) Yes No • How did you hear about this project? • If you would like to stay involved as the guidelines and code are developed, please share your email address. We will only contact you about this project. City of Fort Collins responses to the comments are below (comments are in bold, responses follow). If you continue to allow the killing, make it the last choice. Have people relocate first and have regulations in place for public notices to give opportunity for rescue. We vote every year to fund our public land and we should be able to fund land for the prairie dogs. This question applies to both operations by Natural Areas on public properties as well as development regulations applied to private lands: 8  Natural Areas is recommending relocation options as well as continued use of lethal control. Details regarding the proposed revisions to the Wildlife Management Guidelines are at fcgov.com/naturalareas. Planning Services is recommending a number of changes to the Land Use Code that would require additional consideration and mitigation for prairie dog colonies that are impacted by development projects. If approved, these requirements may make relocation more attractive for some property owners and developers. However, it is important to recognize that relocating prairie dogs is significantly more costly and time consuming than eradication for a property owner or developer. All proposed development projects, regardless of whether the contain prairie dog colonies, are required to post a notification sign on the property for the duration of the development review process. Additional information about these projects can be found at any time online at www.fcgov.com/developmentreview, or by contacting the Planning Services office directly. It might be advantageous to develop a program which allows people to volunteer doing hands on conservation work in order to accomplish more without significantly increasing costs. I understand that there is a colony in town being relocated by volunteers. More of this grassroots type of involvement in conservation could go a long way. Volunteers play an important role in wildlife relocations. Relocations also require the leadership of an experienced, professional wildlife management organization. A recommendation: Look into cooperative management plans with private landowners. By collaborating and working with private landowners we have more power to persuade non- lethal management. There are private landowners in Larimer County who have entered into agreements and incentive programs with federal agencies to conserve areas for the conservation of the black-footed ferret recovery. This typically involves protections of the ferret’s habitat including prairie dog towns. Biggest concern for developers is cost, so how will the city address this if non-lethal is more expensive compared to lethal control? One way to do this is for the city to offer some form of assistance. This has been done around the country, specifically with farmers and wildlife species. I cannot recall the name of the program, but I know it has had success as the farmer is essentially being rewarded for promoting healthy habitats and wildlife coexistence. As noted above, the Natural Resource Conservation Service (NRCS) administers several federal programs that promote grassland-related conservation. The Natural Areas Department is not recommending that the City fund private conservation efforts for prairie dogs. Fumigation is cheaper which is what causes this huge controversy in control and management. It’s cheaper because application is quicker and more convenient than relocation costs. What if we raise the price of fumigation because not only is it painful for the animal, but potentially can be damaging to the environment (other wildlife could consume). This is a cost in itself although it’s not presented by money. Like I mentioned earlier, offering a reward system/credit system for beneficial and healthy practices for the environment. (Also toxins could persist in environment causing more, indirect damage, risks to humans as well.) The City of Fort Collins does not regulate cost of fumigants or cost of services in the private sector for lethal control. For two years now, the Natural Areas Department has used pressurized carbon 9  monoxide gas that is the most humane and environmentally benign method for lethal management of prairie dogs. The City’s Planning Services staff is proposing that developers be required to use carbon monoxide treatment methods rather than other fumigants. Planning Services is also proposing increased requirements for protection and/or mitigation for the loss of prairie dog colonies, which may make relocation more attractive for some property owners and developers. Building a grasslands nature center and require schools to take a field trip there at certain age (kids are a great population to educate as they are excited and eager to learn – they are our future after all). The Natural Areas Department has conducted a variety of prairie dog and grassland conservation education and outreach for more than 20 years. In 2015, over 300 educational activities reached 18,000 people. The City cannot require local school districts to incorporate mandatory field trips/etc. Doing this could create revenue for grasslands management – with a focus on prairie dogs due to ecological importance. Education is huge; there are a lot of misunderstandings and confusion around the subject of prairie dogs. The Natural Areas Department is the largest environmental education provider in Larimer County with a team of three full-time employees, three seasonal employees, and 1,800 volunteers. In 2015, over 300 educational activities reached 18,000 people. It has been our policy since our program’s early days to provide free, high quality educational programming to local school districts and the community. Soapstone already has black-footed ferrets, which are one of the most endangered mammals in North America, so there is already so much investment in a species that is a prairie dog obligate carnivore. Considering a wide array of tactics to support the grassland ecosystem that is of such conservation value at SSN is necessary. Restoring grasslands is a great endeavor that Ft. Collins is undertaking, but guidelines to determine when a restored grassland can be habitat for native species, such as btpd should be established. It says that it is unknown when btpd will be ok on restored grasslands. What’s the point of doing habitat restoration if it is not to support CO native species? Grassland restorations are conducted within the urban core of Fort Collins, not Soapstone Prairie. Urban natural areas often have widespread non-native plants, developed borders, and other stressors that make maintaining native prairie challenging within the city. The City’s efforts to restore grasslands are making substantial progress: to date there are 1,700 acres of disturbed grasslands and former farmlands on their way to becoming native. These areas already support a myriad of native species, including declining bird species. Nevertheless, it will take time for these areas to mature to a point at which they are sufficiently stable to support heavy grazing by prairie dogs. At this time the City does not have specific criteria to determine when, or if, prairie dogs should be reintroduced to restored grasslands. Key decision factors include: presence/absence of other species of concern/interest; boundary conditions; climatic conditions; and, ecological objectives for all natural areas managed by the City. If there is an educational program for the public to teach them the importance and need of prairie dogs, what/where is it advertised? What about utilizing say Public Radio? For over 20 years the Natural Areas Department has provided educational material, field trips, and other efforts for both adults and children alike. Similarly, the Natural Areas Department has hosted professional field trips and workshops that focused on best practices in managing urban prairie dog towns. With limited budgets, public radio advertising/sponsorship is only used to promote large events 10  and special occasions. Very pleased that the City is opening up space to receive prairie dog relocations and changing LUC in consideration of prairie dogs. Would like to see more done to encourage and incentivize developers to relocate other than exterminate. The City could encourage developers to relocate prairie dogs through regulatory incentives. For example, reducing or eliminating requirements for mitigation of the loss of a prairie dog colony in exchange for relocating the colony instead. The City can also provide information about relocation opportunities to developers who are interested in that approach. However, it is important to recognize that relocating prairie dogs is significantly more costly and time consuming than eradication for a property owner or developer. Thank you for the dialogue and considering these wonderful creatures. Thank you for your comment. What can City do to persuade developers to relocate rather than exterminate prairie dogs? The City could encourage developers to relocate prairie dogs through regulatory incentives. For example, reducing or eliminating requirements for mitigation of the loss of a prairie dog colony in exchange for relocating the colony instead. The City can also provide information about relocation opportunities to developers who are interested in that approach. However, it is important to recognize that relocating prairie dogs is significantly more costly and time consuming than eradication for a property owner or developer. Is it possible to create an animal/wildlife sanctuary on private property? How large would the area need to be? Yes, it is possible for the private sector to establish sanctuaries on private properties within the considerations of the City’s Land Use Code. Financial resources and long-term stewardship would be required to ensure the health and sustainability of the land and wildlife. As a Wildlife Biologist who understands the importance prairie dogs play in healthy ecosystems they should be equally valued by the city. The City agrees that prairie dogs are an important component of urban and regional natural areas. Ft. Collins should celebrate its keystone species such as prairie dogs – I find them endearing and the colonies are the main reason I bring my family members to visit Ft Collins!! Great! Fort Collins’ Natural Areas Program serves as both a respected example to other cities looking to conserve local and regional natural areas as well as being a key factor in what makes Fort Collins such a special place to live. One of the most prominent assets of Fort Collins’ natural areas is wildlife, which is an important part of Fort Collins’ natural and cultural heritage. It is imperative that native wildlife be protected from exotic threats. Feral cats pose such a threat, and need to be kept from natural areas. Scientific studies show that, nationally, feral cats kill billions of native birds, mammals, reptiles, and amphibians annually. Natural Areas agrees. Scientific studies document the devastating impact of feral cats on native bird populations. 11  (1). These numbers far exceed the take of native predators and are a significant factor in the decline and extinction of many native wildlife species. Even though many feral-cat supporting organizations desire feral cats to be considered protected wildlife, they are an exotic species (2) and a major problem for wildlife management (3). Trap, Neuter and Release (TNR) programs, sponsored by some organizations, appropriately provide neutering, which helps prevent unwanted reproduction. Unfortunately, many feral cats are then returned to a harsh and cruel life in the wild, where they continue to kill native wildlife. Additionally, numerous scientific studies have shown that Trap, Neuter and Release fails to reduce population numbers (4). Feral and free-roaming cats contract diseases beyond those they have been inoculated against and are subjected to traffic and other accidents, harsh weather, attacks by wild animals and dogs, and human mistreatment. Thank you for your comment. We propose feral cats be trapped, neutered and adopted whenever possible, or if not adoptable, kept in an enclosed area where they can be provided food and water, shelter, veterinary care, regular waste removal, and safety (for both the cats and wildlife). Many animal and wildlife organizations oppose abandoning or returning cats to the wild, including The Wildlife Society, American Bird Conservancy, National Association of Public Health Veterinarians, National Audubon Society, and Fort Collins Audubon Society. Consistent with the City’s current regulations protecting wildlife and against the release of cats into the wild, cats should be kept out of the City’s natural areas. (1)The Impact of Free-ranging Domestic Cats on Wildlife in the U.S. Nature Communications 4, article #1396 (2) The Wildlife Society, Feral Cats: Impacts of an Invasive Species (3) Why American Songbirds Are Vanishing. Scientific American, 226:98-104 (4) Trap-Neuter-Release programs: the reality and the impacts. Journal of the American Veterinary Medical Association, 225:1369-1376. Submitted: Bill Miller, Ron Harden – Fort Collins Audubon Society Board Members Current City Municipal code prohibits animals at large (see below). Sec. 4-93. Animals at large prohibited. (a) All pet animals, except birds, shall be kept under restraint. It shall be unlawful for the owner or keeper of any pet animal, except birds, to permit such animal to be at large in the City, with or without the owner or keeper's knowledge. It’s refreshing to see the City working with local and regional groups to find humane ways of dealing with prairie dogs. I was part of a group that tried very hard, 10 – 15 years ago and was rejected, lied to and deceived by City officials. Thank you for your comment. Prairie dogs are a natural part of the world – remove them and a whole ecosystem collapses. They can and always have co-existed with bison and other prairie animals. Thank you for your comment. Prairie dog colonies are much prettier than that horrid development. Thank you for your comment. 12  Online Comment Form A comment form was available at fcgov.com/naturalareas. The questions were: • Please share your thoughts on the proposed Natural Areas Wildlife Management Guidelines • Please share your thoughts on the proposed Land Use Code changes • Any other comments? • Are you a Larimer County resident? (circle one) Yes No • How did you hear about this project? • If you would like to stay involved as the guidelines and code are developed, please share your email address. We will only contact you about this project. Comments received as of August 10 include: I wholeheartedly support protecting prairie dogs in the city and requiring all developers to relocate prairie dogs. If relocation is not possible, humanely euthanizing colonies is the only acceptable way for developers to move forward with construction. At this point they are just digging right into colonies, which results in much suffering for these sentient beings. See above. I will also note that I find the city's lack of prairie dog protections to be very much at odds with what I see throughout town - e.g., the museum encourages protection and prairie dogs are painted on city property. It's hypocritical. The requirement for a colony to be 50 acres or greater is just silly. The city should take every opportunity to promote and further conservation such as through relocation or fees for mitigation when habitat or colonies are destroyed for development. I agree with the proposed change of removing the 50 requirement. I also think that the 10-20% prairie dog occupation goal has its ups and downs. On one hand it provides a minimum goal to work toward but on the other hand, once that goal is met, it can be used as an excuse to do nothing when something should be done especially with black-footed ferrets in Soapstone. It might be advantageous to develop a program which allows people to volunteer doing hands on conservation work in order to accomplish more without significantly increasing costs. I understand that there is a colony in town being relocated by volunteers. More of this grassroots type of involvement in conservation could go a long way. I think we need more land set aside for prairie dog relocation. I do not agree with lethal control and think we should show / teach compassion. I like the idea of a Prairie Dog Park I like many of the proposed changes as it moves us to consider more details, I do not agree that lethal control is the best way. I think we can come up with some great solutions without killing. If you continue to allow the killing, make it the last choice. have people relocate first and have regulations in place for public notices to give opportunity for rescue. We vote every year to fund our public land and we should be able to fund land for the prairie dogs. A. Moving prairie dogs from private to public lands needs to be an option. If you don't allow this movement it will be too difficult for private landowners to find suitable properties. They'll choose the extermination option. Basically, we're signing prairie dog death warrants. B. The City's proposal to increase the current 1500 acres allotted to prairie dogs in Soapstone and Meadow Springs Ranch to 3000 acres is great. I'd like to see this increased even more in the future. A. The proposal to remove the current rule that lacks any protection or mitigation of impacts to prairie dog colonies less than 50 acres in size is much needed. These smaller colonies are viable, and the proposal that recognizes this is a good one. B. Extermination options need to be removed completely. Regardless of how "humane" we try to frame it, the fact is it is still extermination and it's a lazy and cruel way to deal with matters. 13  Fort Collins is on the brink of destroying many of our best assets through over development. We have to protect what makes our City special. We're already overloading our roads and green spaces with housing, traffic and overcrowding. We now have to search to find a small place where we can view our foothills, due to parking garages, stadiums and residential development. We'll never get that back. Preserving our wildlife, and the open spaces and land they need to survive, is more important than ever. If we don't, we're just another congested city that went for money over quality of life, with nothing unique or special about it. I appreciate the systems-based approach that the City is taking in addressing not just prairie dogs, but also ferrets, bison, etc. as our Natural Areas, in order to be successful, will need to conserve entire systems -- not just a few animal species. A diverse mix of native plants and animals are an important part of any successful approach. I enthusiastically support the City's proposal to eliminate the 50-acre minimum acreage for prairie dog colonies, understanding that smaller colonies are viable and serve an important role in preserving biodiversity. Prairie dogs are a keystone species and make possible the existence of many other species. Thank you for taking such an enlightened approach to this issue. I think it's important, as we think about managing prairie dogs in Colorado, to keep in mind just how diminished prairie dogs' populations are from what they were naturally, and to also keep in mind that we're one of just a few states that still have prairie dogs in our midst. Because they're commonly seen locally, we can sometimes fall into a mindset of thinking of them as if they're a plentiful species, when in fact there are far fewer of them than might be ideal in a prairie ecosystem. The guidelines that are proposed do seem to acknowledge this, but as we make decisions going forward, it would be helpful to keep prairie dogs' small populations in mind when (as an example) we're faced with the choice between killing them (the quick, cheap choice) and relocating them (the more time consuming, more expensive choice.) Preserving this species, including adequate population numbers to keep its genetic diversity healthy, is important and we should think long and hard before killing any of them. ATTACHMENT 8 -1- ORDINANCE NO. 021, 2017 OF THE COUNCIL OF THE CITY OF FORT COLLINS AMENDING LAND USE CODE SECTION 3.4.1, NATURAL HABITATS AND FEATURES WHEREAS, Land Use Code Section 1.2.2, Purpose, states that the purpose of the Land Use Code is to improve and protect the public health, safety and welfare by, among other means, minimizing the adverse environmental impacts of development and ensuring that development proposals are sensitive to natural areas and features; and WHEREAS, Land Use Code Section 3.4.1(B), Natural Habitats and Features, further states the purpose of ensuring that when property is developed, the proposed physical elements of the development plan are designed and arranged on the site to protect the natural habitats and features on both the site and in the vicinity of the site; and WHEREAS, changes in prairie dog colony size and characteristics, best practices, and development patterns within the City have necessitated changes to the existing regulations protecting prairie dogs to continue to fulfill the purposes of the Land Use Code; and WHEREAS, concurrent with the changes to update the prairie dog regulations, changes to Land Use Code Section 3.4.1 to update general provisions for the protection of natural habitats and features are also necessary to fulfill the purposes of the Land Use Code; and WHEREAS, the Planning and Zoning Board has considered these text amendments to the Land Use Code and made recommendations to the Council; and WHEREAS, the changes to Land Use Code Section 3.4.1 set forth by this Ordinance are in the best interests of the citizens of the City and advance the purposes of the Land Use Code. NOW, THEREFORE, BE IT ORDAINED BY THE COUNCIL OF THE CITY OF FORT COLLINS as follows: Section 1. That the City Council hereby makes and adopts the determinations and findings contained in the recitals set forth above. Section 2. That Section 3.4.1 of the Land Use Code is hereby amended to read as follows: 3.4.1 - Natural Habitats and Features (A) Applicability. This Section applies if any portion of the development site is within five hundred (500) feet of an area or feature identified as a natural habitat or feature on the City's Natural Habitats and Features Inventory Map, or if any portion of the development site possesses characteristics contains resourcesnatural habitats or features (including, without limitation, wetlands, riparian areas or foothills forest) which that -2- would have supported their inclusion on the Natural Habitats and Features Inventory Maphave significant ecological value, and such areas natural habitats or features are discovered during site evaluation and/or reconnaissance associated with the development review process. Resources Natural habitats and features included on the Natural Habitats and Features Inventory Map, as described in detail in Technical Memorandum 2, "Identification of Natural Areas," of the Natural Areas Policy Planconsidered to have significant ecological value, are as follows: (1) Natural Communities or Habitats: (a) Aquatic (e.g., rivers, streams, lakes, ponds); (b) Wetland and wet meadow; (c) Native grassland; (d) Riparian forest; (e) Urban plains forest; (f) Riparian shrubland; and (g) Foothills shrubland; and (hg) Foothills forest. (2) Special Features: (a) Significant remnants of native plant communities; (b) Potential habitats and known locations of rare, threatened or endangered species of plants; (c) Potential habitats and known locations of rare, threatened or endangered species of animalswildlife; . . . (j) Prairie dog colonies one acre or greater over fifty (50) acres in size; . . . (E) Establishment of Buffer Zones. Buffer zones surrounding natural habitats and features shall be shown on the project development plan for any development that is -3- subject to this Division. The purpose of the buffer zones is to protect the ecological character of the natural habitats or naturaland features from the impacts of the ongoing activity associated with the development. (1) Buffer Zone Performance Standards. The decision maker shall determine the buffer zones for each natural habitat or feature contained in the project site. The buffer zones may be multiple and noncontiguous. The general buffer zone distance is established according to the buffer zone table below, but the decision maker shall reduce or enlarge any portion of the general buffer zone distance, if necessary in order to ensure that the performance standards set forth below are achieved. The buffer zone performance standards are as follows: (a) The project shall be designed to preserve or enhance the ecological character or function and wildlife use of the natural habitat or feature and to minimize or adequately mitigate the foreseeable impacts of development. (b) The project, including, by way of example and not by way of limitation, its fencing, pedestrian/bicycle paths and roadways, shall be designed to preserve or enhance the existence of wildlife movement corridors between natural habitats and features, both within and adjacent to the site. (c) The project shall be designed to preserve significant existing trees and other significant existing vegetation on the site. (d) The project shall be designed to protect from adverse impact species utilizing special habitat features such as key raptor habitat features, including nest sites, night roosts and key feeding areas as identified by the Colorado Parks andDivision of Wildlife Division (“CPW”) or in the Fort Collins Natural Areas Policy PlanDepartment (NAPP“NAD”); key production areas, wintering areas and migratory feeding areas for waterfowl; heron rookeries; key use areas for wading birds and shorebirds; key use areas for migrant songbirds; key nesting areas for grassland birds; fox and coyote dens; mule deer winter concentration areas as identified by the Colorado Division of Wildlife or NAPPCPW or NAD; prairie dog colonies one acre or greaterover fifty (50) acres in size as included on the Natural Habitats and Features Inventory Map ; key areas for rare, migrant or resident butterflies as identified in the NAPPby the NAD; areas of high terrestrial or aquatic insect diversity as identified in the NAPPby the NAD; remnant native prairie habitat; mixed foothill shrubland; foothill ponderosa pine forest; plains cottonwood riparian woodlands; and any wetlands greater than one-quarter (¼) acre inof any size. -4- . . . BUFFER ZONE TABLE FOR FORT COLLINS NATURAL HABITATS AND FEATURES 1, 2 Natural Habitat or Feature Buffer Zone Standard 3 . . . Special Habitat Features/Resources of Special Concern . . . . . . Prairie Dog Colonies site analysis . . . (F) Protection of Wildlife Habitat and Ecological Character. (1) Sensitive or Specially ValuedRare, Threatened or Endangered Species. If the ecological characterization report required pursuant to subsection (D)(1) above shows the existence in sucha natural habitat or feature of a rare, threatened or endangered species of plant or wildlife, species identified by the City as a Sensitive or Specially Valued Species, or by state or federal agencies as "threatened," "endangered," "species of concern," or "sensitive natural community," then the development plan shall include provisions to ensure that any habitat contained in any such natural habitat or feature or in the adjacent buffer zone which is of importance to the use or survival of any such species shall not be disturbed or diminished and, to the maximum extent feasible, such habitat shall be enhanced. (NOTE: Some studies, e.g., rare plant surveys, are time-limited and can only be performed during certain seasons.) Projects that impact habitat areas used by Sensitive or Specially Valued Species shall be subject to Planning and Zoning Board Review. (2) Sensitive or Specially Valued Species. If the ecological characterization report required pursuant to subsection (D)(1) above shows the existence in a natural habitat or feature of a plant or wildlife species identified by the City as a sensitive or specially valued species, excluding threatened or endangered species, then the development plan shall include provisions to protect, enhance, or mitigate impacts to any such natural habitat or feature or in the adjacent buffer zone which is of importance to the use or survival of any such species to the extent reasonably feasible. (32) Connections. If the development site contains existing natural habitats or features that connect to other off-site natural habitats or features, to the maximum -5- extent feasible the development plan shall preserve such natural connections. If natural habitats or features lie adjacent to (meaning in the region immediately round about) the development site, but such natural habitats or features are not presently connected across the development site, then the development plan shall, to the extent reasonably feasible, provide such connection. Such connections shall be designed and constructed to allow for the continuance of existing wildlife movement between natural habitats or features and to enhance the opportunity for the establishment of new connections between areas for the movement of wildlife. (43) Wildlife Conflicts. If wildlife that may create conflicts for the future occupants of the development (including, but not limited to, prairie dogs, beaver, deer and rattlesnakes) are known to exist in areas adjacent to or on the development site, then the development plan must, to the extent reasonably feasible, include provisions such as barriers, protection mechanisms for landscaping and other site features to minimize conflicts that might otherwise exist between such wildlife and the developed portion of the site. . . . (N) Standards for Protection During Construction. For every development subject to this Division, the applicant shall propose, and the Director shall establish, measures to be implemented during the actual construction phase of the project to ensure protection of natural habitats and features and their associated buffer zones, as follows. . . . (6) Prairie Dog Removal. Before the commencement of grading or other construction on the development site, any prairie dogs inhabiting portions of the site within the LOD shall be relocated or eradicated by the developer. using city-approved methods as set forth in Chapter 4 of the City Code and, when applicable, Prairie dog relocation shall be accomplished using methods reviewed and approved by the Colorado Division of Parks and Wildlife Division. Following relocation or eradication activities, a report shall be provided to the City that documents when prairie dog removal occurred, the method(s) that were used to remove prairie dogs, measures taken to ensure that prairie dogs will not re- inhabit the site, and confirmation that no threatened or endangered species were harmed by removal activities. . . . Section 3. That the definition of “Natural area” contained in Section 5.1.2 of the Land Use Code is hereby amended to read as follows: -6- Natural area shall mean all areas shown as "natural areas" on the City's Parks and Natural Areas Map or the Natural Habitats and Features Inventory Map. Any land that qualifies as a "wetland" pursuant to the Federal Clean Water Act shall also be deemed a natural area, in addition to the areas designated as wetlands on the City's Natural Habitats and Features Inventory Map. Any land area that possesses such characteristics as would have supported its inclusion on the Natural Habitats and Features Inventory Map, or contains natural habitats or features which have significant ecological value listed in subparagraph 3.4.1(A), if such area is discovered during site evaluation and/or reconnaissance associated with the development review process, shall also be deemed a natural area as provided in subparagraph 3.4.1(C)(1)(a). Section 4. That the definition of “Natural area buffer” contained in Section 5.1.2 of the Land Use Code is hereby amended to read as follows: Natural area buffer zone shall mean any area described and established pursuant to subsection 3.4.1(CE). Section 5. That Section 5.1.2 of the Land Use Code is hereby amended by the addition of a new definition “Rare, threatened or endangered species” which reads in its entirety as follows: Rare, threatened or endangered species shall mean those species of wildlife and plants listed by the Colorado Parks and Wildlife Division, the Colorado Natural Heritage Program, or the U.S. Fish and Wildlife Service as rare, threatened or endangered. Section 6. That the definition of “Sensitive or Specially Valued Species” contained in Section 5.1.2 of the Land Use Code is hereby amended to read as follows: Sensitive or sSpecially vValued sSpecies shall mean species included on the City of Fort Collins Species of Interest List, as developed and updated by the Natural Areas Department.the following species: Federally Threatened and Endangered Species; State of Colorado Threatened and Endangered Species; State of Colorado Species of Concern as identified in the document, Colorado's Natural Heritage: Rare and Imperiled Animals, Plants and Natural Communities, April 1996, Volume 2, No. 1, Animals and Plants of Special Concern and/or any other species identified as in need of protection in the City of Fort Collins Natural Areas Policy Plan. Section 7. That the definition of “Special habitat features” contained in Section 5.1.2 of the Land Use Code is hereby amended to read as follows: Special habitat features shall mean specially valued and sensitive habitat features including key raptor habitat features, includingsuch as nest sites, night roosts and key feeding areas as identified by the Colorado Parks and Wildlife Division of Wildlife (“CPW”) or in the Fort Collins Natural Areas DepartmentPolicy Plan (“NAD”PP); key production areas, wintering areas and migratory feeding areas for waterfowl; key use areas for wading birds and shorebirds; heron rookeries; key use areas for migrant -7- songbirds; key nesting areas for grassland birds; fox and coyote dens; mule deer winter concentration areas as identified by the CPWColorado Division of Wildlife or NADPP; prairie dog colonies one acre or greaterover fifty (50) acres in size as included on the Natural Areas Inventory Map; key areas for rare, migrant or resident butterflies as identified inby the NADPP; areas of high terrestrial or aquatic insect diversity as identified inby the NADPP; remnant native prairie habitat; mixed foothill shrubland; foothills ponderosa pine forest; plains cottonwood riparian woodlands; and any wetlands greater than one-fourth (¼) acre in of any size. Introduced, considered favorably on first reading, and ordered published this 7th day of February, A.D. 2017, and to be presented for final passage on the 21st day of February, A.D. 2016. __________________________________ Mayor ATTEST: _____________________________ City Clerk Passed and adopted on final reading on this 21st day of February, A.D. 2016. __________________________________ Mayor ATTEST: _____________________________ City Clerk dog colonies? No representatives from Larimer County were present to respond as the Forum was hosted by City of Fort Collins. As noted above, the Natural Areas Department’s intent is to sustain approximately 10%- 20% occupation in suitable habitat. The City’s ability to sustain these percentages depends on some factors outside of, or only partially, within its control (for example climate and disease). What defines a "suitable habitat" for relocation near housing areas? The City of Fort Collins Natural Areas Department requires a 300 foot buffer from residential areas. Should there be another drought, what is the plan to protect the prairie grasses from over consumption by The City of Fort Collins Natural Areas Department's intent to manage for a 10%-20% prairie dog occupation urban natural areas was set based on experience from the mid-2000's and accounts for drought conditions. Common garter snake Thamnophis sirtalis NA NA Documented SWAP Tier 2 SC Lined snake Tropicdoclonion lineatum G5 S3 Documented CNHP watch Milksnake Lampropeltis triangulum G5 S2 Documented SWAP Tier 2 Ornate box turtle Terrapene ornata NA NA Documented NA Painted turtle Chrysemys picta G5 S5 Documented CNHP partial Short-horned lizard Phrynosoma hernandesi G5 S5 Documented CNHP watch Invertebrates Arapahoe snowfly Capnia arapahoe G1 S1 Potential CNHP full Arogos skipper Atrytone arogos G3 S2 Documented CNHP full Autumn springfly Pictetiella expansa G3 S2 Potential CNHP full Backswimmer Notonecta unifasciata GNR S1 Documented CNHP full Colorado blue Eupholies rita coloradensis G3T3 S2 Potential CNHP full Crossline skipper Polites origenes G5 S3 Documented CNHP full Tier 2 SC McCown's longspur Calcarius mccownii G4 S2B Documented CNHP full/ SWAP Tier 2 Mountain plover Charadrius montanus G3 S2B Documented CNHP full/ SWAP Tier 1 SC Northern bobwhite* Colinus virginianus G5 S4 Documented SWAP Tier 2 Northern goshawk Accipiter gentilis G5 S3B Documented CNHP watch/ SWAP Tier 2 Northern harrier Circus cyaneus G5 S3B Documented SWAP Tier 2 Northern pygmy owl Glaucidium gnoma G4G5 S3B Documented CNHP watch Olive-sided flycatcher Contopus cooperi G4 S3S4B Documented SWAP Tier 2 Ovenbird Seiurus aurocapilla G5 S2B Documented CNHP full Pinyon jay Gymnorhinus cyanocephalus G5 S5 Documented SWAP Tier 2 Piping plover Charadrius melodus G3 S1B Documented CNHP full/ SWAP Tier 2 T T Plains sharp-tailed grouse Tympanuchus phasianellus jamesi G4T4 S1 Potential reintroduction CNHP full SC Prairie falcon Falco mexicanus G5 S4 Documented CNHP watch/ SWAP Tier 2 Rufous hummingbird Selasphorus rufus G5 SNA Documented SWAP Tier 2 Tier 2 SC Townsend's big-eared bat Coryhnorhinus townsendii pallescens G3T3 S2 Documented CNHP full/ SWAP Tier 1 SC Birds American bittern Botaurus lentiginosus G4 S3S4B Documented SWAP Tier 2 American peregrine falcon Falco peregrinus anatum G4T4 S2B Documented CNHP full/ SWAP Tier 2 Deli ste d SC American white pelican Pelecanus erythrorhynchos G4 S1B Documented CNHP full/ SWAP Tier 2 Bald eagle Haliaeetus leucocephalus G5 S1B, S3N Documented CNHP full/ SWAP Tier 2 Deli ste d SC Barrow's goldeneye Bucephala islandica G5 S2B Documented CNHP full/ SWAP Tier 2 Black tern Chlidonias niger G5 S2B Documented SWAP Tier 2 Black-necked stilt Himantopus mexicanus G5 S3B Documented CNHP full Bobolink Dolichonyx oryzivorus G5 S3B Documented CNHP watch/ SWAP Tier 2 Distichlis spicata Herbaceous Vegetation Salt Meadows G5 S3 P Documented Krascheninnikovia lanata / Pascopyrum smithii - Bouteloua gracilis Dwarf- shrub Herbaceous Vegetation Western Slope Grasslands G4 S1 Y Documented Pinus ponderosa / Cercocarpus montanus / Andropogon gerardii Wooded Herbaceous Vegetation Foothills Ponderosa Pine Scrub Woodlands G2 S2 Y Documented Populus deltoides / Carex pellita Woodland Plains Cottonwood Riparian Woodland G2 S2 Y Documented Hesperostipa comata - Bouteloua gracilis - Carex filifolia Herbaceous Vegetation Montane Grasslands G5 S2 Y Documented Typha (latifolia, angustifolia) Western Herbaceous Vegetation Narrow-leaf Cattail Marsh G5 S4 P Documented Potentilla rupincola Rock cinquefoil Osterh. G2 S2 Y Potential Psoralidium argophyllum Silverleaf scurf pea (Pursh) Rydberg G5 SNR N Potential Rotala ramosior Lowland rotala (L.) Koehne G5 S1 Y Potential Silphium integrifolium Michx. var laeve Wholeleaf rosinweed Torr. & A. Gray G5 SH Y Potential Silphium laciniatum Compass plant L. G5 SH Y Potential Sisyrinchium demissum Stiff blue-eyed grass Greene G5 S2 Y Potential Suckleya suckleyana Poison suckleya (Torr.) Rydb. G5 SNR N Potential Symphyotrichum novae-angliae New England aster (L.) G.L. Nesom G5 S1 Y Potential Trillium ovatum Pacific trillium Pursh G5 S3S4 W Potential Viola pedatifida Prairie violet G. Don G5 S2 Y Potential Viola selkirkii Selkirk’s violet Pursh ex Goldie G5? S1 Y Potential List of rare plant communities tracked by the Colorado Natural Heritage Program that occur in Fort Collins Natural Areas. Scientific Name Common Name Global Rank State Rank Tracked by CNHP? ESA Status FC Natural Areas Status Fernald G5 S1 Y Potential Lesquerella alpina var. alpina Alpine bladderpod (Nutt.) S. Watson G5T4 SNR Y Potential Lesquerella arenosa var. argillosa Secund bladderpod Rollins and Shaw G5T4 S1 Y Potential Lewisia rediviva var. rediviva Bitterroot Pursh G5 S2 Y Potential Lewisia triphylla Threeleaf lewisia (S. Watson) B.L. Rob G4? S2 Y Potential Liatris lancifolia Lanceleaf blazing star (Greene)Kittell G4 S1 Y Potential Lilium philadelphicum Wood lily L. G5 S3S4 W Potential Listera borealis Northern twayblade Morong G4 S2 Y Potential Listera convallarioides Broad-leaved twayblade (Sw.) Nutt. Ex Elliott G5 S2 Y Potential Lomatium nuttallii Nuttall's desert-parsley (A. Gray) J.F. Macbr G3 S1 N Potential Machaeranthera coloradoensis Colorado tansy- aster (A. Gray) Osterhout G3 S3 Y Potential Malaxis brachypoda White adder's- mouth orchid (A. Gray) Fernald G4Q S1 Y Potential Mertensia humilis Rocky mountain bluebells Rydb. G2 S1 Y Potential Mimulus gemmiparus Weber's monkeyflower W.A. G1 S1 Y Potential Mimulus ringens Square-stem monkeyflower L. G5 SH Y Potential Oenothera grandis Showy evening (Britton) Smyth G5? S1 Y Potential Aquilegia chrysantha var. rydbergii Golden columbine A. Gray, Munz G4T1Q S1 Y Potential Aralia nudicaulis Wild sarsaparilla L. G5 S2 N Potential Asclepias hallii Hall's milkweed A. Gray G3 S3 Y Potential Asclepias stenophylla Slimleaf milkweed A. Gray G4G5 S2 Y Potential Asclepias uncialis ssp. uncialis Greene's milkweed Greene G3G4T2T3 S2 Y Potential Astragalus americanus American milkvetch (Hook) M.E. Jones G5 SH Y Potential Astragalus bodinii Bodin's milkvetch Sheldon G4 S2 Y Potential Astragalus gilviflorus Plains milkvetch Sheldon G5 S1 Y Potential Astragalus plattensis Platte river milkvetch Nutt. G5 S1 Y Potential Astragalus sparsiflorus Front range milkvetch A. Gray G2 S2 Y Potential Campanula aparinoides Marsh bellflower Pursh G5 SH Y Potential Chenopodium cycloides Sandhill goosefoot A. Nelson G3G4 S1 Y Potential Whorled water milfoil L. G5 S1 Y Potential Potamogeton diversifolius Waterthread pondweed Raf. G5 S1 Y Potential Sagittaria brevirostra Shortbeak arrowhead Mackenzie & Bush, G5 S2? N Potential Sagittaria calycina var. calycina Hooded arrowhead Engelm. G5T5? S1 Y Potential Stuckenia vaginata Sheathed pondweed (Turcz.) Holub G5 SNR N Potential Utricularia minor Lesser bladderwort L. G5 S2 Y Potential Wolffia borealis Northern watermeal (Engelm. Ex Hegelm.) Landolt ex Landolt & Wildi G5 SNR N Potential Shrubs and Trees Amorpha nana Dwarf false indigo Nutt. G5 S2 Y Potential Betula papyrifera var. papyrifera Paper birch Marshall G5 S1 Y Potential Crataegus chrysocarpa Fireberry hawthorn Ashe G5 S1 Y Potential Salix serissima Autumn willow (L.H. Bailey) Fernald G4 S1 Y Potential Grass and Grass-like Achnatherum contractum Contracted ricegrass (B.L. Johnson) Barkworth G3G4 SU Y Potential Carex conoidea Field sedge Schkuhr ex Willd G5 S1 Y Potential Carex oreocharis Grassy slope sedge T. Holm G3 S2 Y Potential Carex peckii Peck's sedge Howe G5 S1 Y Potential Carex sartwellii Sartwell's sedge Dewey G4G5 S1 Y Potential Carex Rocky Mack G5 S1 Y Potential Triodanis perfoliata Clasping Venus' looking-glass G5 SNR N Documented Zone 3 List of plant taxa that could potentially occur in Fort Collins Natural Areas based on the presence of suitable habitat. Synonymy follows USDA, NRCS. 2015. The PLANTS Database (http://plants.usda.gov, 21 December 2015). National Plant Data Team, Greensboro, NC 27401-4901 USA. Scientific Name Common Name Authority Global Rank State Rank Tracked by CNHP? ESA Status FC Natural Areas Status Fern and Fern Allies Asplenium adiantum-nigrum Black spleenwort (L.) A. Nelson G5 S1 Y Potential Asplenium septentrionale Forked spleenwort (L.) Hoffman G4G5 S3S4 W Potential Botrychium campestre Prarie dunewort W.H. Wagner & Farrar G3G4 S1 Y Potential Botrychium lineare Narrowleaf grapefern W.H. Wagner G2G3 S2S3 Y Potential Botrychium multifidum Leathery grapefern (S.G. Gmel.) Trev G5 S1S2 Y Potential Botrychium virginianum Rattlesnake fern (L.) Sw. G5 S1 Y Potential Dryopteris filix- mas Male fern (L.) Schott G5 SNR N Potential Equisetum variegatum var. variegatum Variegated horsetail Schleich Ex, F. Weber & D. Mohr G5 S1 Y Potential Goodyera repens Lesser rattlesnake plantain (L.) R. BR G5 S3S4 W Potential G5 SNR N Documented Zone 1 Ammannia robusta Grand redstem G5 SNR N Documented Besseya wyomingensis Wyoming coral- drops G5 S1 Y Documented Calystegia sepium Hedge false bindweed G5 SNR N Documented Zone 1, 2 Cirsium flodmanii Flodman's thistle G5 SNR N Documented Eustoma exaltatum ssp. russellianum Prairie gentian G5 S3S4 W Documented Zone 1, 2, 3 Gaura neomexicana ssp. coloradensis Colorado butterfly plant G3T2 S1 Y LT Documented Zone 1, 5 Glaux maritima Sea milkwort G5 SNR N Documented Zone 1 Liatris ligulistylis Rocky mountain blazing star G5? S2 Y Documented Lobelia siphilitica var. ludoviciana Great blue lobelia G5T5? SNR N Documented Zone 1 Lysimachia ciliata Fringed loosestrife G5 SNR N Documented Zone 1, 2, 3 Lysimachia thyrsiflora Water loosestrife G5 S1 Y Documented Zone 1 Mentzelia speciosa Jeweled blazingstar G3 S3 Y Documented Musineon tenuifolium Slender wild parlsey G4 S2 Y Documented Osmorhiza longistylis Smooth sweet- cicely G5 SNR N Documented Pediomelum esculentum Large Indian breadroot G5 SNR N Documented G5 S2 Y Documented Zone 1 Opuntia phaeacantha Tulip prickly pear G5 SNR N Documented Vines Humulus lupulus var. neomexicanus Common hop G5 SNR N Documented Zone 1, 3, 4, 5 Smilax lasioneura Blue ridge carrionflower G5 S3S4 W Documented Zone 1 Grass and Grass-like Acorus calamus Sweetflag G4? S1 Y Documented Zone 1, 2 Aristida basiramea Forked three- awn grass G5 S1 Y Documented Carex atherodes Wheat sedge G5 SNR N Documented Zone 1 Carex bebbii Bebb’s sedge G5 SNR N Documented Carex crawei Crawe's sedge G5 S1 Y Documented Carex lasiocarpa Slender sedge G5 S1 Y Documented ATTACHMENT 3 Relocation Options *must meet certain relocation criteria *must meet certain relocation criteria *mitigation requirements may be reduced if more humane forms of fumigation are used Relocation Options *must meet certain relocation criteria *must meet certain relocation criteria *mitigation requirements may be reduced if more humane forms of fumigation are used ATTACHMENT 2