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Cochise County
Board Supervisors
Public Programs...Personal Service
1415 Melody Lane, Building
Bisbee, Arizona 85603
520-432-9200
www.cochise.az.gov
March 20, 2017
Steve Spangle, Field Supervisor
U.S. Fish and Wildlife Service
Arizona Ecological Services Office
9828 North 31st Avenue, #C3
Phoenix, 85051 2517
Tel: 602-242-0210
Email: Jaguar_Recovery@fws.gov
RE: City Sierra Vista and Cochise County Joint Comments U.S. Fish and
Wildlife Service. 2016. Jaguar Draft Recovery Plan (Panthera onca) U.S. Fish and
Wildlife Service, Southwest Region, Albuquerque, New Mexico
Mr. Spangle:
Thank you for the opportunity submit comments the Jaguar Draft Recovery Plan
(Panthera onca) prepared U.S. Fish and Wildlife Service, Southwest Region,
Albuquerque, New Mexico, issued December 2016. The following information was
prepared behalf the City Sierra Vista and Cochise County, local governmental
agencies, with standing due being geographically located the southwestern USA
where this Recovery Plan would implemented. such, request our input
utilized full. Because this document corrects errors the Draft Recovery Plan,
request this document used part the best available science going forward.
Recommendation:
First, for reasons detailed below, request that USFWS withdraw the proposed Draft
Recovery Plan because implementation would more harm than good jaguars and the Endangered Species Act 1973, U.S.C. 1531-44 (ESA).
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Overall Process Flaws: Speculation
This Draft Recovery Plan based too little data and too much speculation.
explained detail below, the computer models used the Recovery Team map jaguar
habitat and determine recovery actions are incorrect. The first item action for USFWS
should determining how collect the necessary scientifically valid data for accurate
computer model jaguar habitat potential the USA.
Scientists agree that there breeding population jaguars the USA (FR Page
50220). Before attempts are made enhance habitat southern Arizona and southern
New Mexico that U.S. Fish and Wildlife Service (USFWS) biologists admit marginal (FR highly recommend the USFWS take step back, discard this Draft Recovery Plan
due speculation, and create plan gather the necessary data determine whether
the USA truly includes habitat that meaningful for jaguar conservation. Lack best scientific and commercial data available recommend USFWS create fact-based set data, utilizing only the best available
science, which primarily twenty-first century information. required Bennett
Spear, 520 U.S. 152, 176 (1997), USFWS must use the best scientific and commercial
data available ensure that the ESA not implemented haphazardly, based
speculation surmise. USFWS did not follow Bennett Spear when used third hand
stories jaguar kills, locations jaguars that were brought the USA from other
countries for trophy hunts, scent baited jaguar locations and other inaccurate data its
GIS habitat preference maps. Lack Quality Information and Lack Objectivity required the USFWS Information Quality Guidelines and Peer Review (Revised
June 2012), USFWS must objective.
Objectivity defined within the agency guidelines whether the disseminated
information presented accurately, clearly, and completely, and unbiased manner.
Objectivity involves two distinct elements: presentation and substance.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca) Information disseminated the FWS will presented accurately, clearly, and
completely. Information disseminated the FWS will treated unbiased fashion. scientific, financial, statistical context, will analyze the original and
supporting data and develop our results using sound statistical and research
methods ensure, the best our knowledge that our results are not subject
bias. Where potential for bias identified, the FWS will address it. The limitations the information disseminated FWS will explicitly stated.
Our concerns regarding lack science and agency biases are discussed detail below.
Lack the Necessary Scientific Report Writing Processes and
Procedures
Critical creation scientifically valid recovery plan process for evaluating data.
Computers have made cutting and pasting easy that USFWS biologists longer read
the original sources information. Instead, they search virtual library. This process
entails entering word phrase into search engine, finding results and cutting and
pasting those results into documents.
The cut and paste methodology fast and easy. However, detailed below, USFWS
biologists not read above and below the cut and paste enough evaluate the veracity the data. The original author may have qualified their statement, yet that qualitative
information lost the USWFW writing process. example, the Grand Canyon jaguar record USFWS repeatedly uses has highly
questionable, unverifiable origin. Lange (1960) reports memorandum Lockett, letter Lyndon Hargrave Goldman, dated July 14, 1943, refers female
and her two cubs being killed the Grand Canyon, probably the period, 1885-1890.
Lange provided citation pointing where the letter can located verify the
information reported. The report therefore unverifiable and unreliable. Householder
(1966) states these alleged jaguars were killed 1890 but fails cite his source.
The second part the process failure called cherry picking. USFWS chooses data
support their suppositions yet fails cite information that rebuts their opinions. USFWS
decisions are based subset data that reaffirms their original positions.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca) example, completely lacking from the Draft Recovery Plan any reference Dr.
Alan Rabinowitz 2012 Review USFWS Proposed Action Designate Critical Habitat
for the Jaguar the United States. context, per information detailed https://www.panthera.org/people/alan-rabinowitzphd
Dr. Alan Rabinowitz one the world leading big cat experts, and has been
called The Indiana Jones Wildlife Conservation TIME Magazine. Dr.
Rabinowitz graduated from the University Tennessee 1981 with M.S.
Zoology and Ph.D. Wildlife Ecology and currently the CEO Panthera.
Prior co-founding Panthera with the organization Chairman, Dr. Thomas
Kaplan, Rabinowitz served the Executive Director the Science and
Exploration Division for the Wildlife Conservation Society for almost years.
Dr. Rabinowitz has traveled the world behalf wildlife conservation and over
the years has studied jaguars, clouded leopards, Asiatic leopards, tigers,
Sumatran rhinos, bears, leopard cats, raccoons, and civets. His work Belize
resulted the worlds first jaguar sanctuary; his work Taiwan resulted the
establishment this countrys largest protected area and last piece intact
lowland forest; his work Thailand generated the first field research
Indochinese tigers, Asiatic leopards, and leopard cats, what was become
the regions first World Heritage Site; and his work Myanmar has led the
creation five new protected areas, including the countrys first marine national
park, first and largest Himalayan national park, and the world largest tiger
reserve the Hukaung Valley. northern Myanmar, Dr. Rabinowitz also
discovered new large mammal species and the world most primitive deer, the
leaf deer.
Dr. Rabinowitz has authored over one hundred scientific and popular articles and
eight books, including Jaguar: One Man Struggle Establish the First Jaguar
Preserve(1986/ 2000), Chasing the Dragon Tail: The Struggle Save
Thailand Wild Cats(1991/ 2002), Beyond the Last Village: Journey
Discovery Asia Forbidden Wilderness (2001), Life the Valley Death: The
Fight Save Tigers Land Guns, Gold, and Greed (2008), and most
recently Indomitable Beast: The Remarkable Journey the Jaguar (2014),
and children book entitled Boy and Jaguar (2014).
Dr. Rabinowitz has dedicated his life surveying the world last wild places,
with the goal preserving wild habitats and securing homes, large scale,
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
for some the world most endangered mammals. His focus cats based conserving top predators, which affect entire ecosystems. saving cats, the
impacts are far reaching and conserve vast landscapes upon which many
species depend, including humans.
One Dr. Rabinowitzs greatest achievements was the conceptualization and
implementation the Jaguar Corridor series biological and genetic
corridors for was the conceptualization and implementation the Jaguar
Corridor series biological and genetic corridors for jaguars across their
entire range from Mexico Argentina.
The USFWS biologists ignored considerable amount information provided them
Dr. Alan Rabinowitz, the foremost jaguar expert the world, because was not aligned
with their personal desire work charismatic species such the jaguar and their
person philosophy that the federal government should control more land, more water and
people the hope that will result more habitat for jaguars least for some wildlife
species general.
Though USFWS quotes some information from subset Dr. Rabinowitz work, they
repeatedly ignore other relevant information presented him. example, USFWS cites Rabinowitz (2010) relation jaguar corridors, yet
they omit his 2010 map those jaguar corridors (Figure below) because the corridors
are all south the border. dollars were spent funding the Rabinowitz (2010) study. However, only subset data from that study was reported USFWS the Draft Recovery Plan. discussed detail below, the fact that there not enough data about jaguar use land the
USA. The truth simple cannot map corridors here Arizona and New Mexico
because have too few data points. are going continue expend tax dollars jaguar management, critical
that spend the money projects that will truly benefit the jaguar.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Figure Jaguar Corridor Map from Rabinowitz Zeller (2010). Note that all Corridors are South the USA Mexico International Border
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Recommendations:
First recommend that the USFWS continue fund the use wildlife cameras
obtain scientific data regarding where jaguars are entering the USA determine whether
there are jaguar travel corridors north the International Border and so, where those
corridors occur and what can done maintain and enhance those corridors. This
wildlife camera information should used create the data base for determining
whether land within the United States can play role jaguar conservation.
Care needs taken assure the data collected unbiased manner. Bait
should NOT used influence jaguar behavior. discussed below, the fact that
Macho were lured cameras with scent makes that data useless determining jaguar
habitat preferences.
Second encourage our neighbors the south, including Mexico, Central and South
America where breeding populations jaguars exist, continue efforts conserve and
study jaguars. There areas south our International Border area where the most good
for the most jaguars can occur.
Since 2005, USFWS has helped secure financial support for on-the-ground jaguar
recovery projects Mexico, Belize, Brazil and Argentina (USFWS News Release,
January 13, 2010). Instead proposing spend over six hundred million dollars
jaguar recovery here the United States recommend USFWS work assure
money spent where will truly conserve jaguars.
The following synopsis some the more egregious errors the Draft Recovery
Plan. However, due the length the Draft Recovery Plan, not all errors, omissions,
misstatements fact and other problems are addressed herein.
All past comments from the City Sierra Vista and/or Cochise County USFWS
regarding the jaguar are herein incorporated reference.
DETAILED COMMENTS
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Recovery Plan Page ix: 2014, six critical habitat units, defined under the ESA, were designated for
the jaguar the U.S., which encompass approximately 309,263 hectares (764,207
acres) Pima, Santa Cruz, and Cochise Counties, Arizona, and Hidalgo County,
New Mexico (USFWS 2014).
Comment: agree with the 2006 USFWS critical habitat finding: summary, not find any
habitats within the jurisdiction the United States that meet the definition critical
habitat, i.e., habitats within the United States that contain the features essential for the
conservation the species and which may require special management considerations
and protection, areas outside the geographical area occupied the species that
are considered essential its conservation. Because there are areas features
essential the conservation the jaguar the United States that meet the
definition critical habitat, designation critical habitat for the jaguar not
beneficial (emphasis added). We, therefore, determine that critical habitat for the jaguar not prudent (Federal Register /Vol. 71, No. 133 /Wednesday, July 12, 2006 /Notices
39335).
Nothing has changed make this 2006 determination any less factual. Land
essential the species located south the International Border between the United
States and Mexico.
Less than percent the jaguar habitat the world the United States
(Rabinowitz 2012 and AGFD 2012 Comments Jaguar Critical Habitat). such, the
United States not essential. request USFWS use more Dr. Rabinowitz work. USFWS cites Dr. Rabinowitz
dozens times throughout the Draft Recovery Plan, however, they completely ignore his
paper titled Review USFWS Proposed Action Designate Critical Habitat for the
Jaguar the United States (2012).
Rabinowitz (2006) identified the following landscape features those that most affect
jaguar presence and movement rangewide: (1) habitat type [vegetation and
topography], (2) percent tree and shrub cover, (3) elevation, (4) human densities, (5)
human settlements and (6) roads. also commented that know what jaguars
need: occasional access water, some degree forest cover, and prey species that
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
can range from peccaries armadillos. also know that jaguars can live close
people, but they generally avoid large open areas and sites high human density. relation the Critical Habitat discussed detail Page and throughout the Draft
Recovery Plan, Dr. Rabinowitz (2012) states Not only are substantive data lacking
prove justification for this action, but the assumptions and speculations put forth
this document are, opinion, often incorrect and not the best interests
either the jaguar the people the United States (emphasis added). Furthermore,
the history this current action has been controversial, not because new, relevant
data becoming available but due litigation NGO who appear have their own
agenda. The USFWS should carefully consider why pursuing this line action and
how credible this proposed action really is.
Dr. Rabinowitz clearly, uncertain terms, states that USFWS NOT ACTING
THE BEST INTEREST THE JAGUAR (emphasis added) proposing critical habitat
for the species. This fact cannot understated. very sad commentary
federal agency entrusted implement the ESA. worries more than words can say. readers these comments will notice, the theme the authors the Draft Recovery
Plan cherry picking certain data while deliberately not citing other data common
throughout the document, thus reoccurring comment herein.
Draft Recovery Plan Page 2014, six critical habitat units, defined under the ESA, were designated for
the jaguar the U.S., which encompass approximately 309,263 hectares (764,207
acres) Pima, Santa Cruz, and Cochise Counties, Arizona, and Hidalgo County,
New Mexico (USFWS 2014). There are seven primary constituent elements
critical habitat that make the habitat features included the physical and
biological feature that meets the physiological, behavioral, and ecological needs the species. This physical and biological feature, including these seven
elements, is:
Expansive open spaces the southwestern U.S. least 100 km2 (38.6 mi2)
size, which: Provide connectivity Mexico; Contain adequate levels native prey species, including deer and javelina,
well medium-sized prey such coatis, skunks, raccoons, jackrabbits; Include surface water sources available within (12.4 mi) each other;
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca) Contain from greater than percent canopy cover within Madrean
evergreen woodland, generally recognized mixture oak (Quercus spp.),
juniper (Juniperus spp.), and pine (Pinus spp.) trees, the landscape,
semidesert grassland vegetation communities, usually characterized
Pleuraphis mutica (tobosagrass) Bouteloua eriopoda (black grama) along with
other grasses; Are characterized intermediately, moderately, highly rugged terrain; Are below 2,000 meters (6,562 feet) elevation; and Are characterized minimal human population density, major roads, stable nighttime lighting over any 1-km2 (0.4-mi2) area.
Comment: eloquently stated Dr. Rabinowitz (2012) USFWS jaguar critical habitat Having
been one the original architects this research, state now with the utmost confidence
that are doing well save jaguars throughout their existing range and that there habitat the United States this time that critical the survival the jaguar species (emphasis added).
Dr. Rabinowitz goes say:
This little more than smoke and mirrors. What
being put forth not true (emphasis added). The report continually uses assumption
and speculation fact, then uses those facts justify defining critical habitat the
United States for species which simply does not live the Unites States and has not
resided there population for least half century. The jaguar south the border
doing quite well many areas and has been shown have genetic connectivity through
designated landscape corridors. There NOTHING about the lands the U.S.
that critical the continued survival the jaguar species (emphasis
added).
The Recovery Plan fails answer the most basic tenant science:
What are the limiting factors for the jaguar?
Can the USA provide those items?
Arizona Game and Fish Department (AGFD) stated their 2012 letter opposing critical
habitat that: habitat occupied jaguars Arizona and New Mexico does not meet
the definition critical habitat described the ESA and should therefore not
designated. The United States represents less than the entire (rangewide)
habitat for the species. acknowledged the notice, recovery jaguar entirely
reliant conservation action the 99+% its habitat found south the international
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
border. The less than potential jaguar habitat the U.S.
does not and cannot contribute substantially recovery the species (emphasis
added).
Further study documenting the role Arizona jaguars play the overall population
needed before any habitat Arizona should considered potential critical habitat. this time, not biologically sound justifiable designate less than
habitat that accounts for less than 0.003 0.01% the population (emphasis
added). Moreover, Arizona and New Mexico have never been documented hold
breeding pair jaguars (emphasis added). There evidence that jaguars
Arizona and New Mexico contribute offspring the rangewide population manner
that outweighs mortality the area dispersal that they provide some other
biological benefit (e.g. novel genetic traits) for the population. Research should
conducted examine the jaguars observed Arizona and New Mexico represent
dispersal sink, where individual jaguars and their genetics are lost the population, they are fact still interacting with the nearest jaguar population (roughly 140
miles the south Mexico). agree with the analysis provided both Dr. Rabinowitz and AGFD. The United
States not critical habitat for the jaguar. The USFWS should work with our State Game
and Fish biologists and utilize the AGFD Jaguar Conservation Assessment for Arizona,
New Mexico and Northern Mexico (2011). AGFD has diligently led jaguar conservation
efforts AZ-NM since 1996.
The USFWS should also work with Dr. Alan Rabinowitz, the leading world authority jaguar conservation. Dr. Rabinowitz and AGFD both clearly oppose critical habitat
for the jaguar the United States, documented their 2012 proposed jaguar critical
habitat comments available www.regulations.gov under Docket No. FWS
2012 0042.
USFWS has access the most complete assessment jaguar conservation needs
and the arguments, pro and con, regarding the population status and critical habitat
designation controversy surrounding jaguars within the borderlands region. The best
available science found AGFD, NMDGF and Dr. Rabinowitz studies and comments the subject.
Draft Recovery Plan Page
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
The more open, dry habitat the southwestern U.S. has been characterized
marginal terms water, cover, and prey densities (emphasis added)
(Rabinowitz 1999).
The authors the Recovery Plan state that critical habitat only included areas with
adequate levels native prey species, including deer and javelina, well
medium-sized prey such coatis, skunks, raccoons, jackrabbits.
Comment:
However, Dr. Rabinowitz (2012) notes, There has been detailed prey occurrence density study cited for the areas under consideration despite recognition that adequate
prey major factor assessing critical habitat. The report assumes that optimal habitat
for jaguars the United States would the high mountain rugged areas, simply
because that where most sightings have been reported. fact, the lowlands that
jaguars and jaguar prey prefer, but they often become relegated more rugged regions
when lowland areas have been taken over destroyed. Upland areas usually have lower
prey densities and lower carrying capacities for large cats.
Draft Recovery Plan Page Assess and maintain improve the status native prey populations.
Comment:
One must ask why studies the prey base southern Arizona and New Mexico are
cited the Recovery Plan. How the authors know whether not the prey populations
need maintained improved they have data? How they know the prey
populations can improved, since they have not cited any literature science
documenting the existing prey?
One should also ask why the Recovery Plan does not address the reintroduction the
Mexican wolf the exact same acres land southern Arizona and southern New
Mexico and how that will affect jaguars and their prey. Mexican wolves eat the same prey jaguars. there enough wild prey for either one both?
Will the jaguar eat the endangered Sonoran pronghorn? The draft recovery plan for the
pronghorn proposes spending more than twenty-three million dollars pronghorn
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
recovery southern Arizona within area that overlaps the proposed jaguar recovery
area.
The existing pronghorn population already decline the Sonoran Desert. Kim
Mulhern, former Chief the Environmental and Natural Resources Division and
Environmental Officer Fort Huachuca (retired), indicated that the Arizona Game and
Fish Department approached Fort Huachuca about introducing additional pronghorn
antelope supplement the declining population that portion Cochise County. The
environmental division responded purchasing and lending radio collar AZGFD for
the purpose tracking introduced pronghorn.
The Draft Recovery Plan fails mention that the endangered Sonoran pronghorn could
become prey for the predatory jaguar southern Arizona and Northern Mexico. What will
happen the financial investment Sonoran pronghorn recovery? How will the
proposed Jaguar Recovery Plan affect pronghorn recovery?
Draft Recovery Plan Page
Contain from greater than percent canopy cover within Madrean evergreen
woodland, generally recognized mixture oak (Quercus spp.), juniper
(Juniperus spp.), and pine (Pinus spp.) trees, the landscape, semidesert
grassland vegetation communities, usually characterized Pleuraphis mutica
(tobosagrass) Bouteloua eriopoda (black grama) along with other grasses
Comment:
The USFWS ignored Rabinowitz and Arizona Game and Fish Department (AGFD)
biologists and had make iterations the jaguar habitat model and reduce vegetation one percent make the model fit their proposed critical habitat maps. explained USFWS biologist Scott Richardson, the Public Information Meeting
the Jaguar July 30th, 2013, USFWS created polygons without the necessary
requirements for the species they could connect areas where their model could
tailored fit parameters for jaguars, and then linked Mexico. The USFWS had
reduce the percentage cover one percent get polygons large enough connect each other. One percent meaningless. The agency manipulated data create
imaginary travel corridors that they cannot prove exist the ground.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Imagine your own back yard what does look like when there only vegetative
canopy cover? Arizona New Mexico, could gravel patio with palm tree
the edge. way would the patio qualify critical habitat essential the survival
the jaguar. What percent vegetative canopy would you seek you were trying stay out view, find shade from searing hot sun and find prey? would much more that
vegetative canopy.
The reason USFWS chose was connect the over 764,000 acres arid lands the
southwestern USA that they wanted label critical habitat There other reason
for using canopy cover the term meaningless. Zero percent cover would just logical not more logical.
Draft Recovery Plan Page xiii
The USFWS will consider (emphasis added) removing the jaguar from the
Federal List Endangered and Threatened Wildlife when all the following
conditions are met
Comment:
The ESA calls for preparation recovery plans for threatened and endangered species
likely benefit from the effort, and authorizes the Secretary the Interior appoint
recovery teams prepare the plans (U.S. Congress 1988). Per section 4(f)(1) the
ESA, recovery plans must, the maximum extent practicable, describe site-specific
management actions may necessary achieve the plan goals, incorporate
objective and measurable delisting criteria (emphasis added), and estimate the time
and cost required for recovery.
The Draft Recovery Plan does not contain objective and measurable delisting criteria.
Instead, states that the agency will consider removing the jaguar from the list certain
criteria are met. This and itself obviously subjective. There guarantee that
USFWS will delist the jaguar even 100% all delisting criteria are met.
The Recovery Plan needs state that certain criteria are met the agency will remove
the jaguar from the list, not just consider removing the animal from the list.
Draft Recovery Plan Page xiii
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
The USFWS will consider (emphasis added) removing the jaguar from the
Federal List Endangered and Threatened Wildlife when all the following
conditions are met:
The status the jaguar changes Least Concern (LC) and maintained under
the IUCN Red List criteria (as defined the World Conservation Union,
http://www.iucnredlist.org) for least more years
Comment:
Why USFWS deferring the IUCN the authority for determining recovery? This nongovernment organization (NGO). USFWS needs separate recovery criteria
from any IUCN wildlife lists and the affiliated politics. USFWS needs their own work determine whether not animal qualifies for listing delisting. Congress did not
delegate that authority IUCN and USFWS cannot delegate that authority IUCN.
Draft Recovery Plan Page xiv
Agency policies and regulations (including transportation), land use regulations,
and land owner agreements Mexico (emphasis added) are sufficient
Comment:
Why the USFWS committing the USA government and its taxpayers keeping the
jaguar listed the USA until Mexico has agency policies, regulations, etc. place? The
USFWS has authority dictate what Mexico does with its agency policies and
regulations. The Draft Recovery Plan too speculative regarding the delisting the
jaguar.
Draft Recovery Plan Page
Total Estimated Cost Recovery (in U.S. dollars)
The Implementation Schedule provides the estimated costs implementing
recovery actions for the first five years after the release the recovery plan.
Continual and ongoing costs, well the estimated total cost, are based the
projected timeframes recovery and delisting the species. Annual cost
estimates are follows:
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Year $2,349,000
Year $12,657,000
Year $10,301,000
Year $20,135,000
Year $10,653,000
The estimated cost implement this plan for the first years $56,093,000. The
total cost implement this plan through the year 2066, the estimated recovery
date the jaguar, $605,648,000.
Comment
USFWS should retract the Draft Recovery Plan for the Jaguar until sufficient verifiable
science available write recovery plan. agree with Rabinowitz (2012) statement that Based the paucity data and
information that are being used reverse prior rulings, due pressure from specific
NGO and the court system, can only believe that this new proposed rule declare
critical habitat for the jaguar the United States political exercise that will continue waste taxpayer funds, take valuable court time, and likely detrimental for
other endangered species that are sore need attention and funding... This
not money and time well spent (emphasis added).
Draft Recovery Plan Page
Given that the jaguar international species with the vast majority its range
outside the U.S., primary actions recover the jaguar will occur outside the
U.S.
Comment
Why would the USFWS propose spending over 600 million dollars recover species
with the vast majority its habitat outside the US? Don have species here that need
recovery?
Draft Recovery Plan Page
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
The jaguar classified Near Threatened the Red List the IUCN due number factors, including habitat loss and fragmentation populations across
portions the range (Caso al. 2008). Current levels habitat loss indicate the
species trending toward Vulnerable (IUCN category); the jaguar status
currently being reevaluated the IUCN and new analysis should available the end 2016 (Quigley, pers. comm. 2016).
Comment:
The USFWS states the jaguar endangered yet the IUCN that USFWS suggests
defer for delisting only classifies Near Threatened The reason the IUCN has
lower level concern because they assess the global situation. The USFWS looked subset facts and used speculation list the jaguar endangered. Rabinowitz
(2012) disagrees with the USFWS the status the jaguar, explained below.
Draft Recovery Plan Page July 25, 1979, the USFWS published notice stating that, although the jaguar
was originally listed endangered accordance with the ESCA, when the ESA
superseded the ESCA, through oversight the jaguar (and six other endangered
species) remained listed the List Endangered Foreign Wildlife, but
populations the U.S. were not protected the ESA (U.S. Fish and Wildlife
Service 1979). The notice asserted that was always the intent (emphasis added) the USFWS that all populations jaguars warranted listing endangered,
whether they occurred the U.S. foreign countries. The jaguar endangered
status the U.S. was therefore clarified July 22, 1997 (U.S. Fish and Wildlife
Service 1997).
Comment
The law does not consider what agency intended. What matters what the agency
did. recommend striking the statement and rationalization about intent and instead,
using facts.
Draft Recovery Plan Page
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
The probability long-term survival the jaguar considered high 70% the
currently occupied range (over million km2 [2.3 million mi2])
Comment
The USA not occupied Only occasional transient male jaguar makes its way into
the USA. The long-term survival the jaguar requires habitat south the USA. The
most meaningful jaguar conservation that taken south the USA.
Draft Recovery Plan Page
Rabinowitz and Zeller (2010) identified least-cost corridors connecting the
JCUs across the jaguar range.
Comment
What USFWS excluded from the Draft Recovery Plan was the map Rabinowitz and
Zeller (2010) that shows there are jaguar corridors the USA (see Figure above). noted Rabinowitz (2012) The fact that essentially all the wild jaguars the
world roam south the border, from Mexico Argentina, all but ignored
USFWS (emphasis added).
Draft Recovery Plan Page
While jaguars have been documented far north the Grand Canyon, Arizona,
occurrences the U.S. since 1963 have been limited south-central Arizona and
extreme southwestern New Mexico. Three records females with cubs have been
documented the U.S. (all Arizona), the last 1910 (Lange 1960, Nowak 1975,
Brown 1989), and females have been confirmed the U.S. since 1963 (Brown
and pez Gonz lez 2001, Johnson al. 2011; note the validity the 1963 record female jaguar killed the White Mountains Arizona) has been disputed see
Johnson al. 2011 for further information). result, jaguars the U.S. are
thought part population, populations, that occur largely Mexico.
Comment:
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
The Arizona Office USFWS continues its bad habit cherry picking information from
their digital library.
The problem that the information that cut and pasted taken out context. The
Draft Recovery Plan authors not read the entire scientific paper. Instead they cut
sentence out that supports premise. The sentence above below may rebut the same
premise. further exacerbate the cherry-picked literature problem, USFWS may note
the veracity some data the first time they mention the data, however, they often then
continue use that speculative unsubstantiated data throughout the document undisputable fact.
Throughout the Draft Recovery Plan, USFWS cites data fact with caveats about the
credibility. Instead, USFWS should use the following publication fact check: Literature
Review and Classification Jaguar (Panthera onca) Records from Arizona and New
Mexico
Edited Cindy Coping, Pima NRCD March 10, 2017 herein cited Coping (2017). noted Coping (2017), the Grand Canyon jaguar record has highly questionable,
unverifiable origin. Lange (1960) reports memorandum Lockett, letter
Lyndon Hargrave Goldman, dated July 14, 1943, refers female and her
two cubs being killed the Grand Canyon, probably the period, 1885-1890.
Lange provided citation pointing where the letter can located verify the
information reported. The report therefore unverifiable and unreliable. Householder
(1966) states these alleged jaguars were killed 1890 but fails cite his source.
Highly respected mammalogist, Dr. Donald Hoffmeister (1986) states Supposedly
(emphasis) female with two cubs were taken the Grand Canyon area, and female
and cub were taken the head Chevelon Creek, Coconino County. That all Dr.
Hoffmeister said about this record. important note Hoffmeister choice
preface-supposedly. also important note that Hoffmeister made citation
source, clearly signaling that this record may myth that could easily have originated
around campfire. can safely inferred that that Hoffmeister was unable locate the
alleged memorandum H.C. Lockett for verification, and least know that copy does not exist the AZGFD files.
Despite citing Hoffmeister their records, Brown and Lopez-Gonzales (2000, 2001)
omitted this Grand Canyon jaguar from their datasets, which begin only 1900. Their
incomplete examination data prior 1900 deprives the reader the knowledge that
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
jaguars were extremely rare Arizona before 1900, and misleads the reader assume
otherwise.
The Lockett memorandum the Hargrave letter cited Lange (1960) not referenced any repository citation, the information unverifiable. Additionally, Ms. Coping
was unable locate any newspaper article mentioning announcing this jaguar kill,
despite the obvious newsworthiness the unprecedented appearance lactating
female jaguar such renowned tourist attraction the Grand Canyon.
Grigione al. (2007) included the Grand Canyon jaguar account Table which
appears simply combined list reliable and unreliable jaguar sightings Arizona
and Sonora. Grigione al. (2007) misrepresents Hoffmeister (1986) the statement,
addition reports Arizona and New Mexico Game and Fish records, Hoffmeister
(1986) cites reports female and two kittens the Grand Canyon between 1889 and
1900 conclusion, the authors the Draft Recovery Plan rely unverified information fact, vastly increase the presumed historic range the jaguar North America.
This not credible science pure speculation. required Bennett Spear, 520 U.S. 152, 176 (1997), each agency must use the
best scientific and commercial data available ensure that the ESA not implemented
haphazardly, based speculation surmise. USFWS did not follow Bennett Spear
when they reported that jaguar with kittens was found the Grand Canyon the late
1800s.
Draft Recovery Plan Page
One adult male was observed and photographed March 1996, the
Peloncillo Mountains New Mexico near the Arizona border (Glenn 1996, Brown
and pez Gonz lez 2001, U.S. Fish and Wildlife Service 2014).
Comment:
Per Coping (2017), the Peloncillo jaguar was most likely Sierra Madre, Mexico jaguar.
USFWS again failed discuss fact verses speculation, violation Bennett vs. Spear.
Draft Recovery Plan Page
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca) second adult male (later referred Macho was observed and
photographed August 31, 1996, the Baboquivari Mountains southern
Arizona (Childs 1998, Brown and pez Gonz lez 2001, U.S. Fish and Wildlife
Service 2014).
Comment:
Macho was lured with the scent female jaguar scat. The data highly tainted and
should purged from the Recovery Plan.
Draft Recovery Plan Page
From 2001 2009, fourth adult male jaguar (referred Macho and the
jaguar observed and photographed 1996 the Baboquivari Mountains (referred Macho were photographed (one repeatedly) camera traps southcentral Arizona, near the Mexico border (U.S. Fish and Wildlife Service 2014).
Comment:
Per Coping (2017), Macho was lured McCain and Childs through baited with scat
from female jaguar heat obtained from zoo. Since this jaguar was secretly being
lured stay near the trail cameras set McCain and Childs, Macho cannot
considered naturally occurring. Was Macho also lured McCain and Childs? Data
collected McCain and Childs unreliable and should not used the Recovery
Plan.
Draft Recovery Plan Page
Furthermore, they were found using areas from rugged mountains 1,577
(5,174 ft) flat lowland desert floor 877 (2,877 ft) (McCain and Childs 2008).
Comment: discussed above, McCain and Childs lured male jaguars with female jaguar scat from zoo. Their data cannot reliably used state that jaguars use areas from rugged
mountains desert floors.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
USFWS needs purge all unverifiable jaguar data, including all baited planted jaguar
occurrence records, before they can begin understand jaguar science and habitat
preference.
When USFWS analyzes jaguars brought into high elevation mountainous areas for
canned hunts, number jaguar kills that only have the location the kill after days
being chased hunting dogs and jaguars lured into Arizona with female jaguar scent those jaguars choose the habitat their own, they falsify the analysis.
The Recovery Plan needs discarded rewritten. All unverifiable data, including
but not limited records jaguars from canned and/or guided hunts, records from scent
baited jaguars and records from non-credible observers, needs purged because NOT the best available data required the ESA.
The fact that USFWS failed purge the unreliable data egregious malfeasance
the part the agency. That failure has led flawed Draft Recovery Plan. Good
decisions cannot come from bad data. The bad data the Recovery Plan has been used justify over six hundred million dollars proposed federal spending. This
unacceptable. further support the notion that numerous jaguar records are from canned hunts,
circus and zoo escapees, pets that have escaped and other non-natural events, see
Cuyckens al. 2017. Figure below shows least ten more jaguar records outside
the historical range the jaguar.
Draft Recovery Plan Page
Rabinowitz (1999, supported Rabinowitz 2014) argues that although the jaguar
cannot simply considered accidental wanderer into the U.S., the
southwestern U.S. marginal habitat the extreme northern limit the jaguar
range further concludes that there indication that habitat the
southwestern U.S. critical for survival the species (emphasis added).
Comment:
The City Sierra Vista and Cochise County agree with Dr. Rabinowitz the fact that
habitat the USA marginal and not critical the survival the jaguar.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Figure Jaguars outside the known distribution range are shown with asterisk form
Cuyckens 2017.
Draft Recovery Plan Page contrast, McCain and Childs (2008) and Grigione al. (2007) argue that female
jaguars with young are proof that there was once breeding population Arizona.
Brown (1983) plotted numbers jaguars killed Arizona and New Mexico 10year intervals from 1900 1980 and argued that the decline characteristic
resident population that was hunted extinction. the jaguars killed during this
period were dispersers from Mexico, the numbers would have fluctuated
erratically, not declining pattern (Brown 1983).
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Comment:
Though USFWS acknowledges Dr. Rabinowitz, the foremost jaguar expert the world,
they discard Dr. Rabinowitz favor McCain and Childs, the jaguar trappers
that illegally lured one more male jaguars the USA with female jaguar scent.
USFWS also uses Brown (1983) that data reliable, without noting that Brown
(1983) used records when only fraction those are verifiable; therefore used too
many unverifiable records and failed inform the reader that there are zero verifiable
records pre-dating 1890 and only one record for the decade 1890-1900 and large
amount canned hunt jaguar data the data was from naturally occurring jaguars,
thus Brown work should also discredited. reliable evidence breeding jaguars has been documented Arizona New
Mexico. The only reliable evidence female jaguars Arizona data about one female each 1919 and 1949; Santa Cruz County. detailed the jaguar critical habitat
comments provided USFWS biologist Dennis Parker, any past information about
jaguars breeding within the United States was pure speculation. There indication
that jaguars will ever breed the Unites States unless the USFWS plans transplant
jaguars into our area. Prior passage the Endangered Species Act, jaguars were
brought the United States hunting guides. Though Dennis Parker only interviewed
one hunting guide, other guides were bringing jaguars the United States part their
hunting businesses. This crucial fact was omitted USFWS and several biologists cited USFWS.
Again, USFWS cherry picks prioritize the tainted data over the best available scientific
data. This ongoing behavior violates the very essence the ESA, which requires use
the best available scientific and commercial data.
Draft Recovery Plan Page
USFWS goes considerable length argue the value peripheral populations,
such jaguar
Comment:
Rabinowitz (2012) calls this simply distraction states that The U.S. has
resident jaguar population, only likely sporadic dispersers, the area the U.S. not
part peripheral population (emphasis added). Further stating that the U.S. lands
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
are important because they allow dispersers leave the Northwestern Recovery Unit
also not supported data, when the dispersers might fact returning the core
area the recovery unit. fact, more likely that the most important dispersal
corridors lay the south the Northwest Recovery Unit. the absence better data,
all the arguments this proposed action fall apart.
How can USFWS cite Rabinowitz throughout the Draft Recovery Plan every time they
agree with him and totally ignore the writings Rabinowitz they don exist, when
they are contrary the agency story? USFWS cannot have both ways. The agency
needs discuss what Rabinowitz has say, even when they disagree.
Draft Recovery Plan Page
Jaguars use medium- and large-size prey, with trend toward use larger prey distance increases from the equator (emphasis added) pez Gonz lez and
Miller 2002).
Comment:
This statement does not correlate all with the USFWS designation critical habitat
more than 2,000 miles north the equator, the USA, based small animals including
coatis, skunks, raccoons and jackrabbits (Draft Recovery Plan Page xi).
The USFWS biologists don know what jaguars would eat southern Arizona and New
Mexico. The agency used tiny little skunks and other small mammals criterion
designate critical habitat, yet the agency states scientific literature that documents
jaguars needing large prey. What large prey available the USA? Livestock? USFWS
does not cover this subject, though vital species survival.
Draft Recovery Plan Page the northern most breeding population jaguars (northeastern Sonora),
Rosas-Rosas (2006) found that large prey (22 lb)) accounted for 80% the total biomass consumed, led cattle (Bos taurus; 57% biomass), whitetailed deer (23%), and collared peccary (5%).
Comment:
The glaring lack information the Recovery Plan regarding what jaguars would eat
they were become established the southwestern USA needs addressed.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Draft Recovery Plan Page
Furtado and Filoni (2008) report the most common virus jaguars canine
distemper virus, which known cause high mortality wild felids (e.g., 30%
mortality Serengeti lions) and has also caused epizootics captive felids.
Comment:
Canine distemper virus common the International Border and spreading fast
https://www.abqjournal.com/421196/canine-distemper-spreading-fast.html.
This fact
was not addressed the Draft Recovery Plan. USFWS could endangering jaguars attempting attract them the Border.
Draft Recovery Plan Page
McCain and Childs (2008), based the use camera-traps, report one jaguar southeastern Arizona having minimum observed range 1,359 km2 (525
mi2). difficult say whether this might typical home range size for
jaguars this area due the small number locations for the animal and the
potential influence female jaguar scat some camera traps various times
throughout their research.
Comment:
McCain and Childs (2008) data tainted beyond limits for science due the use scent
bait lure the jaguars from camera camera. The McCain and Childs (2008) data
needs removed from the Recovery Planning document and analysis. The fact that
female jaguar scat was used throughout their research lure the male jaguar makes the
data illegitimate.
Draft Recovery Plan Page
Country
Location
Method
Habitat type Ind
Home range
Reference
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
United
States
Arizona
Camera
trapping
Madrean
evergreen
woodland
Semidesert
scrub
Grassland
1,359 km2
and
524.7 mi2 McCain
Childs (2008)
Comment:
USFWS knows the McCain and Childs (2008) data tainted, yet continues use valid. The Table above has asterisk next the data warn readers that the data illegitimate due the male jaguar being lured various locations southern Arizona
with female jaguar scat (see Page Draft Recovery Plan).
Draft Recovery Plan Page
Leopold (1959) speculated (emphasis added) that jaguar killed California
the 1950s had traveled more than 800 (497 mi) from its point origin
Comment
The above statement example fatal flaw throughout the Draft Recovery Plan.
The plan rote with speculation. Instead using the expert opinion Dr. Alan
Rabinowitz, USFWS cherry picks data they like better because fits their imaginary story
about how the USA essential jaguars, though experts including Dr. Rabinowitz
disagree.
Draft Recovery Plan Page
The more open, dry habitat the southwestern U.S. has been characterized marginal (emphasis added) terms water, cover, and prey densities
(Rabinowitz 1999).
Comment
The dry habitat the southwestern U.S. marginal. That means not critical
essential
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Draft Recovery Plan Page
gallery forest and forest patches were used more often than expected the basis their availability and open forest and grassland were used less than expected
Comment the USA, open forest and grassland has been characterized critical habitat for the
jaguar, even there only vegetative cover. However, USFWS notes that open
forests and grasslands are used jaguars less than expected USFWS should never
have labeled open forests and grasslands critical habitat since they know the use
low non-existent.
Since jaguars use forests, shouldn vegetative management the form fuel load
reduction important aspect the Recovery Plan? glaringly absent.
Without proper fuels management, intense fires like the Monument and Horseshoe Fires Cochise County, within areas USFWS has designated critical for the jaguar, will
continue cause long term damage soils and forests well grassland vegetation.
The best way assure healthy ecosystem with biological components necessary for
variety wildlife southern Arizona, address fuel loads. are concerned that
critical habitat designated USFWS creates government restrictions that inhibit proper
wildland management. Cochise County has excellent Community Wildlands
Protection Plan that should reviewed and added USFWS planning documents
including this Recovery Plan rewritten.
See details
https://www.cochise.az.gov/sites/default/files/emergency_services/CochiseCWPP15010
5-WebsiteReady.pdf
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Figure Map Monument Fire within the City Sierra Vista and Cochise County, where
designated critical habitat for the jaguar was lost.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Figure Photographs the damage caused forested potential jaguar habitat that had high
fuel loads that are not addressed the Draft Recovery Plan.
Figure Photographs the loss cover jaguar critical habitat resulting from human-caused
wildfire Source: https://www.azpm.org/s/14724-horseshoe-2-fire-two-years-later/
Draft Recovery Plan Page formal habitat use studies have been conducted (with the exception al. (2002) examination arroyo use) the NRU. better understand
habitat characteristics jaguars the northwestern portion their range, the
USFWS sent questionnaire 2011 scientists with experience expertise
jaguar ecology (primarily the northwestern most portion the jaguar range)
large cat ecology. The respondents included nine members the Technical
Subgroup the JRT and two other jaguar experts.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Comment:
USFWS basing their Draft Recovery Plan habitat characteristics analysis
speculation. formal habitat studies were conducted. The majority people the
Technical Subgroup work other countries. one studied the limiting factors for
jaguars the USA.
Draft Recovery Plan Page
the following features constitute high-quality habitat for jaguars the
northwestern portion their range:
High abundance native prey, particularly large prey, like deer and
peccary, and adequate numbers medium sized prey;
Water available within (6.2 mi) year round;
Dense vegetative cover (to stalk and ambush prey and for denning and
resting), particularly including Sinaloan thornscrub;
Rugged topography, including canyons and ridges, and some rocky hills
good for denning and resting;
Connectivity allow normal demographic processes occur and maintain
genetic diversity;
Expansive areas adequate habitat (i.e., area large enough support 100 jaguars) with low human density;
Low human activity, development, and infrastructure, including high speed
roads, mines, agriculture; and low jaguar persecution/poaching humans.
Comment: the Draft Recovery Plan notes, there are prey studies, though the USFWS says
that they have been working jaguar recovery since 1972, when they meant list the
jaguar. prey important, why isn being studied? Why aren competing species
such the Mexican wolf being discussed, since they eat the same prey?
Water availability from maps USFWS created for critical habitat, can quickly proven
that water private land, including livestock water tanks, was used determine that the
habitat was critical for the jaguar. How can USFWS guarantee the private water sources
will there for any length time? They can Therefore, the critical habitat mapping
used throughout the Draft Recovery Plan fatally flawed.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca) Page the Draft Recovery Plan, USFWS states that jaguars need Dense
vegetative cover (to stalk and ambush prey and for denning and resting), particularly
including Sinaloan thornscrub. Page the same Draft Recovery Plan, USFWS
arbitrarily chose vegetative cover the minimum necessary for critical habitat.
jaguars need cover not? NOT cover.
USFWS states that jaguars need rugged topography, including canyons and ridges, and
some rocky hills good for denning and resting. However, the data this assumption
based includes baited jaguars and jaguars from canned hunts where hunting guides
placed the trophy jaguar out the ground rugged terrain, brought hunting dogs
chase the jaguar tree the edge cliff trophy hunter could shoot the
trapped jaguar. Use such data the jaguar arrived that tree cliff its own
absurd. However, that the methodology used determine jaguar occupancy from
many the historical records.
USFWS states that connectivity allow normal demographic processes occur and
maintain genetic diversity necessary. Yet, USFWS had manipulate the GIS data
base the point meaningless parameters including vegetative cover, order
get connectivity. This type data manipulation produce map with connectivity not science. manipulation data make map that shows large swath
interconnected land southern Arizona and New Mexico based five, possibly six
male jaguars (Draft Recovery Plan Page 10), including least one that was proven
lured camera locations with female jaguar scat. Over 99.9% the land mapped
critical habitat has zero evidence jaguar ever setting foot there.
USFWS states that the jaguar needs expansive areas adequate habitat (i.e., area
large enough support 100 jaguars) with low human density However, they
declare southern Arizona and New Mexico critical habitat, even though these areas
not have this parameter.
USFWS states that jaguars need low human activity, development, and infrastructure,
including high speed roads, mines, and agriculture yet they declare critical habitat
areas with high and medium human activity, development and infrastructure, including
high speed roads, mines and agriculture.
USFWS says the jaguar needs certain habitat characteristics that are not present the
USA. USFWS needs re-write the Draft Recovery Plan and document the facts. The
agency cannot presume large swaths land will suddenly revert roadless areas and
become more vegetated. The agency cannot assume water private land will remain,
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
especially when that water was developed for livestock and the agency actions could
eliminate livestock production. Hard facts need incorporated into jaguar
management plans. unbiased look what really know and don know critical the analysis.
Draft Recovery Plan Page
Rangewide jaguar habitat modeling was conducted Rabinowitz and Zeller
(2010) who identified least-cost corridors connecting the JCUs across the
jaguar range.
Comment
Throughout the Draft Recovery Plan the USFWS cites Rabinowitz and Zeller (2010),
though they never provide the map displaying the jaguar corridors. Figure above,
the Rabinowitz Zeller (2010) clearly shows that ALL JAGUAR CORRIDORS are south the USA. However, USFWS fails mention this and omits the image.
Draft Recovery Plan Page
Hatten al. (2005) used Geographic Information System (GIS) model
characterize potential jaguar habitat Arizona overlaying historical jaguar
sightings landscape and habitat features believed important (e.g., vegetation
biomes and series, elevation, terrain ruggedness, proximity perennial
intermittent water sources, human density).
Comment:
USFWS failed their homework when they cited the Hatten (2005) GIS model. The
model based bad data: detailed Coping (2017), Hatten (2005) used the 1996 Warner Glenn
jaguar New Mexico their model, though Warner Glenn clearly let everyone
know that the jaguar had been chased the edge cliff the Peloncillo
Mountains his hounds. analyze habitat preference based the cliff the
jaguar ended after hounds chase that animal not good science. The Hatten (2005) GIS model also used the December 2001 Pajarito Mountain
jaguar male known Macho their model. Hatten failed even disclose the
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
fact that Macho was being baited with scat from female jaguar heat obtained
from zoo. Since these jaguars were secretly being lured stay near the trail
cameras, they cannot considered naturally occurring. Hatten (2005) included the Rincon Mountain 1902 jaguar the GIS habitat
analysis. the late Mr. Herbert Brown, Yuma, Arizona, wrote letter dated
April 1902 regarding this jaguar record: send you the photograph very interesting animal which was killed
the Rincon mountains, about twenty-five miles east Tucson, the 16th March last; was killed two Mexican scalp hunters. They were the
Rincons, above the Cebadilla, when their dogs found the trail what
appeared very large California lion. After short run the animal was
overtaken, and two dogs were killed the mix-up that followed. was finally
driven into cave, smoked out and killed. noted Coping (2017), Hatten al. (2002, 2005) used this Rincon Mountain
record their models, gave the account class rank for the physical
evidence, and gave the site description, which they identify Redington Pass,
rank for good, accuracy 1.7km-5 km. unclear, however, how Hatten al. (2005) were able determine the location with such precision based the
general description above the Cebadilla. Nonetheless, they used this account
that manner their model, thereby compromising its scientific integrity.
Draft Recovery Plan Page
Menke and Hayes (2003) conducted spatial analysis potential habitat for the
jaguar New Mexico. Because only seven jaguar reports and records from 1900 1996 have occurred New Mexico, Menke and Hayes identified positive and
negative potential habitat features for jaguars based literature sources and
evaluations from the Jaguar Habitat Subcommittee and Jaguar Scientific Advisory
Group the Arizona Game and Fish Department (AGFD)- and New Mexico
Department Game and Fish (NMDGF)-led Jaguar Conservation Team. GIS
model was used combine data layers for landscape features influencing
suitability for jaguar habitat, and create composite potential habitat map.
Comment
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Again USFWS did not verify its source data. USFWS used the Menke and Hayes (2003)
GIS model that has unreliable data: Taylor Creek, Mogollon Mountains, Grafton, Socorro County, New Mexico
1900 jaguar Barber (1902) reports: Felis hernandesii (Gray) Mr. Nat Straw,
hunter and trapper, informed that trapped jaguar near Grafton,
Taylor Creek, Socorro County, New Mexico, May, 1900. gave its length feet and inches (2439 mm.) saw the skin made into rug. have
heard several others being seen killed. probable that they find their
way into the Mogollon Mountains ascending the Gila River.
The problem with using the Taylor Creek, Socorro, 1900 jaguar record for habitat model the location not the animal natural habitat. hunter
lured the cat into trap. Without knowing where the animal was when
altered its course follow the scent the natural location the cat unknown.
The Menke and Hayes (2003) GIS model used this inaccurate data. Engle, New Mexico/Truth Consequences, New Mexico 1900 Jaguars documented Coping (2017) the scientific literature missing regarding
the story jaguar killed December 9,1900 near what today Truth
Consequences, New Mexico, and another sighted and fired upon the same
area two days later. should noted that there was train depot Engle,
New Mexico. Engle about miles east Truth Consequences. Las
Palomas was miles south Truth Consequences. This within months
and within about miles from the Taylor Creek account presented above.
The following account two kills and tracks three jaguars states that the
locals believed the three jaguars escaped from traveling show. The
Menke and Hayes (2003) GIS model used this data within doing the research
regarding veracity. USFWS made the same mistake not verifying the data. Manning Ranch, Datil Mountains, New Mexico 1903 Jaguar detailed Coping (2017) this jaguar record unverifiable and the story
was changed over time. started out 8/1902. Mrs. Manning. Bailey 1931.
Photographed Ned Hollister. Sex Manning Ranch, Datil Mts., NM.
Poisoned stock killer. Adult. Rocky Mtn Montane Conifer Forest. The
chain retelling this story goes from Manning Reddeman Hollister, three
years later, and finally years after Hollister, Bailey. such, significant
details may inaccurate possibly embellished with fiction.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
The assignment lower elevation Rocky Mtn Montane Conifer Forest habitat this jaguar Brown and Lopez-Gonzales (2000, 2001) inconsistent with
Brown and Lopez-Gonzales (2000, 2001) assigning the 1963 Penrod jaguar
kill similar elevation Rocky Mtn Subalpine Conifer Forest habitat.
also inconsistent with Bailey (1931) who assigned the kill pine and spruce
timber habitat.
The question also remains why naturally occurring jaguar and possibly
another, which were allegedly representatives discrete, resident
population, would suddenly move next humans, 9,000 feet elevation,
kill calves near the house, and then stay there until eliminated
poisoning. That this jaguar was obviously habituated human presence
evidence indicating that was very possibly neither naturally occurring nor
representative discrete, resident population. result, use this record
for modeling habitat purpose unreliable. summary since the Menke and Hayes (2003) GIS model only had seven jaguars and
three more are unreliable, the model not reliable. USFWS had duty verify data,
including the habitat models they base the Recovery Plan on.
Draft Recovery Plan Page
Robinson al. (2006) conducted another analysis potential habitat for jaguars New Mexico. Robinson al. (2006) conducted another analysis potential
habitat for jaguars New Mexico. They mapped suitable habitat based the
Jaguar Habitat Subcommittee criteria used identify jaguar habitat the U.S.,
which included: The area considered must within (50 mi) documented jaguar
occurrence. This would include entire mountain range, portion that
range within (50 mi) the occurrence. Based Brown and Lowe (1994) habitat associations, the area must the
Semi-desert Grassland, Plains and Great Basin Grassland, Subalpine
Grassland, Interior Montane Conifer Forest, Petran Subalpine Conifer Forest,
Chihuahuan Desertscrub, Arizona Upland Sonoran Desertscrub, Great
Basin Desertscrub. Areas the Lower Colorado River Sonoran Desertscrub,
Mojave Desertscrub, and Alpine Tundra are not considered jaguar habitat.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca) The area must within (10 mi) surface water, least seasonally.
Comment
What makes Center for Biological Diversity employee Michael Robinson expert the
jaguar and its habitat? stated Rabinowitz (2012) The history this proposed
action the Federal Register clearly follows repeated responses litigation brought
about the Center for Biological Diversity and Defenders Wildlife, who might have
other agendas mind and have little jaguar expertise (emphasis added).
Why this Center for Biological Diversity activist, Michael Robinson, quoted were scientist? Mr. Robinson does not have degree biology. According
http://www.biologicaldiversity.org/about/staff/ Michael Robinson Conservation
Advocate with degree literature. not scientist. What qualifies him
prepare analysis potential jaguar habitat? USFWS should not blindly quote
conservation advocates with political agendas they provide accurate unbiased
information. case point, least jaguar records used the Robinson al. (2006)
jaguar model were unreliable (Coping 2017). Many the jaguar records used
Robinson (2006) completely misrepresented the jaguar location for purposes
modeling suitable jaguar habitat New Mexico. The approach used Robinson
(2006) was both unscientific and irresponsible.
Draft Recovery Plan Page
Boydston and pez Gonz lez (2005) estimated the potential geographic
distribution jaguars the southwestern U.S. and northwestern Mexico
modeling the jaguar ecological niche from occurrence records (100 male records
from Arizona [42], New Mexico [6], Chihuahua [8], and Sonora [39] and female
records from Arizona [6] and Sonora [36]).
Comment:
Per Coping (2017), Boydston and Lopez Gonzales (2005) used four unverifiable female
jaguars modeling differences spatial preferences jaguar, the key analysis that
determined the outcome Center for Biological Diversity Kempthorne.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Draft Recovery Plan Page
Grigione al. (2009) conducted study construct blueprint priority
conservation areas for jaguars, ocelots, and jaguarundis the U.S.-Mexico border
region. This was done by: compiling reliable (i.e., Class sightings for each
species from the early 1900s 2003, conducting field surveys ascertain
species presence, and conducting GIS-based habitat mapping workshop
which scientists and conservationists provided information the distribution
and status each species. Participants were asked delineate and describe
specific areas the border region where historical and recent sightings the three
cats have occurred, resulting compilation Class jaguar sightings from
Arizona (20), New Mexico (8), and Sonora (56).
Comment: detailed Coping (2017), Grigione al. (2007) used jaguars, claiming them
highly reliable records and claiming use Girmendonk classification system. Grigione al. (2007) failed mention that these cats were likely imported and released from
cages but did improperly mention them among the total number supposedly naturally
occurring females seen Arizona. That methodology both misleading and unscientific.
Grigione al. (2007) then speculated, based part their misrepresentation this
data, that the number females taken Arizona means there was historic breeding
population jaguars Arizona.
Grigione al. (2007) used what they said was mortality Cochise County. However,
all other details were unknown and therefore the record unreliable. Coping (2017)
found corroboration this alleged jaguar occurrence any other documentation.
Without better documentation, and skin, skull unique photograph, this account
appears fabricated because was not documented anywhere else that know
outside Grigione al. (2007). The exact year this alleged jaguar occurrence
obviously not known and the entire record gives strong appearance either unreliable
hearsay impropriety. This record therefore wholly unreliable and therefore unfit for
scientifically credible modeling use.
Draft Recovery Plan Page
Sanderson and Fisher (2013) used GIS characterize potential jaguar habitat the NRU overlaying 453 jaguar observations (not 452 indicated Table
1.3 Sanderson and Fisher 2013) landscape and habitat features believed
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
important (i.e., percentage tree cover, ruggedness, human influence (as
measured the Human Influence Index, HII), ecoregion, elevation, and
distance from water).
Comment: detailed Coping (2017), the dataset used Sanderson and Fisher (2013), like other
datasets referenced USFWS form the core basis scientific input for modeling
alleged jaguar decline and suitable habitat purposes are flawed.
Jaguar presence and decline the United States since 1900 modeled Sanderson and
Fisher (2011 database) were used the USFWS identify distance water for jaguars
allegedly based the compilation 130 undisputed Class reports jaguar locations the United States since the time the species was listed. (77 161 50221). All
rely the aforementioned fatally compromised datasets for alleged scientific support.
Draft Recovery Plan Page -44
Miller (2013) reports that establishment jaguar population the Mexico and
U.S. portions Borderlands Secondary Area depends three basic aspects: demographically robust core source population Sonora, suitable habitat
northern Sonora maintain jaguars the long-term and provide key dispersal
corridors the international border, and permeable border between the
Mexico and U.S. portions the Borderlands Secondary Area.
Comment:
Miller does not mention that that there must suitable habitat the USA. Having
robust jaguar population Mexico does not mean jaguars will breed the USA. The
jaguar would need open expanses wildlands, water, prey, cover and solitude. These
attributes are not present the quantities and quality necessary for female jaguars,
evidenced the lack females here. Miller also states the border must permeable,
which may not possible, due National Security.
Draft Recovery Plan Page
This analysis suggests that conditions are not currently favorable for
establishing long-term viable population jaguars the northernmost
portion the NRU (emphasis added), most likely due low abundance
jaguars the Mexico portion the Borderlands Secondary Area, relatively low
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
levels dispersal across the U.S.-Mexico border, and habitat-mediated limitations long-term robust population growth the U.S. portion the NRU. there
specific desire facilitate such process establishment, directed attention
improving any all these limiting factors essential step achieving the
long-term goal (Miller 2013).
Comment: agree with Miller (2013) his statement that not have the conditions favorable establishing long term viable jaguar populations the northernmost portion the
NRU, which southern Arizona and southern New Mexico. The reasons the conditions
are not favorable include lack natural water sources, potential inadequate prey base,
arid climate, arid vegetation, number people and roads, well existing conflicting
land uses.
Most limiting factors are outside the control USFWS. These limiting factors are
absent from areas where breeding jaguars are abundant.
Draft Recovery Plan Page
Brousset and Aguirre (2007) proposed implement standard protocol for the
health evaluation wild jaguar populations Mexico diseases can devastate
wild carnivore populations, and their effects jaguars should carefully
monitored. diseases are found affect jaguar populations, steps should
taken address this threat.
Comment:
Why does the Recovery Plan discuss ten-year-old proposal implement protocol
Mexico and after the fact solutions diseases? now the USA and Mexico should
have protocols place ensure wildlife species including jaguars are protected from
canine distemper, rabies and other communicable diseases.
Draft Recovery Plan Page
Rosas-Rosas and Valdez (2010) reported that jaguar habitats were degraded and
conflicts between jaguars and human interests were common Sonora.
Furthermore, they reported that habitat fragmentation and illegal hunting jaguars
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
and their potential prey species are probably the main threats long-term
conservation jaguars their northernmost western range.
Comment:
USFWS discusses threats Mexico yet fails mention that jaguars are bought, sold and
traded Mexico. Though jaguars are species listed PROFEPA danger
extinction, according https://news.vice.com/article/its-basically-legal-for-mexicannarcos-to-buy-lions-cheetahs-and-other-exotic-pets jaguars are legally available they
come from accredited breeders. can get you jaguar cub for about $4,650 $5,230 (80,000 90,000 pesos), said
the owner breeding center that houses pure-bred domestic animals spacious,
secluded property just outside Guadalajara. Showing off images jaguar his phone,
the breeder told VICE News has also sold monkeys, pythons, panthers, and tigers,
with the last tiger cub going for $5,800 (100,000 pesos) about six months ago.
The vendor only brings exotic species upon receiving advance orders, but insisted
they all have the necessary permits, though declined disclose their origins.
Given the minimal regulation Mexico, many animal rights campaigners are more
focused ethics than legal technicalities.
Draft Recovery Plan Page
The recovery criteria this plan are not binding, and important note that
meeting the recovery criteria provided below does not automatically result downlisting delisting the species (emphasis added). Downlisting and
delisting decisions are under the authority the USFWS Director and must
undergo the rulemaking process and analyses.
Comment:
According section 4(f)(1) the ESA, recovery plans must, the maximum extent
practicable, describe site-specific management actions may necessary achieve
the plan goals, incorporate objective and measurable delisting criteria, and estimate the
time and cost required for recovery. not believe the Draft Recovery Plan meets section 4(f)(1) the ESA. The
exclusions that make the recovery criteria within the plan not binding negate the intent create actions may necessary achieve the plan goals. The fact that USFWS
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
states that meeting the recovery criteria does not automatically result downlisting delisting the species negates the Congressional directive section 4(f)(1)
incorporate objective and measureable delisting criteria. essence, matter what done and matter how much money spent, whether the
jaguar will ever downlisted delisted purely subjective, based the whim the
USFWS Director. The USFWS has made jaguar recovery too subjective. believe
they did because they not have the data necessary objective.
Draft Recovery Plan Page
The status the jaguar changes Least Concern (LC) under the IUCN Red List
criteria (as defined the World Conservation Union, http://www.iucnredlist.org/)
Comment:
Under what authority USFWS allowed delegate its duties the Switzerland based
World Conservation Union founded Julian Huxley? This appears abrogation Congressional authority.
Draft Recovery Plan Page
Agency policies and regulations (including transportation), land use regulations,
and land owner agreements Mexico are sufficient ensure that landscape
permeability will maintained for jaguars within the Sinaloa Secondary Area
Comment:
Where the ESA does state that USFWS can delegate its power another country
set policies and regulations that control whether not animal delisted within the
USA? The fact that USFWS wants Mexico use hammer instead carrot approach jaguar management troublesome. Solving the underlying social issues Mexico
would more help the jaguar than policies and regulations about landscape
permeability.
Draft Recovery Plan Page
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca) not currently have baseline occupancy information for these Areas;
therefore, not know the level occupancy necessary for jaguars
(emphasis added) the NRU.
Comment:
Another significant flaw the Draft Recovery Plan the use 60% occupancy certain
areas delisting criteria. Since the agency does not have baseline occupancy data, impossible measure change. area has 100% occupancy now, the 60%
occupancy criteria would 40% reduction. There nothing measure the 60%
against. Until there baseline data, percent occupancy criteria are meaningless.
Draft Recovery Plan Page not know gene flow currently occurs between the Core Areas.
Comment:
The amount unknown data significant. Encouraging other countries want
understand the genetics the jaguar for conservation takes different approach that
offered the Draft Recovery Plan. Third world countries with poverty and hunger issues
need help make cultural shifts that benefit people that those same people will want conserve their natural resources. This philosophical shift away from regulations that
punish people for basic survival activities toward win:win approach will more save
jaguar habitat the long term.
Draft Recovery Plan Page
Agency policies and regulations (including transportation), land use regulations,
and land owner agreements the U.S. and Mexico are sufficient ensure that
landscape permeability, including two more trans-border linkages (as described
above criterion 1.B.iv, above) will maintained for jaguars throughout the
Borderlands Secondary Area. (Factors
Comment:
Please describe the regulatory authority USFWS has dictate trans-border linkages
through Recovery Plan?
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Draft Recovery Plan Page
Individuals dispersing into the Borderlands Secondary Area are important
because they occupy habitat that serves buffer zones regular
reproduction and are potential colonizers vacant range, thereby maintaining
normal demographics, well allowing for possible range expansion (U.S. Fish
and Wildlife Service 2014). Additionally, populations the edge species
range, such those the NRU, play role maintaining the total genetic
diversity species; some cases, these peripheral populations persist the
longest fragmentation and habitat loss impact the total range (Lomolino and
Channell 1995, 1998; Channell and Lomolino 2000). The NRU essential for the
conservation the species; therefore, consideration the spatial and biological
dynamics that allow this unit function and that benefit the overall unit prudent.
Providing connectivity between the U.S. and Mexico key element
maintaining those processes (U.S. Fish and Wildlife Service 2014). Therefore,
trans-border connectivity the Borderlands Secondary Area important
component jaguar recovery the NRU.
Comment:
Per Rabinowitz (2012) The jaguar south the border doing quite well many areas
and has been shown have genetic connectivity through designated landscape
corridors. There NOTHING about the lands the U.S. that critical the
continued survival the jaguar species. When the report discusses the potential
importance peripheral populations the genetics species, this simply
distraction. The U.S. has resident jaguar population, only likely sporadic
dispersers, the area the U.S. not part peripheral population (emphasis
added). Further stating that the U.S. lands are important because they allow dispersers leave the Northwestern Recovery Unit also not supported data, when the
dispersers might fact returning the core area the recovery unit. fact,
more likely that the most important dispersal corridors lay the south the Northwest
Recovery Unit. the absence better data, all the arguments this proposed action
fall apart.
Draft Recovery Plan Pages 116
4.2. Recovery Action Outline and Narrative
and
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
5.1 Responsible Parties and Cost Estimates
The value this plan depends the extent which implemented; the
USFWS has neither the authority nor the resources implement many the
proposed recovery actions throughout the species range outside the U.S. The
recovery the jaguar dependent upon the voluntary cooperation many other
organizations and individuals who are willing implement the recovery actions.
The implementation schedule identifies agencies and other potential responsible
parties (private and public) help implement the recovery this species. This
plan does not commit any responsible party carry out particular recovery
action expend the estimated funds. only recognition that particular groups
may possess the expertise, resources, and opportunity assist the
implementation recovery actions. Although collaboration with private
landowners and others called for the recovery plan, one obligated this
plan any recovery action expenditure funds. Likewise, this schedule not
intended preclude limit others from participating this recovery program.
Comment:
Since the vast majority these actions need occur south the International Border,
who going fund the recovery plan? That not clear the current draft.
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
Draft Recovery Plan Page 142
Number
1a,
4.2.
Action
Numbe
Establis
improve,
enforce,
and/or
fund
impleme
ntation laws
and
procedu
res
protect
jaguar
habitat.
Cost Estimate
(by $1,000s)
3.3.1.
B.i.vi;
3.3.2.
B.i.vi.
Con
tinu
ous
PROFE
PA;
PGR;
Local,
State,
and
Federal
Legislat
ures;
AGFD;
NMGFD FWS;
All
71,54
Comments
Costs
for
improving
enforcement existing
laws are based
adding minimum
additional
PROFEPA
agents per Core and
Secondary Area the
NRU Mexico (24 total
additional agents), plus
transportation,
communications,
and
equipment. Costs for
establishing
and
improving
laws
are
included action 6.3.
below.
Comment:
The current Draft Recovery Plan written from narrow, traditional point view.
Spending over seventy one million dollars enforcement existing laws the usual
stick instead the carrot. time change more inclusive twenty first century
approach.
Conclusion:
The Draft Recovery Plan based flawed science and paucity verifiable data.
request the USFWS purge all unverifiable data and isolate the hard facts. USFWS needs work with AGFD collect more detailed data about jaguar use the USA. The
USFWS should continue encourage other countries the same.
Most jaguar habitat third world countries where necessities including food, water and
shelter for people are not being met. For jaguar conservation efforts truly successful cultural and economic shift necessary the countries with key habitat.
Over the next thirty years, USFWS can more for jaguars stepping back and
encouraging other countries and large cat conservation organizations develop
comprehensive approach that includes biological field research, the identification local
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca)
human interests, and growing recognition the need for cooperation across political
lines. The USFWS needs more fully appreciate the contributions far less developed
countries instead attempting police the globe. More can done maintain and
restore populations jaguars including the human element than encouraging other
countries emulate our overly negative regulatory big government approach.
USFWS might want take look the playbook the Cheetah Conservation Fund.
The Founder and Executive Director that organization, Laurie Marker, said
training network regional professionals collaborating regional cheetah strategies,
the impact would expand from local pockets protection dotting the cheetah range
countries much broader, far-reaching and inter-connected swaths Regionalising (sic)
and unifying efforts will cause the conservation impact exponential, she said
(https://bigcatrescue.org/ccf-leads-the-way-in-cheetah-management/).
USFWS and
other organizations may want consider getting involved very different level. seems time for shift toward addressing the needs people, sustainable food
production, the role conservancies achieving conservation goals, integrated food
management practices, and the varying cultural and social parameters. Isolated single
species management practices have not worked the past and will not work here.
USFWS and their partners may want speak local subsistence farmers humanwildlife conflict issues areas with jaguars begin understand the real issues.
Endangered species are threatened partly because people are starving, and people are
starving partly because nobody protecting them from criminals, warlords soldiers.
All the ivory tower esoteric planning the world will very little for the jaguar until the
solution includes the people where the animals live. When the jaguar longer seen competitor for food lucrative object sell, real progress can made. recommend very different approach jaguar recovery that involves the people
the ground the areas where jaguars live and thrive. Spending over six hundred million
dollars help the people help themselves will more for the jaguar than the steps
recommended this Recovery Plan.
Thank you for the opportunity comment.
considered. sincerely hope that our efforts are
City Sierra Vista and Cochise County Joint Comments U.S. Fish and Wildlife
Service. 2016. Jaguar Draft Recovery Plan (Panthera onca) Behalf The City Sierra Vista and Cochise County
Mary Darling
Natural Resource Consultant