HomeMy WebLinkAboutPlans - 11/13/2025Twin Peaks Environmental
4750 York Street, Dacono, CO 80514 phone: 229.344.6801
TO: Ryan Benson
Touchmark Development and Construction
FROM: Rebecca Hannon
Twin Peaks Environmental (TPE)
DATE: November 13, 2025
RE: Prairie Dog Management Plan – Touchmark Fort Collins
TPE has prepared this plan for prairie dog management activities for the proposed Touchmark
development located on 20 acres at 4701 Cinquefoil Lane in Fort Collins, Colorado (Figure 1). It details
the scope of work that TPE will complete to remove black‐tailed prairie dogs (Cynomys ludovicianus)
located within the limits of disturbance.
Per the Fort Collins municipal code, prairie dog colonies greater than one acre must be either removed
for donation to a licensed raptor rehabilitator or black‐footed ferret program or fumigated in‐situ.
However, fumigation requires payment of in‐lieu fees for natural areas habitat restoration and
management. The project proponent intends to initiate project activities in early 2026, and therefore,
TPE will begin management activities in late fall or winter. During this time of year, the only option
available is relocation to a licensed raptor rehabilitator. This process is described below.
TASK 1: BURROWING OWL SURVEYS
All prairie dog colonies, active or inactive, provide potential habitat for the burrowing owl (Athene
cunicularia). The burrowing owl nests in Colorado from mid‐March through October each year. If any
prairie dog management activities are proposed during the nesting season, burrowing owl surveys must
be completed. TPE will complete owl surveys following the recommended guidelines from Colorado
Parks and Wildlife (CPW 2021). Surveys will consist of three separate site visits that will be conducted
within two hours of sunrise or sunset on days with low winds and no precipitation. A qualified biologist
will survey the entire property with binoculars for 10 minutes at each survey point; the number of
survey points will be determined by the lines‐of‐sight on the property. A recorded burrowing owl call
will be utilized to increase odds of detection.
Surveys should begin approximately two weeks before the scheduled start of prairie dog management
activities. If owls are identified on‐site, the CPW District Wildlife Manager (DWM) for the Fort Collins
area and the Environmental Planner with the City of Fort Collins should be notified. Given the small size
of the site, prairie dog management and construction activities should be delayed until the fall when the
owl(s) will likely migrate. If owls are not detected, activities can proceed as scheduled.
TASK 2: PRAIRIE DOG REMOVAL BY LIVE‐TRAPPING FOR DONATION
Colorado Parks and Wildlife Notification
CPW requires a permit only when prairie dogs are transported alive. For non‐permitted projects, CPW
requests communication prior to the start of trapping and submission of documentation of the number
of prairie dogs removed and donated from project sites following project completion. TPE will contact
the DWM for the area and submit a CPW Dead Prairie Dog Transportation Report upon completion.
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Live Trapping
TPE will utilize Tomahawk traps baited with sweetened rolled oats to remove prairie dogs. The trapping
period will include three days of pre‐baiting during which prairie dogs are allowed to acclimate to the
traps, followed by seven days of live trapping. Captured prairie dogs will be removed from the trapping
field within four hours of capture and housed in their cages in a protected area on site. If the
temperature is below 32° F or above 75° F, prairie dogs will be moved to a protected area within 1.5
hours of capture. Traps will be activated and monitored on weekdays between 0700 and 1600 hrs. Any
non‐target animals that are trapped will be released immediately.
Many factors contribute to the success of a trapping effort. Weather plays a significant role in prairie
dog capture success. Black‐tailed prairie dogs are diurnal and do not hibernate, but they have extremely
poor vision in low light. As a result, they are less active on cloudy days, and they may remain in their
burrows for several consecutive days during inclement weather. Human disturbance can also decrease
the success of a trapping effort. When prairie dogs encounter what they perceive to be a threat, an
alarm call is sounded, and individuals retreat into their burrows. A pedestrian walking on a sidewalk, a
vehicle driving through the site, or members of a survey crew could all cause prairie dogs to move
underground, thereby limiting capture time. For these reasons, TPE monitors trapping areas from a
distance using binoculars, and removes captured prairie dogs from the field only every few hours.
Euthanizing
TPE utilizes compressed carbon dioxide (CO2) gas to euthanize prairie dogs. Captured prairie dogs will
remain in their cages which will be placed four at a time into gas chambers. Following the American
Veterinary Medical Association procedures for euthanasia using CO2, TPE will slowly subject the
captured prairie dogs to the gas, which will put them to sleep and kill them within about 20 minutes.
TPE will also perform cervical dislocation on each animal after gassing to ensure death.
Donation
TPE will store all euthanized prairie dogs in freezers at the TPE facility for up to one month. This ensures
that any disease vectors, specifically fleas, are dead. TPE will donate dead prairie dogs to the Rocky
Mountain Raptor Program in Fort Collins where they will be used as food for rehabilitating raptors. TPE
has been donating prairie dogs to this facility for over five years.
TASK 3: FUMIGATION
Live‐trapping projects do not capture 100% of the population; there is always a proportion of
individuals that are not catchable. Because of this, TPE will fumigate all burrows within the project
area using pressurized exhaust. The Pressurized Exhaust Rodent Controller (PERC) utilizes compressed
exhaust collected from a small internal combustion engine. Upon collection, the exhaust is cooled and
compressed for distribution into burrows. TPE will utilize this machine to fill burrows with engine
exhaust, which contains a high level of carbon monoxide gas. Once a burrow is filled with the gas, it is
plugged with soil whereby all animals in the burrow should succumb to the gas. After the initial
treatment, TPE will perform two follow‐up inspections and re‐treat all open burrows found during that
time. Prairie dogs can survive all three treatments or migrate onto the site from nearby properties. If
needed, TPE can provide additional treatments.
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Pressurized exhaust can only be used on burrows located 100 feet or more from any habitable structure
due to Colorado Department of Agriculture regulations. All burrows requiring treatment within 100 feet
of a structure can be treated with CO cartridges, which are not regulated against such use. TPE will
increase trap density in these areas to minimize the need for cartridges.
TASK 4: COMPLETION REPORT
After all management activities are complete and all prairie dogs are believed to have been removed or
eradicated, a completion report will be submitted summarizing the management activities that
occurred, stating that no prairie dogs remain within the limits of disturbance, and authorizing
earthmoving activities to proceed.
TASK 5. PREVENTION OF RECOLONIZATION
When all prairie dog removal activities are complete, TPE recommends installing a silt fence along the
southern property line to prevent recolonization immediately before and during construction. There do
not appear to be prairie dogs on the property to the north, but if there are, a fence along the northern
property line would also be recommended. The roadway and hospital to the west and the ditch to the
east are serving as adequate barriers to movement. Once construction is complete, there will generally
be no remaining habitat for prairie dogs, and permanent fencing should not be necessary.
References
CPW. 2021. Recommended Survey Protocols and Actions to Protect Nesting Burrowing Owls. Available
at: https://cpw.state.co.us/Documents/WildlifeSpecies/LivingWithWildlife/Recommended‐Survey‐
Protocol‐Burrowing‐Owls.pdf. Accessed October 7, 2025.
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Figure 1. The green‐outlined area is the Study Area, which encompasses approximately 20 acres.