SACPA’s Sept 23, 2010 comments & research submitted on proposed Jaguar rule

Click here to view comments Dennis Parker submitted September 23, 2010 in response to the USFWS decision that a critical habitat designation for the jaguar is “prudent.”

Attachments submitted with comments:

  1. Email from Carlos Lopez-Gonzales email to AGFD employee William Van Pelt requesting peer review on extremely short notice for a paper* he was presenting at the Madrean Archipelago conference held by US Forest Service Rocky Mountain Research Station. This email, obtained through a public records request, is evidence that Carlos Lopez-Gonzales and Erin Boydston selected their own peer-reviewers, if any peer review at all was actually done on the paper, which suggests a biased peer-review.  For a more detailed explanation of why this matters, see Dennis Parker’s comments, pp. 4-5.
  2. FOIA response from USDA Forest Service Rocky Mountain Research Station in response to request for copies of peer-reviews of a 2005 conference presentation made by Carlos Lopez Gonzales and Erin Boydston, “Sexual Differentiation in the Distribution Potential of Northern Jaguars (Panthera onca).”(USDA Forest Service Proceedings RMRS-P-36. 2005.)
    This is important because this  utterly unscientific paper  was successfully presented to the late Judge Roll as reason to overturn the USFWS decision that critical habitat is not warranted for jaguars. The FOIA response is void of any evidence the paper was ever peer-reviewed. For a detailed explanation see Dennis Parker’s comments, pp. 4-5.
  3. Letter of July 1, 1963 from Curtis Prock to US District Court. The letterhead proves a famous jaguar hunting guide had been in the business of leading bear, lion and jaguar hunts in Arizona and “Old Mexico” a short time before a female jaguar was killed at Big Lake. It also shows that as a criminal suspect the  formerly  successful and world-famous hunting guide was unconstitutionally forced out of business by the fish and game authorities before his case ever went to trial.
  4. U.S. Fish and Wildlife Service Question and Answer flier of January 13, 2010 on Jaguar Prudency Determination and Recovery Plan. In this document, the USFWS published misleading innuendo that jaguars had occurred at Santa Fe, New Mexico. This is a falsehood based on an error in a U.S. Boundary Survey document telling of a jaguar which, in 1825, got inside the cloister of a monastery on the bank of the Rio Paraná in Santa Fe, Argentina and killed four priests. One error in the 1825 document put the incident on the bank of the Rio Grande in Santa Fe, New Mexico (never mind they are about 40 miles apart). The error is exposed in the same literature  the USFWS cited in its prudency finding.
  5.  Emails obtained through public records request indicating AZ Game and Fish Department paid the Center for Biological Diversity $999.99–one penny below the radar of the Arizona Game and Fish Commission–to create its own model to replace the New Mexico Game and Fish Department’s previously approved internal analysis of jaguar habitat in New Mexico.** This occurred shortly after a rancher filed a malicious defamation suit (which he later won) against  the Center for Biological Diversity. The USFWS cited the unscientific CBD product*** in its determination of critical habitat for the jaguar. For a more detailed explanation, see Dennis Parker’s comments, pp. 6-10.
  6. Evidence the female jaguar killed at Big Lake in 1963 and a male jaguar killed on the Mogollon Rim in January 1964 were imported; For a detailed explanation why this is important, see Dennis Parker’s comments, pp.6-10.
  7. Letter of Oct 9, 2005 from AGFD Jaguar Conservation Team (JAGCT) member Judy Keeler to AGFD employee William Van Pelt discussing differences between JAGCT minutes and what actually occurred; and criticizing the $999.99 contract AGFD  made with Center for Biological Diversity to remodel jaguar habitat maps in New Mexico as a replacement for models already developed and published by the New Mexico Department of Fish and Game.
  8. Copy of email from FWS Public Outreach Specialist Jeff Servoss in response to a request for a time extension for public comment beyond March 15, 2010
  9. Alan Rabinowitz’s New York Times Op Ed: “Jaguars Don’t Live Here Anymore.“ Alan Rabinowitz is widely recognized as the highest authority on jaguar recovery alive anywhere in the world. Rabinowitz believes no essential habitat for jaguars exists north of Mexico, and money is being wasted on the critical habitat designation that could be put to better use elsewhere.
  10. Chilton v. Center for Biological Diversity Division 2 Appeals Court decision  The Arizona Game and Fish Department contracted the Center for Biological Diversity to map jaguar habitat to replace existing expertise published by the New Mexico Game and Fish Department during the same time period the CBD was being successfully sued for malicious defamation of a rancher. For a detailed explanation why this is important, see Dennis Parker’s comments, pp. 6-10.
  11. Sports Illustrated January 14, 1974: “The Man Who Loved Cat Killing.” This article discusses one famous jaguar hunting guide who was caught in New Mexico with 9  jaguars he had imported and intended to release in front of unsuspecting hunting clients. In previous hunts at least one female escaped into the wild. For a detailed explanation why this is important, see Dennis Parker’s comments, pp. 3-10.
  12. “Spatial Ecology and Social Interactions of Jaguars (Panthera Onca) in The Southern Pantanal, Brazil” by Sandra Cavalcanti and Eric Gese, Journal of Mammalogy 90(4): 935-945, 2009 This paper is important because it indicates jaguars and cattle have cohabited the Pantanal for more than 200 years and occur at very high densities on cattle ranches. This is evidence that instead of causing jaguar demise, the livestock industry allows the species to survive. For a more detailed explanation, see Dennis Parker’s comments, pp.12-13.
  13. “Kill Rates and Predation Patterns of Jaguars in the Southern Pantanal of Brazil” by Sandra M.C. Cavalcanti and Eric M. Gese. Journal of Mammalogy 91(3): 722-736, 2010. This paper is important because it provides evidence that high stocking rates of cattle support high densities of jaguars in the Pantanal of Brazil. More than 30% of the jaguar’s diet in the Pantanal is beef. This is evidence that instead of causing jaguar demise, the livestock industry allows the species to survive. For more information, see Dennis Parker’s comments, pp. 12-13.
  14. “Estimating the Density of a Jaguar Population in the Brazilian Pantanal Using Camera-Traps and Capture-Recapture Sampling in Combination with GPS Radio-Telemetry” by Marianne K. Soisalo and Sandra M.C. Cavalcanti. Biological Conservation 129(4):487-496. May 2006. Despite human-jaguar conflicts over cattle deaths, the jaguars nevertheless persist. This is evidence that instead of causing jaguar demise, the livestock industry allows the species to survive. For more information see Dennis Parker’s comments, pp. 12-13.
  15. “Identifying Potential Conservation Areas for Felids in the USA and Mexico: Integrating Reliable Knowledge Across an International Border.”  M. Grigione, K. Menke, C. López-González, R. List, A. Banda, J. Carrera, R. Carrera, A.J. Giordano, J. Morrison, M. Sternberg, R. Thomas and B. Van Pelt, Oryx 43(1): 78-86. Flora and Fauna International, 2009. DOI:10.1017/50030605308002019. This paper is mentioned in Dennis Parker’s comments on pp. 4-5. The authors narrowed the database for modeling purposes down to 20 jaguars but still included two jaguars likely imported for sport hunting, and therefore the conclusions of this paper are likewise unreliable.

*Citation: Boydston, E. E. and C. A. Lopez Gonzalez. 2005. Sexual differentiation in the distribution potential of northern jaguars (Panthera onca). In: Connecting mountain islands and desert seas: biodiversity and management of the Madrean Archipelago II. 2004 May 11-15; Tucson, AZ. Proceedings RMRS-P-36. G. J. Gottfried, B. S. Gebow, L. G. Eskew & C. Edminster (eds.). U. S. Forest Service. Fort Collins, CO: US Department of Agriculture, Forest Service, Rocky Mountain Research Station, pp. 51-56.

**Citation: Charles L. Hayes and Kurt A. Mencke,”Evaluation of the Relative Suitability of Potential Jaguar Habitat in New Mexico” NM Dept. of Game and Fish
***Citation: Robinson, Michael J. “Potential Habitat for Jaguars in New Mexico” January 2006. Center for Biological Diversity