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Black-footed ferret draft plan causes continued concern for Wyo groups

by Wyoming Livestock Roundup

At the conclusion of the second comment period for the Black-footed Ferret Draft Recovery Plan, Wyoming groups continue to express concern for the plan.

“We are concerned about all of these efforts continuing to aggressively move forward, absent the statewide 10(j) designation,” said Wyoming Association of conservation Districts (WACD) Executive Director Bobbie Frank. 

Wyoming Weed and Pest Coordinator Slade Franklin continued, “The Wyoming Weed and Pest Council’s (WWPC) position on the Recovery Plan, is similar to the position they took on the proposed Black-footed ferret Safe Harbor Agreement.  These programs and plans should be delayed and efforts should instead focus on finalizing the statewide 10(j) designation for the black footed ferret.”

10(j) protection

The lack of a 10(j) designation for black-footed ferrets in the state continues to concern Wyoming groups and landowners because of the lack of protection on public lands. 

Section 10 of the Endangered Species Act provides for exceptions to the act for actions that would otherwise be prohibited. Section 10(j) allows for the Secretary of the Department of the Interior to designate certain reintroduced populations established outside the species’ current range, but within its historical range, as experimental populations.

After Wyoming Governor Matt Mead contacted the Fish and Wildlife Service (FWS) requesting the 10(j) designation, the FWS responded with a letter indicating plans to develop a 10(j) rule.

In the March 6 letter, the FWS wrote, “We will initiate development of a complementary statewide 10(j) ‘experimental and non-essential’ rule for Wyoming, in collaboration with the Department.”

While the letter noted FWS’ commitment to developing the rule and work with the Wyoming Game and Fish Department, it provided no timeline or direction moving forward. 


The WWPC also remarked that urbanization is listed as a minimal threat to the disappearance of Black-footed ferret habitat. 

“The WWPC requests that the U.S. Fish and Wildlife Service revisit the issue of urbanization in the Recovery Plan and the threat it represents to black-footed ferret recovery,” reads the group’s comment letter.

In addition, the status of anticoagulant pesticides, such as Rozol and Kaput-D, as a high magnitude, imminent threat at ferret recovery sites also proved to be concerning for the group.

Due to label restriction by the Environmental Protection Agency, the WWPC commented that the potential for ferrets to be exposed to anticoagulant pesticides at recovery sites is slim to non-existent and would likely constitute a violation of federal and state pesticide laws. 

Further, the Council added that the FWS has documented that the primary reason for failure of some recovery sites has been sylvatic plague, but the draft plan marks prairie dog poising as the highest recovery threat, creating inconsistency.

The WWPC, as a result, requested data and specific information on site failure due to poisoning with anticoagulants. 

Other concerns

Additionally, the lack of diversified representation on the team working to implement black-footed ferret recovery was marked as a concern held by the WWPC.

“The U.S. Fish and Wildlife Service ‘solicited extensive partner review from the Black-footed Ferret Recovery Implementation Team’ in the development of this draft plan,” noted the WWPC. “The team, as defined by is ‘representatives from federal, state and tribal governments, zoos, private landowners and nonprofit organizations.’”

Yet the Implementation Team, according to the WWPC, lacks involvement and perspective from private landowners and local pest regulators with insight on the management of prairie dog populations. 

“We find it difficult to believe the committee can adequately address prairie dog management without input from those who implement regulatory programs on a state or private level,” they added.

“Private landowner and local government support and participation are integral to ferret recovery efforts,” said WACD in their comments.

Additionally, WACD continued, “Throughout the document, there is a lack of mention in regard to coordination with local governments.”


Further, the WWPC targeted inconsistencies in the plan.

In noticing increasing prairie dog numbers, the group expressed concern with the notion presented by the FWS that prairie dog numbers may be the most limiting factor to ferret recovery. Data, however, show that prairie dog populations have continued to increase.

Finally, in meeting recovery goals, the WWPC expressed apprehension as to the FWS plan to adequately monitor ferret populations and asked for clarification as to how monitoring would be accomplished to ensure recovery goals are achieved.

On the plan as a whole, the WWPC commented, “We believe a recovery plan that recognizes private landowner rights and needs and a multiple use management philosophy will provide the groundwork needed to make any recovery plan successful.”

Saige Albert is managing editor of the Wyoming Livestock Roundup and can be reached at 

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