September 16, 1999

Mr. Ralph O. Morgenweck, Regional Director
U.S. Fish and Wildlife Service
Post Office Box 25486
Denver Federal Center
Denver, Colorado 80225

Dear Ralph:

The state wildlife agencies within the historic range of the black-tailed prairie dog are developing a Conservation Agreement (see attachment) to address the conservation needs of the species in our states. Unfortunately, the Service has an obligation for a decision on the species status by January 2000. This does not allow much time for the states to implement conservation actions directed toward the species. However, the Service can assist the states with finalizing and implementing the conservation agreement.

Our preferred approach is similar to how the jaguar listing action was handled in USFWS Region 2 (see attached). After submitting the Conservation Agreement to the Service, it was considered by the Service to have significant new information that should be considered in making a final decision. The comment period was opened for a short period of time (two weeks), public meetings were held within the affected areas, and a signed multiple-party agreement was submitted to the Service for their consideration. Although the jaguar was eventually listed, the Service considers the agreement as a template to a recovery plan and works through the Jaguar Conservation Team on conservation issues.

To assist with the conservation agreement, we request that the Service begin with simultaneously publishing in the Federal Register (a) a request for public comment on our draft black-tailed prairie dog conservation agreement, and (b) a reopening of the public comment period for the species status review. A 75 day comment period for the Conservation Agreement and the status review (with one Open House in each state for both actions) would enable us to gain further input from our stakeholders, finalize the document, and implement conservation actions before the close of the reopened status review comment period. The signed Agreement would then allow the Service to assess how the threats to the species will be reduced by implementation of the Agreement, as the Service considers the species status. 

We need your support and prompt action on this request. If you have any question or need assistance please do not hesitate in contacting Bill Van Pelt (602-789-3573).


Duane L. Shroufe


cc: Nancy Kaufman, Director, USFWS Region 2
Directors, Fish and Wildlife agencies within the range of the black-tailed prairie dog
Pete Gober, USFWS Region 6
Black-tailed prairie dog distribution list