AZGFD Comments On Recent Jaguar Critical-Habitat Announcement

On March 4, 2014, the Southwest Region of the U.S. Fish and Wildlife Service (Service) notified the public that the Service had designated 764,207 acres of land in southern Arizona as critical habitat for the rarely-present jaguar. This action completed the third review by the Service that examines the need for jaguar critical habitat in Arizona.

The two prior reviews found that designation of critical habitat in Arizona-New Mexico was not warranted. The Arizona Game And Fish Department does not support the latest finding of the Service that designating critical habitat is essential to the conservation of the jaguar.

Difficult To Justify

Game and Fish Assistant Director for Wildlife Management Jim deVos states, "I find it difficult to justify designating critical habitat for a species that is so rarely found in Arizona. In looking at the available data on the presence of jaguars, there has been no documentation of a female jaguar in Arizona for nearly a century.

"There have been long periods when no jaguar was even found in the state. Such designations should be based on good science and effective conservation, which are both lacking with this designation. This designation does nothing to further the conservation of the jaguar."

Not A 'Population'

Based on the current information from Mexico, the closest breeding population of jaguars is approximately 130 miles south of the international border between Arizona and Sonora, Mexico. Further, for many decades, the observations of jaguars in Arizona have been individual males, which clearly do not constitute a "population" given the lack of females and/or breeding pairs.

The American public has a reasonable expectation that when the Service lists a species or designates critical habitat for a species that the restrictions posed by these designations are, in fact, essential to that species' conservation.

"With the absence of any documented breeding pairs in the U.S. for many decades and with an estimated population of no less than 30,000 jaguars and more than 99 percent of the jaguar's range occurring outside of the United States, the Service's recent declaration of critical habitat undermines the congressional intent for the Endangered Species Act (ESA)," says Larry Voyles, Arizona Game And Fish Department director.

Comment Letters

In the department's comment letters submitted to the Service in 2012 and 2013 (posted at http://www.azgfd.gov/jaguar), the department opposed this designation, based on several points, including the following:

• The ESA defines critical habitat as that which is essential to the conservation of the species.

• Lone males that disperse to the edge of the species' range are not essential to species preservation, particularly in the absence of any documented jaguar breeding pairs in the region.

• That designation of critical habitat is not warranted and indeed sets an unacceptable precedent of using poor science to designate critical habitat.

• To be declared critical, habitat should be occupied. However, in 35 of the 49 years between 1962-2011, no jaguars were detected in Arizona. In the other 14 years, no more than one or two male jaguars were detected per year, failing to demonstrate occupancy as required.

"The department has a long history of supporting endangered species, including designation of critical habitat, but designating critical habitat for the jaguar simply fails in both logic and biological foundation," says Voyles.

"Further, recovery of jaguars is very important, so important that all conservation efforts and use of precious limited resources need to be focused where most jaguars actually exist."

Arizona Game and Fish has long been involved in jaguar conservation and has been a member of the Interagency Jaguar Conservation Team since 1996. For more information on jaguars, visit http://www.azgfd.gov/jaguar.