Proposed Jaguar habitat in Arizona and New Mexico is scientifically and legally indefensible

JaguarA new report from the Pima Natural Resource Conservation District (PNRCD) shows that the proposal by the U.S. Fish & Wildlife Service (FWS) to designate Critical Habitat for the jaguar under the Endangered Species Act (ESA) is scientifically indefensible because it is based on flawed data, and it violates laws such as the Data Quality Act.

PNRCD requests that FWS withdraw its proposed rule “because habitat ‘essential’ to the conservation of the jaguar as a species does not exist in either Arizona or New Mexico under any scientifically credible definition of that term, because designation of critical habitat therein cannot possibly help save jaguars, and because the economic consequences of adding yet another layer of regulation and restriction on national security, resource production, water use, hunting and recreation during the worst recession on record since 1929 far outweigh any possibly discernible benefit to jaguars as a species that might be gained by designating critical habitat for them north of the Mexican border where they are but rarely transient…”

See report and supporting material at:

Some highlights:

For Critical Habitat to be established under ESA, the FWS must show that the area in question is essential to the jaguars conservation and survival as a species, not merely whether the area in question could host or has hosted individual, transient jaguars.  “Contrary to the claim of the Service in this proposed rule, recent, documented sightings of four or five individual jaguars on singular occasions, two of which occurred over a decade and a half ago, are not scientific evidence of current jaguar residency in or occupancy of the United States for purpose of critical habitat designation. Nor are these sightings scientific evidence that such brief, male-only transience represents use of habitat by jaguars essential to their collective existence or conservation as a species because the jaguar’s breeding range spans two continents, ends in northern Mexico, and the jaguar’s actual epicenter of abundance is located in South America.”

 The study shows how FWS is using opinion of so-called jaguar experts rather than hard data.  This goes counter to the requirements of ESA which states that design of Critical Habitat much be based on the best scientific data available rather than upon concepts and principles of conservation biology which rely on assumptions.

 The study examines reports of jaguar sightings in Arizona and New Mexico and shows why they do not meet the standards of scientific evidence of “essential” habitat.  The study documents that several jaguars were transported into the U.S. for the purpose of big game hunts and “seeding” a population for future hunts.  Jaguar sightings can be attributed to some of these jaguars rather than natural ranging of jaguars.

 The study also alleges that  false and mis-representative statements, published in the  2011 Arizona Game & Fish Department Jaguar Conservation Assessment, have been used by FWS to form a basis for Critical Habitat designation.

 The study shows FWS “misrepresents the distribution of jaguars within the United States by erroneously claiming that jaguars once occurred as far north as Santa Fe, New Mexico.”  PNRCD shows, however, that FWS errs in its attribution because the claim is actually based on a jaguar sighted near Santa Fe, Argentina, and not from New Mexico or the North American continent at all.

 The PNRCD study notes that “The premise that resident populations of jaguars existed in Arizona and New Mexico before 1900 is unsupported by the scientific record, and the scientific record of jaguars killed in Arizona and New Mexico after 1900 is fraught with discrepancies, inaccuracies, duplications and unreliability.”  The study also notes “that neither Padre Kino nor Juan Mateo Manje make any mention of jaguars in what is today Arizona despite their many entradas into southern Arizona conducted during the late 1600s and early 1700s, and when it is also considered that the Spanish offered no bounties on jaguars, ever, in what is today Arizona and New Mexico, respectively.”  If a natural population of jaguars  existed in Arizona in the early days, one would think that someone would have taken note.

 PNRCD provides thorough review of the historic records of jaguar occurrence for Arizona and New Mexico. As the PNRCD’s review clearly reveals, many of those records heretofore assumed by all researchers to be accurate and reliable are, in fact, both inaccurate and unreliable.  Moreover, this review found that ten fatal flaws compromise the scientific integrity of both the characterization of those records by editors, researchers and the Service to date, and, all conclusions and models of alleged suitable jaguar habitat and residency based on the use thereof.

 These ten, fatal scientific flaws are:

1) Use of inaccurate and unreliable records.

2) Reliance on the unfounded assumption that all recorded natural history of jaguars in Arizona and New Mexico began in the year 1900.

3) Reliance on and propagation of the false assumption that all sightings of jaguars in Arizona and New Mexico are of “naturally occurring” animals when many were actually of foreign origin and imported and released by humans for hunting purposes.

4) Failure to examine primary records and adequately verify cited data and literature for accuracy (an universal error).

5) Failure to present the specific dataset used in the model.

6) Failure to cite data sources or other sources for specific records.

7) Speculation that the location where a jaguar was killed, or in some cases where it was first sighted in the United States, somehow represents its preferred natural habitat.

8) Failure to acknowledge the existence of data rejected or omitted, and failure to explain why certain data was rejected or omitted when the reason is neither obvious nor apparent to the reader.

9) Failure to identify a specific jaguar in an occurrence record.

10) Failure to properly verify the data to prevent according duplicative records to the same jaguar.

 The last part of the PNRCD study shows how the FWS proposal fails to conform to the law in designating Critical Habitat for the jaguar.

See also:

Jaguar Listing and Habitat Designation Based on Junk Science

Jaguars versus the Rosemont mine


  1. The Pima Natural Resource Conservation District is nothing more than natural resource users, exploiters of public lands. The Board members are as follows:

    Andrew McGibbon, Chairman – RANCHER

    John W. King, Vice Chairman –

    Stuart Bengson, Supervisor – MINER

    Cynthia Coping, Supervisor – RANCHER

    James Chilton, Supervisor – RANCHER

    Their position opposing the USFWS designation of jaguar habitat for the purpose of assisting the survival of this endangered species is an expected political position. It’s nothing more than a bunch of cowboys and miners trying to continue profiteering off public land.

    I just bought a used copy of a great book titled “Welfare Ranching: The Subsidized Destruction of the American West”. The book points out that “Livestock grazing in the arid West is as outmoded as is whaling in today’s oceans.” Check out this great book:

    It’s time to get our country out of the business of subsidizing livestock grazing on public land for the betterment of those public lands by stopping the ecological disasters that livestock grazing has imposed on our national treasures. It is time to protect jaguar habitat by supporting the Center for Biological Diversity in its litigation to force the USFWS to comply with law and do the right thing for jaguar.

    1. The best stewards of the land are those who have an economic interest in keeping it healthy, i.e., ranchers.

      1. Public lands have been overgrazed and abused by the livestock industry for decades. Killing apex predators is also a detriment to wildlife habitat, because it allows wild herbivore populations to explode and denude vast areas. The grazing lease fees on public land are way lower than lease fees on private lands. Ranchers support politicians who are notorious for their anti environment positions in Congress.

      2. Okay, Jonathan. Sorry for writing that your statement that ranchers keep land healthy was no more than male cow dung. I should not have used those vulgar words, particularly three times, even though your notion that ranchers are good stewards of public land is grossly offensive.

        Just because a group has an economic interest in something is NOT indicative of ethical and effective conduct.

        Consider the health insurance industry’s economic interest in health care. That industry’s conduct and policies regularly kill people by focusing on profit.

        Similar result as ranchers on public land. Ranchers regularly kill wildlife habitat on public land with the range maggots they place on grazing allotments that they lease at rates below market value.

    2. The “anti’s” cannot scientifically defend the proposed critical habitat rule. Therefore, they are attempting to change the subject by attacking and demonizing ranchers and miners.

  2. I notice that Ricardo didn’t try to argue the science and in regard to grazing, there is plenty of science showing the benefits of grazing on the health of the range. So Ricardo, since you seem science deprived here is some of the science those cowboys and miners have on their side:

    Citations to Publications Showing Benefits of Controlled Grazing and Selected Publications Relating to Riparian Habitat, Native Fishes and Political Ecology
    Anderson, E.W. and R.J. Scherzinger. 1975. Improving quality of winter forage for elk and by cattle grazing. J. Range Management 28-2-7.

    Anderson, M.C. 2009. Livestock And Elk Grazing Effects On Stream Morphology, Brown Trout Population Dynamics, Movement, And Growth Rate, Valles Caldera National Preserve, New Mexico. Master of Science Thesis, New Mexico State University, Las Cruces,

    NM.Bayley, P.B. and H.W. Li. 2008. Stream Fish Responses to Grazing Exclosures. North American Journal of Fisheries Management 28: 135-147.

    Bock, C.E., J.H. Bock, W.R. Kenney and V.M. Hawthorne. 1984. Responses of birds, rodents and vegetation to livestock exclosure in a semidesert grassland site. J. Range Management 37: 239-243.

    Bristow, K.D. and R.A. Ockenfels. 2000. Effects of human activity and habitat conditions on Mearns quail populations. Arizona Game and Fish Dept. Res. Tech. Guidance Bull. No. 4, Phoenix, AZ.

    Brodhead, K.M., Stoleson, S.H. and D.M. Finch. 2007. Southwestern Willow Flycatchers (Empidonax Trailli Extimus) In A Grazed Landscape: Factors Influencing Brood Parasitism. The Auk 124(4): 1213-1228, 2007.

    Curtin, C.G. 2005. Landscape-Level Impacts of Livestock on the Diversity of Desert Grassland: Preliminary Results From Long-Term Experimental Studies. U.S. Forest Service Proceedings RMRS-P-36.

    Davies, K.W., Svejcar, T.J. and J.D. Bates. 2009. Interaction of historical and nonhistorical disturbances maintains native plant communities. Ecological Applications: 19(6): 1536-1545.

    Donahue, D. 1999. The Western Range revisited: Removing livestock from public Lands to conserve nation biodiversity. University of Oklahoma Press, Norman, Oklahoma. 352 p.

    Fleming, W., D. Galt and J.L. Holechek. 2001. 10 steps to evaluate rangeland and riparian health. Rangelands 23(6): 22-27.

    Guretzky, J.A., K.J. Moore, C.L. Burras and E.C. Brummer. 2007. Plant species richness in relation to pasture position, management, and scale. Agriculture, Ecosystems and Environment 122 (2007) 387-391.

    Holechek, J.L., M. Thomas, F. Molinar and D. Galt. 1999. Stocking desert rangelands:what we’ve learned. Rangelands 21(6): 8-12.

    Holechek, J.L., T. Baker and J. Boren. 2004. Impacts of controlled grazing versus grazing exclusion on rangeland ecosystems: what we have learned. Range Improvement Task Force Report No. 57, 44pp. New Mexico State University, Las Cruces, NM.

    Jackson, R.D., Allen-Diaz, B., Oates, L.G. and K.W. Tate. 2006. Spring-water Nitrate Increased with Removal of Livestock Grazing in a California Oak Savanna. Ecosystems 9: 254-267.Knight, R.L. 2007. Ranchers as a keystone species in a West that works. Rangelands29(5): 4-9.

    1. I am not spending the time to go through your whole bibliography, J.D. However, I did spot check one entry, the one by Bristow & Ockenfels, because I am intimately familiar with Mearn’s quail populations. Some years ago I completed a field study of availability of Mearn’s quail foods in grazed vs ungrazed plots in and around Fort Huachuca. I doubted that Bristow & Ockenfels would have data that support your notion that grazing is good for Mearn’s quail. In fact, Bristow & Ockenfels write: “…in years of poor grass production, even light use by cattle may reduce grass height below the level needed by Mearns’ quail …” That’s science! And, check out the extensive bibliography in a book titled “Welfare Ranching: The Subsidized Destruction of the American West” There’s a great deal of science in that book, too. I’ve seen photographs of what the San Simon Valley looked like BEFORE it was destroyed by overgrazing. The livestock industry advocated spraying herbicide on public land to remove shrubby species of vegetation in a futile and poisonous attempt to encourage growth of grasses & forbs for domestic livestock. That herbicide, back in the 1960s was agent orange. The livestock industry introduced buffelgrass for domestic livestock forage. That invasive species of grass chokes out native plants, including Sonoran desert cacti. So, the factual evidence I have first hand knowledge of … the science … certainly disproves your suggestion that the best stewards of public land are those who have an economic interest in it. I call quadruple male cow feces on your bibliography, J.D. And, Ms. Coping, if the shoe fits, wear it. I was not changing the subject, I pointed out the inherent bias of the Pima Natural Resource Conservation District. You are not a resource conservation group. You are a resource user group and should not use such a deceitful name.

      1. As Ms. Coping pointed out, Ricardo does not argue the facts concerning jaguar habitat, but rather deflects the issue with ad hominem attacks on those who sponsored the research. Cattle grazing is not the issue.

      2. Of course cattle grazing is THE issue. So is mining. The people who compose the PNRCD Board are ranchers and miners who do not want an endangered species’ habitat to be identified by the USFWS and claim science and law does not support designation. It was a court order that forced the USFWS to comply with law that led to jaguar being placed on the endangered species list and another lawsuit led to the USFWS designating jaguar habitat to comply with law. The PNRCD Board members are far from conservationists. Why do they indict the USFWS designation of jaguar habitat? Because they want the freedom to profiteer from public resources on public land without sensitivity to jaguar habitat.

        J.D., your fallacious notion that public land is best left to those with an economic interest in it is misguided. BTW, economic interest in public land was NOT the issue, either, was it? Since you seem to want to restrict discussion.

        Jaguar have lived in Arizona for a very long time. Read a book titled Borderland Jaguars by David Brown and Carlos Lopez Gonzalez. There’s a great deal of science in that book by those two wildlife biologists.

      3. You get the point. It would not take long to compile an extensive bibliography that scientifically points out the detriment of livestock grazing on public land. This is a large part of the argument to counter the mistaken push by the PNRCD to halt protections for jaguar, which ARE based on science and ARE legal.

      4. Thanks, Uncle Karl. I appreciate your advice. I will not waste my time arguing anymore with J.D., the closed minded Randian. As you apparently learned here, many adherents to the Rand philosophy take on a zealotry that is impermeable to reason and is insensitive to consequences, other than the bottom line of profitability. Worshiping the dollar, as Randians do, is a shallow existence. I would rather see a jaguar, a wolf, a mountain lion or a bear than a herd of cows or a flock of sheep.

  3. “For Critical Habitat to be established under ESA, the FWS must show that the area in question is essential to the jaguars conservation and survival as a species, not merely whether the area in question could host or has hosted individual, transient jaguars. ” That is the legal principle.

    Richardo, can you provide evidence to prove that land in Arizona and New Mexico is essential for the survival of jaguars as a species? That is the issue, anything else is peripheral.

    1. No, “H” in my name. It’s Ricardo, J.D.

      The evidence is that the destruction of jaguar habitat in other portions of their home range, down into Nayarit and south of there, down where Dale Lee used hollowed out big gourd growl calls to entice answers from out in the swamps, down there – where abusers of land are killing off these big cats and wiping out their habitat, THAT destruction raises the jaguar habitat in the Southwestern U.S. to critical status, essential to jaguar conservation … real conservation, not the male bull feces that the PNRCD and you sling about.

      Obtain a copy of the court transcripts for more detailed evidence.

      What facts do you base your notion that land in Arizona and New Mexico are not essential for the survival of jaguars as a species?

      1. Ricardo, obviously you have not read, much less thought about any of the arguments or the supporting materials linked in Jonathan’s article. Mr. Parker, a professional wildlife biologist with decades of field experience, examined everything you mentioned -and a whole lot more. How then, can you justify your claim that his work is biased?

      2. I’ve thought a great deal about grazing on public land, about mining on public land, about jaguar habitat, Ms. Coping. I’ve read a great deal about these subjects, too. See the few book references I’ve listed in my recent posts at this site. BTW, there is no reference in J.D.’s list to anything by a Mr. Parker. Who does or did Mr. Parker work for? Where can I find what he wrote about “everything I mentioned – and a whole lot more”? What’s his first name? Does Parker’s writing refute Steve Gallizioli’s conclusions? Have you read Steve Gallizioli’s articles? How about David Brown’s book, Borderland Jaguars? Welfare Ranching? Read those and think about their contents, then let’s talk again soon.

      3. Ricardo, if had clicked the link provided, it would bring you to a webpage. The first link there “Comments” show that Dennis Parker is an attorney and biologist. Your question shows that you have not read the material.

      4. What link is that? Provided where? Have you read the material I provided links to, J.D.? Probably not, since you persist in your mistaken position about jaguar habitat.

  4. I don’t believe cattle are an indigenous species in the American southwest. The grazing of cattle in the Saguaro National Monument(now park) was well documented to be detrimental to the growth of the young saguaros. For more than fifty years the growth of the saguaro population was interfered with by grazing cattle on monument land. We are finally seeing the re-emergence of young saguaro since cattle grazing was discontinued. I think it’s logical to conclude that grazing cattle in other areas of the southwest where they have been introduced into the environment by humans is also going to be responsible for environmental damage eventually, if it hasn’t already happened. Whether or not the southwest is now, or ever has been Jaguar habitat, is really not the issue, IMO. The total environmental impact of introducing a non-indigenous species of bovine herbivores into a fragile desert environment is what we need to be evaluating. When the balance of nature is disturbed there is seldom a desirable or acceptable outcome. The protestations of the ranching community notwithstanding. There are much bigger issues at play here than the economic costs to the ranchers. They have only been occupying the land and grazing their cattle for the last one hundred fifty years or thereabouts, destroying what it took natural processes many eons to achieve.

    In the great plains states it has been found that grazing of the prairie by non-indigenous domestic cattle has produced widespread ecological problems involving a wide variety of native plant species. Native buffalo grazing the land did not have the same effect because the buffalo were much more selective about what they would eat. Domestic cattle did not differentiate, and today there are large tracts of land being replanted in the great plains states where cows are not allowed. These dedicated tracts of land are being successfully returned to their original state by various groups interested in restoring the environment. The desert environment of the southwest is quite fragile and we ought take a much closer look at what we may be destroying by putting domestic cattle on it to graze it to the bare earth. Along those lines it’s worth mentioning that given an acre of land, 15 to 30 more people can be fed by planting the land, as opposed to grazing cattle on it.

    I’m not about to agree with the U.S. Fish and Wildlife Service either. I don’t like to see government agencies overstepping their bounds and heavyhandedly issuing proclamations that may well have no basis in fact. What I do believe is that the fringe boundaries a very few Jaguars may range is not the issue we should be looking at. The destruction of native southwest habitat by grazing non-indigenous domestic cattle, and the future impact of that destruction, is.

  5. If a black panther can live around Kanab, Utah (mid 90’s) and in the Pine/Strawberry area (2001) without “protected areas” and amongst the very viable mountain lion population, which survives without our help all across the West, then so can jaguars. The family of lions living around an old homestead ranch I lived on outside Sedona had plenty to eat. If jaguars wanted to travel that far north, they’d find the lions, not humans, their only competition. That jaguars do not wander this far north anymore, if they ever did, is probably due more to their preference for more tropical and densely forested areas that matches their coloring pattern. But the hippie lawyers and environmental Nazis of the so-called Center for “Biological Diversity” don’t care to pay attention to such obvious details. This begs the question: in addition to excluding humans from proposed “protected” areas, do these ecology Nazis also plan to kill off the existing mountain lion population to give the jaguars more “lebensraum”? Or is their true purpose in demanding more area than proposed by the FWS really a furthering of the misanthropic UN Agenda 21?

    1. Ah, yes. Now we have the truth about the objective of protecting an endangered species. It is a Nazi plot, a UN conspiracy. Oh woe is me! How could I have been so wrong as to not the see this?

      MadMagyar, whoever you really are behind your anonymous handle, I suggest you extract your head from where the sun don’t shine and examine some facts.

      First, jaguar dominate mountain lion, much like wolves dominate coyotes, and there is no plan to kill off mountain lion. Hence the name Center for Biological Diversity, emphasis on “diversity”. Second, the densely forested areas down south that you mention are disappearing fast, and large portions of Arizona and New Mexico are also densely forested. You should get out and see the Southwest’s wild country some time. It is beautiful! Third, using “nazi” and suggesting that there is a UN plot characterizes you as a kook. Fourth, the USFWS did not initially propose anything for jaguar, because that agency regularly caves in to political pressure from resource abuse folks, like ranchers and miners. The Service was forced to comply with law by court orders.

      1. 1, I LIVE in “wild country”, not some smog-choked city. I hear coyote, elk and other wild animals every night
        2. I left the mountain lion family that lived near a ranch where I stayed several years ago alone – and they left me alone. Ever had one 10 feet from you, in the dark, on a rock ledge above you? Thought not. I have, and she let me live. THAT will teach you more about having some respect for large wild cats than reading about them in a book.
        3. Apparently you’ve never heard of Agenda 21. Try reading about it. It’s not a conspiracy “theory” when it’s a conspiracy FACT. The UN, like any other so-called “government”, is all about control, just the opposite of the natural world. Start here:
        4. When people finally wake up, they will learn that this planet can handle anything we think we can do to it, and much more. If we ever learn to just leave nature alone and quit trying to control it, or stuff it in a box, or a cage, then we’ll get along with it just fine.
        5. Cats, especially big ones, don’t care what humans want.
        6. Nazis were real, too, in case you haven’t heard. And they didn’t just “go away”. Ever heard of Stormfront? As insane, belligerent and violent as they are, the kids on that forum are a joke compared to the real ones. Pray you never meet one.
        Guess you didn’t catch the sarcasm in the allusion.

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