Part 3 of 8: The State Wildlife Action Plan: Creating Pressure on Ranchers
An investigation by High Country Advocate
CPW’s State Wildlife Action Plan: Whose Interests Does It Serve?
Colorado Parks and Wildlife presents its State Wildlife Action Plan as objective science—a careful assessment of which species need conservation attention. But when you examine who sits on the CPW Commission, where conservation priorities cluster geographically, and which organizations benefit from implementation, the picture becomes less scientific and more political.
The Official Framework
Every state must maintain a State Wildlife Action Plan to receive federal State and Tribal Wildlife Grants. Since 2000, these grants have Colorado’s participation in this program requires maintaining an approved SWAP, making federal funding contingent on priorities that may not reflect balanced state interests. distributed over $1.4 billion nationally to state wildlife agencies. Colorado submitted its latest SWAP in September 2025, identifying Species of Greatest Conservation Need—wildlife facing population declines or habitat threats. The plan designates 55 Tier 1 species as highest priority.
CPW correctly emphasizes that SWAP designation is non-regulatory. Unlike Endangered Species Act listing, SWAP creates no legal restrictions on land use. Ranchers cannot be legally compelled to stop prairie dog control because SWAP identifies ferrets as a conservation priority.
But this misses how policy actually works. SWAP determines which species receive funding priority, which landscapes become conservation focus areas, and which landowners find themselves operating in zones where informal pressure—through cost-share program eligibility, conservation organization land purchases, and lease renewal decisions—creates economic incentives to abandon traditional agricultural use. The question isn’t whether SWAP imposes legal mandates. It’s whose interests the plan serves when implemented.
Prairie Dogs, Ferrets, and the Agricultural Squeeze
Prairie dogs create economic problems for ranchers statewide. Large colonies consume forage that could support livestock and create hazards for cattle and equipment. They’ve overtaken former federal facilities like Rocky Mountain Arsenal, proliferate along state roadsides, and expand across public and private lands throughout Colorado. Multiple prairie dog species now appear in SWAP as Species of Greatest Conservation Need.
The black-footed ferret—a Tier 1 SGCN—depends entirely on prairie dog colonies for survival. Historically, ferrets ranged across the entire Great Plains from southern Canada to northern Mexico. In Colorado, CPW has released ferrets in Baca, Prowers, Pueblo, Larimer, and Denver counties.
For ranchers in SWAP-designated ferret recovery areas, this creates an impossible situation: control prairie dogs and face criticism for harming conservation species, or tolerate expanding colonies and watch ranch productivity decline. Federal cost-share programs for prairie dog control become unavailable in ferret recovery areas. Conservation organizations purchase adjacent properties and protect prairie dog colonies that expand onto working ranches.
Much of Colorado ranching depends on federal and state grazing leases; most ranchers cannot afford to own all necessary land. When the State Land Board decides grazing conflicts with SGCN habitat, lease renewals are denied. No due process. No compensation. Just economic pressure that eventually forces sales. The designation creates what might be called a “conservation trap”—ranchers cannot control prairie dogs without facing criticism for harming conservation species, yet tolerating expanding colonies means watching ranch productivity decline. Either choice leads to economic pressure that eventually forces sales to conservation organizations operating with substantial public funding.
The pattern extends to grassland bird priorities—Mountain Plover, Long-billed Curlew—all theoretically benefiting from reduced grazing pressure. Who developed these priorities? CPW biologists workingAgricultural voices exist in public comment processes but are systematically marginalized compared to urban environmentalists whose daily lives remain insulated from the economic consequences of these policy decisions. While ranchers bear direct financial impacts from SWAP priorities, they represent a numerical minority in formal comment periods dominated by conservation advocates. When the $47 billion Colorado agricultural industry—employing 195,000 people—finds itself systematically excluded from priority-setting for wildlife policy that directly affects agricultural viability, calling this “balanced management” strains credibility.
The Conflict of Interest Problem
The composition of Colorado’s wildlife governance structure raises significant questions about objectivity and conflicts of interest. In 2020, Governor Jared Polis appointed Jay TutchtonTutchton also works as Preserve Manager for the Southern Plains Land Trust, whose explicit mission involves purchasing ranchland in southeastern Colorado, eliminating grazing, and “rewilding” prairie. SPLT operates in Baca and Bent Counties—precisely where SWAP identifies prairie dogs, black-footed ferrets, and grassland birds as conservation priorities.
Tutchton sits on the Commission setting CPW priorities while employed by an organization that directly benefits when those priorities identify southeastern Colorado as critical habitat requiring landscape-scale conservation. SPLT currently protects over 60,000 acres, with its largest property—Heartland Ranch Nature Preserve at 43,000 acres—located in Bent County where SWAP priorities cluster. These acquisitions concentrate in counties where SWAP designates critical habitat for prairie dogs, black-footed ferrets, and grassland birds. The geographic alignment between SWAP priorities and SPLT land purchases is not coincidental—it represents systematic policy implementation where public priorities justify private conservation acquisitions.
The funding mechanisms reveal deeper structural issues. Tutchton and Dan Gibbs, Director of the Department of Natural Resources (CPW’s boss). GOCO provides grants to Southern Plains Land Trust. The money flows: public lottery funds → GOCO (where Tutchton sits on the board) → SPLT (where Tutchton works as staff).
Does this constitute corruption? Not in any criminal sense. These are public appointments, documented relationships, legal grant distributions. But it represents a structural conflict of interest that undermines SWAP’s claim to objectivity. When commissioners work for organizations benefiting from the priorities they help establish, when public funds flow to those organizations through boards where commissioners serve, the distinction between conservation policy and organizational advancement blurs considerably.
Nicole Rosmarino’s appointment as State Land Board Director adds another dimension. Rosmarino co-founded WildEarth Guardians, served as Polis’s wildlife adviser during wolf reintroduction, and wrote for the Great Plains Restoration Council—an organization explicitly promoting “Buffalo Commons” transformation of Great Plains landscapes. As State Land Board Director controlling 2.8 million surface acres, Rosmarino can shift state lands from grazing to conservation uses. Since taking control, her board has already begun this shift. In October 2025, she approved Colorado’s first biological carbon lease—a 480-acre project near Alamosa claiming 10,000 tons of CO₂ sequestration that independent analysis suggests will achieve only 13% of that projection. The lease generates $720 annually for schools compared to $1,500-2,000 a comparable grazing lease would provide, but removes land from agricultural potential for 40 years. This pattern—sacrificing school funding and agricultural use for dubious environmental claims—demonstrates how ideology shapes policy implementation across multiple agencies. Rosmarino can shift state lands from grazing to conservation uses.
The pattern: Polis appoints Tutchton (CPW Commissioner working for rewilding organization). Polis appoints Rosmarino (State Land Board Director with Buffalo Commons connections). Both influence wildlife and land policy affecting southeastern Colorado. Both positioned to implement landscape transformation without explicit legislation requiring public debate.
The Larger Pattern
The Comanche National Grasslands tell a revealing story. During the 1930s Dust Bowl, the federal government purchased over 4.7 million acres of failed farmland in Baca, Otero, and Las Animas Counties. The government bought land from bankrupt farmers, replanted native grasses, and in 1960 established what is now 443,000 acres of Comanche National Grasslands. This was the original “rewilding.”
Now examine where SWAP priorities cluster: Baca and Bent Counties. Where does Southern Plains Land Trust operate? Baca and Bent Counties, directly adjacent to Comanche National Grasslands. Add Aurora Water’s 22,000-acre acquisition removing both land and water from agricultural use. Add Ogallala Aquifer depletion creating economic pressure on farming. Add SWAP priorities making ranching increasingly difficult. Multiple pressures converge on the same landscape simultaneously.
SWAP supporters will object that prairie dogs and ferrets face legitimate conservation challenges, that grassland birds warrant protection, that science demands attention to imperiled species. This objection has merit. Black-footed ferrets are genuinely endangered. Prairie ecosystems genuinely declined. The conservation concerns are real.
But real conservation needs don’t explain why commissioners work for organizations benefiting from conservation priorities. Real science doesn’t explain geographic concentration of SWAP focus where rewilding organizations operate. Legitimate species recovery doesn’t explain why public money flows to organizations led by state appointees. Valid ecological concerns don’t explain agricultural community exclusion from priority-setting.
What This Means
Colorado agriculture generates $47 billion annually across 30 million acres supporting 195,000 jobs. Southeastern Colorado’s ranching heritage spans generations—families who survived the Dust Bowl, who adapted to changing conditions, who maintained working landscapes through dedication and skill.
CPW should serve all Coloradans—urban and rural, conservation-minded citizens and agricultural producers.
The State Wildlife Action Plan isn’t neutral science. It’s a policy document serving specific interests. When you examine the conflicts of interest, follow the money, and map the geographic priorities, those interests become clear: not the agricultural communities whose land and livelihoods are targeted, but the political appointees and conservation organizations implementing a vision of landscape transformation that rural Colorado never agreed to.
This investigation continues with detailed examination of the political appointment network, Southern Plains Land Trust’s operations and funding sources, Aurora Water’s acquisition strategy, Ogallala Aquifer crisis implications, Rocky Ford’s economic collapse, and comprehensive analysis of Buffalo Commons implementation across southeastern Colorado.
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