http://www.arizonadailyindependent.com/2013/07/03/jaguars-and-junk-science/
Jaguars and junk science
July 3, 2013 Last August, the U.S. Fish & Wildlife Service (FWS)
proposed to designate 838,232 acres in southeastern Arizona and southwestern
New Mexico as critical habitat for the jaguar. FWS sought public comments and
got plenty. FWS has slightly changed the boundaries of their proposal and is
now seeking more public comments. A 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 requested 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, no
less, 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; and, 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.
http://www.arizonadailyindependent.com/2013/07/03/jaguars-and-junk-science/
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