A 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: http://www.sacpaaz.org/comments-on-proposed-jaguar-critical-habitat/
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.