EPA is providing an opportunity for public comment and the submission of
additional information pertinent to the following topics (if any is
available), as such information would further assist the Agency in
responding to the June 5, 2009 petition filed by the World Wildlife
Fund.

If possible, please specify how the information you submit was gathered.

I. Black – Tailed Prairie Dog Mortality

1.  Time to mortality for animals consuming Rozol bait, in comparison to
zinc phosphide.  

2.  Susceptibility of prairie dogs to predation after consuming
chlorophacinone, in comparison to zinc phosphide.

3.  The extent to which prairie dogs die above or below ground after
consuming chlorophacinone, in comparison to zinc phosphide.

4.  Other observations regarding prairie dog deaths after consuming
chlorophacinone, in comparison to zinc phosphide.

II. Secondary Exposure to Non-Target Organisms 

5. Identity of predators and scavengers of Black-tailed Prairie Dogs,
and other exposed animals.

6. Observations of chlorophacinone poisoning incidents among such
animals, including chlorophacinone concentrations found in non-target
carcasses.

7. Toxicity of chlorophacinone to avian and mammalian predators and
scavengers that feed on Black-tailed Prairie Dogs.

8. The speed and frequency at which prairie dogs are expected to be
scavenged.

9. Information regarding chlorophacinone exposure pathways to the
American burying beetle and any other relevant information.

10. Other relevant data pertinent to the effects of chlorophacinone on
nontarget organisms.

 

III. Exposure to Listed Species

11. Expected co-occurrence of listed species and chlorophacinone use.

IV. Carcasses – Monitoring and Removing

12. The percentage of the overall number of target animals killed from
an application of bait that is likely to be found during carcass
searches.

13. The practicality of possible regimens for monitoring and removing
target species carcasses, including a daily search regimen.

V. Chlorophacinone vs. Zinc Phosphide

14. Relative advantages of chlorophacinone over zinc phosphide (e.g.,
cost; efficacy; and labor requirements for pre-baiting, application, and
post-application carcass removal).

15. Evidence of bait-shyness/bait-avoidance reducing the efficacy of
zinc phosphide.

16. Situations, such as particular rangeland conditions, where
chlorophacinone may be used but zinc phosphide cannot.

17. Number of acres treated with chlorophacinone and with zinc
phosphide, at the state, county or other level.

18. Effect of chlorophacinone product registrations on overall acreage
treated for prairie dogs (whether with zinc phosphide or
chlorophacinone).

VI. Alternative Management Strategies  

19. Alternative prairie dog management strategies (non-pesticidal
control techniques), such as managing the height of prairie grass (e.g.,
feasibility, effectiveness, examples, advantages and disadvantages of
such alternative strategies).

VII. Economic Impact of Prairie Dogs

20. Quantitative studies of damage to rangeland from uncontrolled
prairie dogs.

21. Evidence of improvements in forage or livestock production resulting
from use of prairie dog bait (e.g., increased weight gain by individual
animals, ability to increase stocking rates, and/or decreased
requirements for supplemental feed).

