An Overview of Soil Erosion on Prairie Dog-Occupied OSMP Lands

✱ Soil health is the absolute foundation of ecosystem health. Without healthy soils, diverse plant and animal communities cannot be sustained.

✱ Boulder’s Open Space agricultural lands (Ag lands) were purchased as farms to remain farms for our local foodshed. Once soil has been tilled or grazed—in many cases for more than 100 years—careful management is required to re-build or maintain soil health. Simply “conserving” this land in the arid West does not lead to regeneration of the soil. (Please “Take the Tour” to see the result of agricultural land being allowed to lie fallow with prairie dogs).

✱ Prairie dog populations on Boulder’s Open Space are currently at the highest levels ever measured since Boulder began counting them in 1996.

✱ Because of the compounding issues of prairie dog overpopulation and climate change, our top soil is literally blowing away, and along with it goes the ecological health and integrity of thousands of acres of Open Space lands. 

✱ Boulder has not updated its approach to managing prairie dog populations on agricultural lands for almost 20 years.

✱ Relocation of prairie dog communities alone is not a viable option for dealing with the numbers we now have on Open Space lands (see “Myths” for details).

✱ Relocation of prairie dog communities requires (by state law) multiple applications of a neurotoxin called “Delta Dust” at burrow entrances prior to relocation. The insecticide is intended to kill the plague-carrying fleas that could be moved with the prairie dogs, but also introduces a deadly toxin to our Open Space lands, which then blows around in the air and runs into water our systems, possibly killing native bees and other pollinators, fish and invertebrates, and posing significant risks to human health.

✱ Relying on a hands-off “natural” die-off of prairie dogs caused by sylvatic plague is not a reliable land management strategy. The last significant die-off event was in 2007.

✱ It is possible to simultaneously conserve and protect prairie dogs in dedicated Habitat Conservation Areas (HCAs)—which exist within the City of Boulder, Boulder County, and the greater Western region—while also conserving and protecting our remaining irrigable agricultural lands by keeping them free of prairie dogs.

✱ Our community has been actively engaged in trying to update Boulder’s approach to managing prairie dog populations on our Ag-lands for many years and the time to make definitive choices is now. Multiple stakeholders and the general public have had input into the current process since 2016, with the formation of the Prairie Dog Working Group, followed by almost 2-years of public hearings and meetings often referred to as the “Expedited Process.”

Competing Public Mandates

Since 2000, Boulder has prioritized the health and proliferation of prairie dog colonies over other, competing priorities on our Open Space lands. This has resulted in the severe degradation of many of our public agricultural lands—as well as adjacent private lands—damage that has pushed City Council towards a decision-making point.

The complexity of these competing priorities are reflected in the City of Boulder’s own mandates and ordinances, which sometimes contradict each other. For example, prairie dogs are unequivocally prioritized in Boulder’s Grassland Ecosystems Management Plan (last updated in 2010), while the City’s Charter specifically identifies the preservation of agricultural uses and lands suitable for agricultural production as a focus for open space and the work of the Open Space and Mountain Parks department (OSMP) (reference).

To add to these complexities, neither prairie dogs nor irrigation ditches recognize the borders of Boulder’s public lands. Our shared home is a checkerboard of privately-owned land, City-owned land, and County-owned land, each of which is governed by different (sometimes contradictory) prairie dog ordinances; all of which are superseded by Colorado Parks & Wildlife (CPW) state laws. Also at stake are water rights, of which Boulder’s OSMP holdings are estimated to be worth more than $100 million (reference, 2020 email from City Staff) including shares in nearly 30 local ditch companies. These precious water rights—and the possibility that we could forfeit some of them by allowing lands to become so degraded they can no longer retain irrigation water—should be a major consideration of how the City manages our public agricultural lands.

A Balanced Approach To Prairie Dogs & Agriculture Is Possible

OSMP has reserved 6,000+ acres of Habitat Conservation Areas (HCA’s) where prairie dogs are protected above all other species. Even if all prairie dogs on OSMP irrigated acres immediately disappeared, 3,200 acres of prairie dogs would still remain on OSMP HCA’s and preserves, a number well over OSMP’s stated goals of 800 to 3,137 acres of prairie dog colonies on dedicated sanctuaries (reference).

Interspersed with our own public lands, are the dedicated HCAs maintained by Boulder County Parks & Open Space (BCPOS), which also holds prairie dog HCAs as one of only 3 types of land use designations for its open space resources. In addition to that, private land owners and conservation groups are working to preserve appropriate grassland ecosystems for prairie dogs.

Prairie dog populations are actually now at their highest recorded record since Boulder began tracking them in 1996 (reference). The same is true state-wide, according to the most recent (2017) Colorado Parks and Wildlife state-wide survey, which found prairie dogs to be twice as abundant as they expected to find, which is good news for the black-footed prairie dog and its predators (reference).

Our Open Space Lands Are Blowing Away, When They Could Be Sequestering Carbon

Soils are the absolute, literal foundation of all ecosystem health. Healthy soil requires millions of species to exist in balance, from microbes to millipedes to mammals. Prairie dogs are often called a “keystone species,” but there is no such thing as a keystone species without a stable fully-functioning soil ecosystem below it.

Unfortunately, large concentrations of OSMP prairie dogs are destroying our soils by stripping our prairies and pastures of their protective grassy coverings. Bare soil loses carbon and nutrients, and then blows away in the wind, leaving barren, stony subsoil where only non-native invasive weeds like bindweed, thistle, and teasel thrive. 

It is tempting to cling to the belief that “just leaving prairie dogs alone” will have positive results, but this understanding is based on how prairie dogs coexist with other species in intact grassland ecosystems, not fragmented parcels of agricultural or untended lands. Please go see for yourself what OSMP’s prairie dog-impacted properties look like, and what types of vegetation are thriving there. We have created (and will keep adding to) this Prairie Dog Virtual Tour Google Map that be used for biking, driving, or even virtual tours of affected areas. You can also view and contribute to our new crowd-sourced database of Open Space land health.

There are some pervasive “myths” and misunderstandings about the impact that prairie dogs have on our public lands that likely stem from the conflation of the “big picture” in terms of the role prairie dogs play within intact grassland ecosystems, and the impact they have on our agricultural lands and fragmented open space, which have nowhere near the diversity of forage and predator communities that would be needed to maintain a natural balance without human intervention.

Myth #1 — Prairie dogs are a “keystone” species that is the foundation of ecosystem health, therefore simply leaving them to reproduce unchecked will naturally lead to healthy ecosystems.

Prairie dogs co-evolved with numerous predators keeping them in check, and with large ungulates (bison, elk) that migrated in vast herds and created cycles of disturbance and recovery—far different from Boulder County conditions for the last 150 years. Sufficient numbers of predators and vast herds are not going to return to fragmented OSMP agricultural holdings interspersed with development and highways, and prairie dogs unfortunately do not play the same solely beneficial role on our ag lands as they do in wild grasslands.

Myth #2 — Left “in peace” prairie dogs will, by nature of their being a “keystone species”, result in a return of our public lands to the wild grasslands they once were.

Boulder’s irrigated agricultural Open Space holdings were purchased at great taxpayer expense for the purpose of preserving our foodshed. They were not “wild” places when they were purchased, and decades of evidence has shown again and again that overpopulation of prairie dogs in confined parcels of land leads first to the loss of all vegetation (save some invasive, noxious weeds), then to the loss of those denuded top soils to windstorms and erosion. We are left with barren, rocky deserts—not healthy grasslands.  

Myth #3 — We don’t have to shoulder the unpleasant moral burden of culling prairie dog populations because the plague will periodically reduce their numbers sufficiently that we can take a wait and do-nothing approach.

In reality, both plague and lethal control by PERC-CO (carbon monoxide poisoning) are human-caused means of extermination. Plague is not “natural” in the West. It was introduced to San Francisco’s Chinatown by humans in 1900 and gradually spread West, arriving on the Front Range in 1943. Sylvatic plague is a gruesome disease of prolonged agony (3-5 days on average) that we would not wish on any living creature, whereas PERC-CO is a relatively painless death lasting 5-7 minutes.

Regardless of the murky moral territory here, there is some evidence that prairie dogs are becoming immune to plague, and the last significant “die-off” event was in 2007.

Myth #4 — We don’t have to kill prairie dogs to protect agriculture, because they can be live trapped and relocated.

✱ Relocation has been attempted for many years, but has not been successful at preventing the need for lethal control as well. Some prairie dogs always avoid capture, and then remaining populations have to be killed anyway.

✱ Relocation is, as the name implies, not a solution—it just means moving the problem somewhere else.

✱ OSMP staff has said that it can only feasibly relocate prairie dogs from 40 acres per year—given contraints on personnel, financial, and receiving sites. As we have nearly 1,000 acres of Ag lands already in crisis, the math alone tells us that we cannot “relocate” ourselves out of this conflict (reference).

✱ Relocation was prohibitively expensive before the City’s budget was slashed due to the loss of sales tax revenue post-pandemic. There are nowhere near sufficient funds now to relocate all of the prairie dog colonies that need to be removed.

✱ Even if there were funds to do so, there are not enough receiving locations within our jurisdiction to move existing colonies to. State law prevents prairie dogs from being moved across county lines, as they are considered pests that carry deadly diseases.

Myth #5 — Relocating prairie dogs is safe for the environment.

Because of the danger that plague-carrying fleas pose to both humans and animals, Colorado Parks & Wildlife requires the application of a lethal neurotoxin known as Delta Dust (deltamethrin) two separate times at all burrow entrances before relocation of a prairie dog colony.

Prairie dog burrows are literally dust, which prairie dogs spend all day kicking up. This means that in choosing to prioritize prairie dog lives by relocating them, we risk sacrificing the lives of native bees and other pollinators, invertebrates and fish, as the deltamethrin enters our air and water.

Boulder County is home to over 550 species of bees alone, of which 70% are solitary bees—the majority of which are ground-nesting. Many of these species nest in the ground around prairie dog colonies. Many beetles and other invertebrates inhabit the areas in and around prairie dog burrows. Several of these species have disappeared or at risk. For this reason, relocating prairie dogs is unfortunately a deadly choice for local ecosystems (reference).

Just as we need a diversity of species living in dynamic balance for there to be a fully functioning ecosystem, we need a diverse community of land stewards and approaches to how we tend to the land. Given the rapid pace of change we are living through—with our climate, and in our society— we need new ways of conducting this stewardship. Implementing changes that will allow for regenerative agriculture and “carbon farming” within the Project Area could give us the opportunity to do just that.

We can’t—and we shouldn’t—attempt these changes everywhere at once. The members of HEAL would like to see updated prairie dog management policies applied on the small percentage of our agricultural lands contained within the current “Project Area.” Meanwhile, the vast majority of our OSMP lands will continue to be managed under the best practices we’ve understood up to this point. 

Please do your own research, tour our Open Space lands where prairie dog colonies dominate, and write to Council express your views.