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Edited on Tue Jan-29-08 10:03 PM by malakai2
Make sure you mention that:
1) Any decision should not be made until after the Fish and Wildlife Service determines whether or not the black-tailed prairie dog warrants listing as a threatened species (90 day finding expected in August 2008); 2) The Forest Service, as a Federal agency, is required by the Endangered Species Act to use its discretionary authority to assist in conservation and recovery of listed species such as the black-footed ferret (reference the ESA); 3) The black-footed ferret recovery plan requires a minimum of 10,000 acres of black-tailed prairie dog acreage before a site can be considered for a reintroduction under Section 10(j) of the Endangered Species Act (reference the ferret recovery plan) 4) The Forest Service's ongoing efforts to limit the prairie dog acreage in Conata Basin, and on Nebraska National Forest in general, should be offset by an effort to create a new ferret reintroduction site in Thunder Basin (no need to reference, they'll know exactly what you are talking about) 5) Maintaining prairie dog acreage does not foreclose on any other use except livestock grazing and possibly recreational shooting (trust me, the Forest Service staff will go to great lengths to find cites to support this because ranchers own them politically); 6) Shooting of prairie dogs causes severe negative physiological effects in survivors, sufficient to cause colony collapse (reference Pauli and Buskirk, 2007); 7) Poisoning for the benefits of private landowners is an economic loser (reference Dan Uresk, several papers); 8) Prairie dogs are highly susceptible to plague, and therefore do not pose a significant disease threat to humans (lots of CDC data on that); 9) In light of the ongoing loss of prairie dog acreage due to poisoning, plague, shooting, and development, additional mortality from Forest Service sanctioned poisoning and shooting is likely to foreclose on meaningful black-footed ferret recovery while also causing mountain plovers and black-tailed prairie dogs to trend toward listing; 10) And finally, with the revelations of political interference in several endangered species listing and recovery decisions involving former Deputy Assistant Secretary of Interior Julie MacDonald, current Deputy Undersecretary of Agriculture David Tenney, and former FWS Region 6 Director Mitch King, those improprieties should be addressed prior to selecting an alternative so that the final decision is not subject to an injunction as arbitrary and capricious.
If you just send a form letter, the agency will read it, class it as not substantive because it matches comments already made by everybody else that sent the form letter. 50,000 people could say the same thing and have it count as a single comment. Several dozen unique, handwritten pro-poisoning, pro-shooting letters that they might receive from local landowners and shooters would be classed as substantive because each of those will address their own points. Go the extra mile, spend 20 minutes putting it in your own words. Feel free to use my points in your own letters.
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