Forest Service plan sabotages ferret recovery on Thunder Basin National Grassland

Here’s a press release from Western Watersheds Project about the Forest Service’s plans to eliminate a Black-Footed Ferret Recovery management area of over 50,000 acres on Wyoming’s Thunder Basin National Grassland via a Forest Plan amendment.

Yesterday, Jon Haber shared this account of the Coconino National Forest in Arizona amending a Forest Plan, which was just revised in 2018, to facilitate construction of a powerline.

That got me wondering: Can folks think of many examples where the U.S. Forest Service has amended a Forest Plan to strengthen protections for wildlife, clean water, old-growth forests, soils or biodiversity? If so, please do share these examples. Regardless, my gut feeling is that the number of times the Forest Service has amended a Forest Plan to weaken protections for wildlife, clean water, old-growth forests, soils or biodiversity would far outnumber them.

Here’s that Western Watersheds Project press release:

LARAMIE, Wyo. – Western Watersheds Project submitted formal comments today excoriating a Forest Service proposal to eliminate a Black-Footed Ferret Recovery management area of over 50,000 acres on Wyoming’s Thunder Basin National Grassland. The Forest Service’s plan amendment increases the poisoning and shooting of native prairie dogs, upon which ferrets depend for their survival, an action driven by livestock lobby concerns that prairie dogs compete for vegetation with privately-owned cattle on these public lands.

“The Thunder Basin is one of the rare large expanses of public land where black-footed ferrets could be reintroduced on the High Plains,” said Erik Molvar, a wildlife biologist and Executive Director with Western Watersheds Project. “The Forest Service has an obligation to recover both prairie dogs and black-footed ferrets to their natural and healthy populations here, irrespective of livestock industry profits.”

The black-tailed prairie dog is designated as a Sensitive Species by the Forest Service. Ecologically, it is considered a “keystone species” holding grasslands ecosystems together, and it is critical to the survival of many other rare species of wildlife, from burrowing owls to swift foxes to mountain plovers. According to the Wyoming Game and Fish Department, black-tailed prairie dogs are down to one-one-hundredth of one percent of their original occupied habitat in Wyoming.

The original Grasslands Plan, completed in 2002, limited prairie dog poisoning to areas immediately adjacent to homes and cemeteries, and protected prairie dogs from sport shooting in the Black-footed Ferret Recovery zone. Thunder Basin ranchers, dissatisfied with the limitations governing prairie dog killing on public lands, pressed for weaker protections and more loopholes, and succeeded in dominating a collaborative process that wound up expanding prairie dog poisoning to Forest Service lands along private land boundaries. The new plan amendment expands poisoning and recreational shooting further still.

“Ranchers shouldn’t be able to rent public lands for private livestock grazing if they can’t coexist with the native wildlife, prairie dogs included,” said Molvar. “The idea that a federal agency wants to authorize the poisoning native wildlife in order to keep them off neighboring private lands – where they are also native – effectively imprisons wildlife on public lands and blocks them from repopulating their original habitats elsewhere.”

The Thunder Basin National Grassland encompasses lands that are the traditional lands of the Cheyenne, Crow, and Lakota peoples.


5 thoughts on “Forest Service plan sabotages ferret recovery on Thunder Basin National Grassland”

  1. It’s kind of in the structure of forest plans that entropy happens. Projects typically conflict with standards, and standards typically protect the environment, so project-specific plan amendments tend to get rid of or suspend standards to increase flexibility and impacts. The Forest Service desire for more flexibility is also playing out when plans are revised by reducing and softening standards compared to current forest plans. And there are some amendments like this one where that is the “purpose and need.” The Daniel Boone NF was working on an amendment to remove protections for Indiana bats. The Bitterroot proposed amendment for elk is probably in this category.

    On the other hand, some of the highest profile amendments undertaken were to add protection for wildlife, starting with the Northwest Forest Plan. These primarily involved species listed under ESA and litigation (or threats of). So they’ll add protections when legally necessary and when they are forced to. (I suggested this approach for a newly listed species on the Monongahela in a post yesterday.) But I would love to see an example of a forest that voluntarily says “we need to provide more protection for x, so we’re going to amend the plan” (or strengthen protection measures when a plan is revised).

    The Forest Service is required by both ESA and NFMA to contribute to recovery of the black-footed ferret. It will be interesting to see how they argue that this decision does that.

    • Jon, why would you do a plan amendment to be more protective when you could just change the project design criteria? That way when new science or whatever comes out you can just incorporate the new info rather than having to do more (potentially unnecessary) paperwork.

      Two other things about this press release: (1) I find it hard to believe that “According to the Wyoming Game and Fish Department, black-tailed prairie dogs are down to one-one-hundredth of one percent of their original occupied habitat in Wyoming.” Are they sure it isn’t .011 of a percent (here I’m just quoting the WW press release, I didn’t check that that Game and Fish actually said it.)?

      Here’s what FWS says..

      “The historic range of the black-tailed prairie dog included portions of 11 States, Canada, and Mexico. Today it occurs from extreme south-central Canada to northeastern Mexico and from approximate the 98th meridian west to the Rocky Mountains. The species is currently present in 11 States including Arizona, Colorado, Kansas, Montana, Nebraska, New Mexico, North Dakota, Oklahoma, South Dakota, Texas, and Wyoming.

      Most estimates of black-tailed prairie dog populations are not based on numbers of individual animals, but on estimates of the amount of occupied habitat. Density of animals varies depending on the season, region, and climatic conditions, but typically ranges from 2 to 18 individuals per acre. Density also can vary temporally due to poisoning, plague, and recreational shooting. A rangewide estimate of historically occupied habitat for the black-tailed prairie dog is 80 to 100 million acres. Current occupied habitat is estimated to be 2.1 million acres.

      The black-footed ferret is a federally listed endangered species that depends upon prairie dogs as a source of food and uses its burrows for shelter. Any actions that kill prairie dogs or alter their habitat could prove detrimental to black-footed ferrets occupying the affected prairie dog towns. Black-footed ferrets are considered extirpated except where they have been purposely reintroduced using special authorities under Section 10 of Endangered Species Act. For project planning purposes, please consult IPaC ( to determine if pre-construction black-footed ferret surveys are required, or contact your local Ecological Services Field Office.”

      Molvar says
      (2) “The idea that a federal agency wants to authorize the poisoning native wildlife in order to keep them off neighboring private lands – where they are also native – effectively imprisons wildlife on public lands and blocks them from repopulating their original habitats elsewhere.”

      But my thought would be, if landowners want them to repop their original habitats, they can move them, in fact if you wanted them many people would want to give theirs to you. And if people don’t want them, they can poison or shoot them anyway. So I think it is more the fact that landowners don’t want them that is the problem.

      Note what great lengths Boulder County, CO (most environmentally sensitive place in CO?) goes to manage them and respect their place in the ecosystem.

      “What are some of the challenges associated with relocating prairie dogs?
      While the city conducts prairie dog relocations – including recent efforts to remove prairie dogs from development sites, city parks and OSMP agricultural lands – relocations are logistically complicated and expensive. Finding suitable relocation sites is also challenging. There are many plant communities, such as xeric tallgrass prairie, and animal species like grasshopper sparrows that do not thrive where there are active prairie dog colonies, making these grasslands poor choices for relocating prairie dogs.

      Open space relocation sites must also meet specific standards to obtain a relocation permit from Colorado Parks and Wildlife. OSMP’s ability to relocate prairie dogs is further constrained by neighboring landowner concerns about relocating prairie dogs near their property, and state law makes it difficult to move prairie dogs to available sites outside of Boulder County.

      While OSMP has more than 1,050 acres of irrigable agricultural land that overlaps with prairie dog occupation, past relocation projects have only been able to accommodate the removal of up to 70 acres of prairie dog colonies per year because of the cost, time, contractor availability and permitting requirements associated with those projects.”

      I’ve also got a bit of a problem with the logic from the Defenders of Wildlife site here

      “For example, there are only about 300 ferrets remaining in the wild, and recovery hinges on the conservation of prairie dogs of the Thunder Basin.”

      Since we’ve come up from 18 ferrets to 300 without the Thunder Basin, I just don’t get the logic of any particular plains area being necessary for “recovery” if the pop has increased 37.5 times without it? Certainly it would be nice, but recovery apparently doe not “hinge” on it. And wouldn’t the dogs in the interior of the Thunder Basin be enough for the BFF? Wouldn’t being further away from private land be better anyway for the BFFs due to less disruption?

      • To answer your planning question, there are substantive requirements for wildlife that a forest plan must meet. If new information indicates that the forest plan is no longer meeting those requirements the plan must be changed. These strategic decisions about what is needed for a species can not be made project by project. (That doesn’t mean that additional mitigation beyond forest plan standards won’t be needed in unusual circumstances to achieve the plan’s desired outcome. Guidelines may also used to create flexibility to achieve those outcomes in different ways if they are equally as effective.)

        As for your ferret questions, the answer must be based on the 2013 Recovery Plan:
        • “Establish free-ranging black-footed ferrets totaling at least 3,000 breeding adults, in 30 or more populations, with at least one population in each of at least 9 of 12 States within the historical range of the species, with no fewer than 30 breeding adults in any population, and at least 10 populations with 100 or more breeding adults, and at least 5 populations within colonies of Gunnison’s and white-tailed prairie dogs.
        • Maintain these population objectives for at least three years prior to delisting.
        • Maintain a total of approximately 494,000 ac (200,000 ha) of prairie dog occupied habitat at reintroduction sites by planning and implementing actions to manage plague and conserve prairie dog populations (specific actions are described in Part II of this plan)”

        The Recovery Plan also says, “The availability of suitable reintroduction sites is a key limiting factor on the rate and success of black-footed ferret recovery.” It is specific only to the state level, but if Defenders’ characterization of Thunder Basin is accurate, this decision would impair recovery potential, not contribute to it. The Recovery Plan calls for prioritizing reintroduction sites, and if that were done the importance of Thunder Basin would be clearer.

      • The following comment is from Erik Molvar, who asked that I post it for him. For some odd reason, he’s not able to view any of the comments on this blog post and he’s not able to provide any comments on this post.

        Hi Matt,

        Please feel free to provide the following response to Sharon’s comment, as I am unable to access the comments online:

        The percentage of black-tailed prairie dog occupied habitat in Wyoming, contained in WWP’s press release, comes from the USFS 2015 Black-tailed Prairie Dog Conservation Assessment and management Strategy, which states on p. 18: “In Wyoming, it is estimated that BTPDs occupy 0.01% of their historic range”. We agree that this is a very low figure, but the agriculture industry in Wyoming has been extremely aggressive at eradicating this species.

        We agree that private landowners poisoning and shooting prairie dogs on private lands are a severe problem. However, we find it unacceptable that the Forest Service is permitting poisoning on adjacent National Grassland lands to facilitate what is clearly an ecologically dysfunctional private land management strategy. The very least the Forest Service can do is to prevent the poisoning of a Forest Service Sensitive Species, and to foster prairie dog numbers adequate to support ferret reintroduction. The proposed Plan Amendment alternatives each and all would weaken protections for prairie dogs and increase poisoning and shooting targeting prairie dogs on the National Grassland.

        Finally, under the Recovery Plan for the black-footed ferret, ten populations in the wild (with at least 30 breeding adults each), totaling at least 1,500 breeding adult ferrets are required to meet breeding objectives. Most potential reintroduction sites include a great deal of private land, and the Thunder basin is on of two candidate sites with the greatest acreages of non-private land. Being farther away from private land would be absolutely preferable, but such sites simply do not exist due to the scarcity of large prairie dog complexes. This is why the Thunder Basin reintroduction is considered a lynchpin for ferret recovery.

        – Erik Molvar


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