Kaput Prairie Dog Stewardship Plan

Answering Agricultural needs for 15 yrs
Stewardship: the careful and responsible management of something entrusted to one's care.
-Merriam-Webster

No one understands and appreciates the meaning behind stewardship of the land more than those in Agriculture.    With 60+ years of agricultural experience, the Scimetrics Team knows the goals and continues to provide effective baits that help protect crops, offer a reduced risk to non-target species and does not take a large bite out of the already too slim, bottom line.   We have put together this page to assist the Users of  anticoagulant Prairie Dog Baits to do so effectively, efficiently and with minimal impact to the environment.

 

So let's Begin...

User Responsibilities READ THE LABEL !!!  The label is the law. It is the responsibility of the applicator to read and follow all label directions. Failure to do so is a violation of federal law. Keep proper records for possible inspection by state and/or federal agencies, including copies of Bulletins,  even if there are no restrictions for the application area

Restricted Use Pesticide (RUP) Classification RESTRICTED USE PESTICIDE       DUE TO HAZARD TO NON-TARGET ORGANISMS For retail sale to and use only by Certified Applicators or persons under their direct supervision and only for those uses covered by the Certified Applicator's Certificate. Restricted use pesticide statement is clearly marked on the product label Requires a valid commercial or private applicator license to purchase the product Can only be applied by a certified applicator or persons under the direct supervision of a certified applicator, and only for those uses (pests) covered by the Certified Applicator’s license For prairie dog bait, your license must cover Outdoor Vertebrate Pest Control U.S. EPA classifies products as RUP for various reasons including, but not limited to:
  • required level of expertise for bait application
  • toxicity of bait
  • hazards to non-target organisms
  • threatened and endangered species concerns
  • ground water contamination concerns
Endangered Species Act (ESA)  Federal law The purpose of this act is to provide a means whereby the ecosystems upon which endangered species and threatened species depend may be conserved (ESA, Section 2b).  Administered by USFWS and NOAA. Website:  www.fws.gov and www.noaa.gov
Federal Insecticide, Fungicide and Rodenticide Act (FIFRA) Federal law....FIFRA
  •    regulates manufacturing, distribution, sale and use of pesticides
  • ensures that using the pesticide according to the product label will not cause
  • unreasonable adverse effects to humans, non-target species and/or the environment
  • dictates that the product label, including all materials referenced on it (e.g. endangered species protection bulletins, www.epa.gov/espp), is the LAW
  • Administered by U.S. EPA (Website: www.epa.gov)
EPA is required to abide by ESA regulations
  • The ESA directs all Federal agencies to work to conserve endangered and threatened species
  • Section 7(a)(2) of ESA requires federal agencies (“action agencies”) in consultation with the Services to ensure that any action they authorize, fund or carry out is not likely to jeopardize the continued existence of a listed species or result in the destruction or adverse modification of habitat designated by the Services as critical
Under FIFRA, the “action” subject to the consultation provisions of the ESA is the federal registration of a pesticide Pesticide Misuse is illegal…It is a violation of federal law to use a pesticide product in a manner inconsistent with its labeling If label directions are followed and there is “take” (i.e. an animal is injured or killed) of a listed species
  • NO violation of FIFRA
  • NO violation of ESA
If label directions are NOT followed and there is “take” of a listed species
  • VIOLATION of FIFRA
  • VIOLATION of ESA
  • Civil Penalties may apply
Examples of misuse:
  • Increase dosage rates
  • Violating specific safety instructions
  • Selling a restricted use pesticide to an uncertified applicator
  • Baiting outside the baiting season
  • Not performing line-transect carcass searches
  • Failure to report dead or morbid non-target wildlife to the National pesticide Information Center
  • Failure to dispose of dead or moribund black-tailed prairie dogs
 

Primary, Secondary & TertiaryPoisoning Primary Poisoning:

  • Direct consumption of bait
  • Example: Prairie dog bait was spilled on the ground and not cleaned up. A songbird (non-target animal) eats the spilled bait and gets sick or dies
Secondary Poisoning:
  • Consumption of poisoned carcass by predators or scavengers
  • Example: Eagle eats dead or dying BTPD with enough poison residue in tissue to sicken or kill the eagle
Tertiary Poisoning:
  • Consumption of a dying or dead animal that was poisoned by secondary poisoning
  • Example:    
  • 1. BTPD eats prairie dog bait, and dies above ground 2. Coyote eats poisoned BTPD with enough residual poison in its tissue to kill the coyote 3. Eagle eats dead coyote with enough residual poison in its tissue to sicken or kill the eagle
Endangered Species Protection Bulletins

Bulletins are part of EPA’s Endangered Species Protection Program Sets forth geographically specific pesticide use limitations for the protection of listed species and their designated critical habitat Bulletins are an extension of the product label.  Non-compliance is a violation of federal law Before applying bait, you MUST obtain the proper bulletin for the application area and month in which you are applying the product It is mandatory to access bulletins no more than 6 months prior to application Bulletins can be obtained via

          Website: http//www.epa.gov/espp/bulletins.htm           Phone: 1-844-447-3813

It is strongly recommended to have a printed bulletin with you during application, for the intended application area and month of your application It is recommended you keep a copy of the bulletin for your files, even if there are no restrictions in your area.  It is proof you checked the website.

Conservation Measures for species potentially affected by black-tailed prairie dog control Black-footed ferret Habitat: Central North America Do not apply bait within black-footed ferret reintroductions sites Do not apply bait if live/dead black-footed ferrets are found outside reintroductions sites in a BTPD colony, but immediately report it to the Black-footed Ferret Coordinator at 970-897-2730 ext.224. Allow sufficient time for FWS to capture and relocate BFF’s before applying bait Contact Black-footed Ferret Coordinator if BFF’s are found anytime, before, during or after application, or during carcass searches

 Grizzly Bear Habitat: Northwest United States (ID, MT, WA, WY) and Alaska In 13 counties in Montana, delay bait application by 2 months until Dec. 1, and shorten the application period in the spring by 2 weeks to end by March 1

Chiricahua Leopard Frog Habitat: desert grasslands of Southwestern United States, primarily AZ and NM Do not apply bait within the five southwestern New Mexico counties of Catron, Grant, Hidalgo, Sierra, and Socorro to avoid impacts to the Chiricahua leopard frog and its critical habitat

Jaguar Habitat: Southern United States, primarily AZ and NM Do not apply bait within the southwestern New Mexico county of Hidalgo to reduce the risk of impacts to the Jaguar

New Mexican Ridge-nosed Rattlesnake Habitat: Southwestern United States, primarily NM Do not apply bait within the southwestern New Mexico County of Hidalgo to avoid impacts to the New Mexican Ridge-nosed Rattlesnake and its designated habitat

Mexican Gray Wolf Habitat: Southwestern United States, primarily AZ and NM Do not apply bait within the four southwestern New Mexico counties of Catron, Grant, Hidalgo, and Sierra to reduce the risk of impacts the Mexican Gray Wolf

Mexican Spotted Owl Habitat: canyons and mountain forests in Southwestern United States (Southern Colorado, Southern Utah, AZ, NM, West Texas) Do not apply bait within 5 southwestern New Mexico counties (Catron, Grant, Hidalgo, Sierra & Socorro) to reduce risk of impacts to the Mexican spotted owl and its designated critical habitat

Preble’s Meadow Jumping Mouse Habitat: Colorado and Wyoming In 7 counties in Colorado (Larimer, Boulder, Weld, Jefferson, Douglas , Elbert & El Paso)  and 4 counties in Wyoming (Converse, Platte, Albany & Laramie) , delay bait application in the fall by 1 month, until November 1

Northern Aplomado Falcon Habitat: Southwestern United States, primarily Southern NM and South Texas BTPD colonies in 6 counties in NM and 35 counties in TX may be occupied by the federally endangered Northern Aplomado falcon Prairie dog bait application may be harmful to the Northern Aplomado falcon Contact U.S. Fish and Wildlife Service before application Contact Information USFWS in New Mexico: Ph. 505-346-2525 Contact Information USFWS in Texas:          Ph. 817-277-1100 Note: If you have to leave a voicemail message, FWS should respond within three (3) business days.  If you do not receive a response back from FWS within three (3) business days, you may apply the bait

 

Use Restrictions for PRAIRIE DOG BAIT For use only to control black-tailed prairie dogs For use only in the 10 states where the bait is registered For use only in underground applications. Apply 6 inches down active black-tailed prairie dog burrows. Leave no bait on soil surface Apply only between October 1 and March 15 of the following year, unless stated otherwise in the respective bulletin Do not allow non-applicators in the area during application Do not allow livestock to graze on treated areas for 14 days after treatment Do not use KAPUT-D PRAIRIE DOG BAIT, KAPUT COMBO PRAIRIE DOG BAIT, or ROZOL PRAIRIE DOG BAIT with any other anticoagulant bait. Do not apply black-tailed prairie dog bait within black-footed ferret reintroduction sites, or within the following Indian Reservations: •South Dakota: Cheyenne River, Lower Brule, Rosebud         •Montana: Ft. Belnap, and Northern Cheyenne (as specified in Endangered Species Protection Bulletins) Other BFF reintroduction sites include: •Wyoming: Shirley Basin •South Dakota: Badlands NP, Conata Basin, Windcave NP •Montana: UL Bend NWR, BLM-40 complex •Colorado: Wolf Creek  •Kansas: Logan County  •New Mexico: Vermejo Park Ranch •Use of black-tailed prairie dog bait is also prohibited within two additional Indian reservations in Montana:  Blackfeet and Crow. These areas are not BFF reintroduction sites, but the tribes do not want anticoagulant rodenticide products used within the boundaries of the reservation (as specified on federal label). NOTE:  Other tribes may have specific ordinances against the use of anticoagulant bait, for example Pine Ridge Indian Reservation, SD.  It is recommended to check specific ordinances before applying bait within Indian Reservations

Pre-application Assessment Check Bulletins Live! for your specific application area and month in which you intend to apply prairie dog bait to determine if there are any geographical pesticide use limitations Access bulletins no more than 6 months prior to application to make sure you will have up to date information KAPUT-D PRAIRIE DOG BAIT, KAPUT COMBO PRAIRIE DOG BAIT, and ROZOL PRAIRIE DOG BAIT are all Restricted Use Pesticides, therefore you must have a valid applicator’s license Make sure you have valid applicator’s license for the state you are baiting in

Site Inspection Identify active black-tailed prairie dog burrows Indications of active BTPD burrows are •Openings with freshly turned earth that are free of leaves, seeds, spider webs and other debris •BTPD feces and tracks Treat only active black-tailed prairie dog burrows

Application Directions By hand scoop By mechanical placement machine with calibration capability Apply ¼ cup of bait at least 6 inches down active prairie dog burrows Make sure no bait is left on the soil surface Applicator must retrieve and dispose of any bait spilled above ground or placed less than 6 inches down burrow entrance

Carcass Search and Removal Applicator must return to site within 4 days after bait application, and at 1 to 2 day intervals thereafter for AT LEAST TWO WEEKS to collect and properly dispose of any bait or dead or dying BTPD’s found on surface Collect and dispose of dead or dying BTPD’s and search for non-target animals for at least two weeks, BUT LONGER if carcasses are still being found at that time Carcass collection should occur by late afternoon to reduce the chances of nocturnal animals finding carcasses of dead or dying animals Although not required by the label, the following actions will help minimize risks of secondary poisoning to predators and scavengers      •longer duration of the search (beyond two weeks)      •more frequent carcass searches and collections, e.g. twice a day, once early in the morning to reduce exposure to daytime sight predators such as hawks and eagles, and another late in the afternoon to reduce the potential of nocturnal animals finding carcasses

Carcass Search Requirement Must be performed using a line-transect method that completely covers the baited area Transect center lines must not be more than 200 feet apart Transect center lines may be traveled on foot or by vehicle at a rate of 4 mph or less Start by dividing the area into straight, parallel lines to define width and ends of the area.  Use natural landmarks, stakes, GPS or other tools to easily identify the line and return to it for future carcass searches Set transect lines at a distance which will allow for unobstructed view, which may mean using natural breaks and creating a new transect line at a fence, hedge row, ditch, crests, etc. To evaluate proper distance, put a small brown object (e.g. glove) on the ground and walk away to a distance where the object still can be easily seen.  Use that as a benchmark for your spacing.  Remember: Max. spacing is 200 ft., but may have to be less depending on density of vegetation and/or other geographic properties Consider time of day and position of sun when establishing transect layout for maximum visibility (e.g. looking into the sun when searching decreases visibility) When a dead/sick animal or bait is detected, address it immediately before continuing to traverse the line and visually scan as before •Bait: remove from surface area •Non-targets (including live BFF):  report it •Targets: collect it for proper disposal Consider time of day and position of sun when establishing transect layout for maximum visibility (e.g. looking into the sun when searching decreases visibility) When a dead/sick animal or bait is detected, address it immediately before continuing to traverse the line and visually scan as before •Bait: remove from surface area •Non-targets (including live BFF):  report it •Targets: collect it for proper disposal

Reporting Requirements Report any apparently sick, dying or dead non-target animals, including federally listed species, that are found during carcass searches Report any sightings of live or dead black-footed ferrets to the Black-footed Ferret Coordinator.  (Coordinator has to be contacted if black-footed ferrets are found any time, i.e. before, during, or after application or during carcass searches)

Carcass Burial Bury carcasses on site in holes at least 18 inches deep or in inactive burrow to avoid non-target animal scavenging Burial includes covering and packing the hole or burrow with soil If burial is not practical (frozen ground), check with your state or local authorities regarding other disposal methods allowed Although not required by the label, the most effective method for disposing of carcasses and avoiding risk of secondary poisoning is to dispose of carcasses by state-approved methods that ensure inaccessibility of carcasses to scavengers and predators

Re-application of Prairie Dog Bait A second application of bait may be made if black-tailed prairie dog activity persists several weeks or months after the first application of bait NOTE: The same anticoagulant bait has to be used as in the first application Follow all the Use Restrictions, Site Assessment, Application and Follow-Up Directions as with the first application

Summary of Key Points Follow all label directions Consult EPA’s Bulletins Live! website Use only one anticoagulant prairie dog bait per treatment area (diphacinone or chlorophacinone) Use transect-line method for carcass searches Conduct carcass searches for at least two weeks or longer if carcasses are still being found at this time Reporting Responsibilities •Dead/dying non-target animals •Injured or sick Federally listed species •Live or dead black-footed ferrets