We request that you return the black-tailed prairie dog (Cynomys ludovicianus) to the Endangered Species Act candidate list. This vital keystone species of Americas Great Plains deserves to be listed as a Threatened species under the Act. The black-tailed prairie dog population in the United States is down to less than 2\% of its historic size because of human actionsprimarily poisoning, shooting, and habitat destruction. Yet on August 12, 2004, the U.S. Fish and Wildlife Service under the Department of the Interior removed the species from a list of candidate species awaiting listing under the Endangered Species Act. In 2000 the Service declared the black-tailed prairie dog warranted for listing but precluded by other higher priority species. The reckless move to deny federal protection to the black-tailed prairied dog will exacerbate the threats of poisoning, shooting, and habitat destruction, futher imperiling the species and condemning to potential extinction other native species dependent on prairie dogs and the habitat they create.

The Fish and Wildlife Service justified its decision to remove the black-tailed prairie dog from the Endangered Species Act candidate list based on questionable new information. The Service now claims that new prairie dog data show that more prairie dogs exist than originally believed in 2000. It raised the official estimate from 676,000 acres up to 1,840,000 acres in 2004. However, the new estimate still demonstrates that the black-tailed prairie dog population has dropped by more than 98\%, far too small to maintain healthy ecosystems. In addition, the new figure is highly suspect. For example, independent scientists are calling into question the accuracy of Colorados 2002 prairie dog survey. The survey identified a large percentage of new prairie dog colonies where prairie dogs were later found not to exist.

In its announcement to remove the black-tailed prairie dog from the Endangered Species Act candidate list, the Fish and Wildlife service also claimed that sylvatic plague is not as serious as believed in 2000. Sylvatic plague in prairie dogs does not pose a significant threat to human health, but its effects are devastating to the animals. Plague remains a major threat to prairie dogs. The disease can wipe out whole prairie dog colonies. In the face of plague alone, scientists question whether the species can recover. Given the threats of poisoning, shooting, and habitat destruction, these activities must be regulated.

For some, prairie dogs are just rodents. This reflects a poor understanding of the crucial role prairie dogs play in the natural world. The prairie dog is the linchpin of vital ecosystems that sustain a host of wildlife species. These include animals dependent on prairie dogs and the habitat they provide, such as the endangered black-footed ferret and the imperiled swift fox, mountain plover, burrowing owl, and ferruginous hawk. Indeed, over 140 animal species are thought to benefit from prairie dogs and their colonies. Black-footed ferrets remain endangered primarily because few large prairie dog complexes exist to support this carnivore that eats prairie dogs almost exclusively and lives in their burrows. The Fish and Wildlife Service now spends $2 million of taxpayer money per year to support ferret captive breeding and reintroduction. Concentrating resources on prairie dog conservation would ensure a more cost-effect approach for protecting associated species by securing their habitat and prey-base.

Without federal protection, the black-tailed prairie dog and the many species that depend on it will continue their steep decline toward extinction. The Endangered Species Act is a critical safety net. The Act has successfully prevented the extinction of many hundreds of native animals and plants. However, long listing delays and the failure to list many warranted species puts wildlife and ecosystems at risk of disappearing from the American landscape. Only 1,265 of over 6,000 domestic wildlife species at risk are currently listed under the Endangered Species Act. Eighty-eight species are now extinct because of listing delays, and 92 died out after being denied federal protection under the Act. Approximately 300 species await listing right now. Moreover, the Endangered Species Act continues to be enormously popular with the American people; 86\% of the voting public support the current Endangered Species Act, according to a 2004 poll by Decision Research.

Additionally, ecosystem protection is a central purpose of this law and precisely what Congress intended when the Act passed in 1973. Prairie dog protection means ecosystem protection. Listing black-tailed prairie dogs as a Threatened species would also safeguard black-footed ferrets, burrowing owls, ferruginous hawks, mountain plovers, swift foxes, and over 130 other wildlife species that also benefit from prairie dogs. With strong protection we can recover the prairie dog, and safeguard a national treasure: the American Great Plains.