SACPA Comments on Dec. 20, 2016 USFWS Draft Jaguar Recovery Plan

This page was last updated March 18, 2017.

On March 18, 2017, our comments and Attachment 1, Literature Review, which were submitted February 26, 2017 were revised. We revised them to reflect new knowledge that previously had been unavailable to us. The revised comments and all supporting attachments were resubmitted to supersede everything formerly submitted.

Click here to read U.S. Fish and Wildlife Service’s December 20, 2016 Jaguar Draft Recovery Plan

Click here to read comments submitted by SACPA et al. on March 18, 2017 in response to December 20, 2016 Jaguar Draft Recovery Plan (311 Kb)

Attachment 0. Map of USFWS-proposed jaguar cross-border corridors and Table of Contents of all attachments (274 Kb)

Attachment 1. March 17, 2017 Jaguar Literature Review (2 Mb)

The Literature Review examines the documentation on every jaguar referenced in the scientific literature and illuminates discrepancies, duplications and errors. Each record is classified according to standards set forth in Tewes and Everett (1986). Results are summarized, tabulated and charted at the end. The 2017 review is an update of the previously submitted 2012 Literature Discrepancies review, with the addition of new information published since 2012, charts and tables, a table of contents, and a complete bibliography.

Attachment 2. 2017.02.17.1351.Did the Men on Coronado’s Expedition See Jaguars in Arizona?  (528 Kb)
The short answer: No verifiable evidence supporting the legend exists. The legend originated in inaccurate translations and fictitious embellishments by translators of copies and previous translations of the original Spanish text. The two original Spanish documents from which the legend arose are both lost to history.

Attachment 3. Southern Border Safety and Security Threats (1.1 Mb)


Attachment 4: News Articles Showing Emil McCain baited jaguar “Macho B” from 2004-2009 with scat collected from female zoo jaguars in heat. 

The articles linked below were submitted in this attachment. The articles, in contrast to the stated methodology of McCain and Childs (2008), show that Emil McCain made extensive use of sexual scent-bait,  to manipulate the movements and behavior of Macho B. The fact that these “researchers” manipulated the movements of the jaguar, which their report falsely implied had occurred naturally, invalidates all the data they collected.

In the 2014 Jaguar Critical Habitat designation, USFWS knowingly and falsely stated that the sexual scent-baiting first began in 2008, not 2004, and knowingly relied on invalid data Emil McCain collected between 2004 and 2008.  USFWS not only refers to this fake data as “the best available science,” but continues to rely on it in the Jaguar Draft Recovery Plan. Unfortunately, McCain’s methodology took its toll in the unnecessary suffering and death of not just Macho B, but also at least one and possibly more jaguars in Mexico.

Attachment 5. Documents related to Arizona Game and Fish Department and/or its former employee David E. Brown (3.5 Mb)

Arizona Game and Fish Department’s 8/8/2013 comments on the Jaguar Critical Habitat Rule

Arizona Game and Fish Department’s 10/19/2012 comments on the Jaguar Critical Habitat Rule

David E. Brown, 01/11/2011, email to AZGFD’s lead jaguar conservation biologist Terry Johnson.

This email was obtained through public records request to AZGFD from the Center for Biological Diversity and then posted on the AZGFD’s website. Brown casts doubt on the authenticity on the alleged 1906 record of a female jaguar with cubs. Ironically, the alleged record had been published by David E. Brown and Carlos Lopez-Gonzales in their 2001 book, “Borderland Jaguars.”

McCain, E., Aug 21, 2007, “David E. Brown Q&A” 

David E Brown is a former employee of Arizona Game and Fish Department. He has written many publications on the subject of jaguars in Arizona, New Mexico and Sonora. The opinions he expresses here are different than statements in his earlier published opinions.

Housholder, Bob, June 1966, “Arizona Jaguars.”

This is an unpublished list of jaguars seen or killed in Arizona, which the Pima NRCD obtained from the US Forest Service Coronado District through a FOIA request. This document reveals the AZGFD’s suspicion in 1966, that the young female jaguar killed in 1963 at Big Lake had at some time been released for sport hunting and had gotten away. Housholder mentions the tiny 105 pound jaguar’s “well-worn teeth” as evidence. This contrasts with the fact that photos of that jaguar, and her very small size, suggest she was very young. “Well worn teeth” may be an indication she had tried to chew her way out of a cage. The Literature Review (Attachment 1) reveals several jaguars, taken far outside their expected range, were likewise described as having “well-worn teeth” despite also having “fine pelage.”

Bob Housholder was an avid big game hunter and the editor of the AZGFD’s monthly magazine, Arizona Wildlife Sportsman in the 1950’s and 1960’s. He wrote many articles about jaguars in Arizona, most notably, “Arizona Jaguars” in the August 1958 issue.

All previously submitted comments were copied and tramsmitted to USFWS. All attachments to previous comments are incorporated in our comments on the Jaguar Draft Recovery Plan by reference.

Attachment 7. AZGFD CBD $999.99 contract to replace NMDGF habitat map (1.1 Mb)

This attachment consists of a series of emails obtained through public records request from the Winkleman Center for Conservation Education to the Arizona Game and Fish Department.

These emails tell the story of how powerful NGOs on the AZGFD’s Jaguar Conservation Team politically influenced  the methodologies of purportedly “scientific” research. These emails show how political activism directly contaminated the results of published research by demanding the researchers use unreliable data in habitat modeling.

The emails further document how a scientifically legitimate New Mexico jaguar habitat mapping study, Menke and Hayes (2003), which had been prepared for– and accepted by the New Mexico Department of Game and Fish–was supplanted with junk science produced by the Center for Biological Diversity for the Arizona Game and Fish Department. The latter was funded by a $999.99 contract from the Arizona Game and Fish Department. The contract fee is one penny below the level that would have mandated it be advertised for public bid, and one penny below which the contract would have required review and approval by Arizona Game and Fish Commission.

Moreover, at the time this contract was signed, the Center for Biological Diversity was being successfully sued by a rancher for malicious defamation. The rancher sued  because, following the renewal of his Forest Service grazing permit, the CBD posted on its website the same maliciously false information they had previously submitted to federal regulators in their attempt to halt the permit’s renewal.

These emails confirm what David E. Brown implied in the 2007 interview submitted in Attachment 5, that jaguar research funding is contaminated by “agendas.”

Attachment 8. Letter from Apache County requesting participation as co-submitter of comments (96 Kb)