BOBCAT, COUGARS, MOUNTAIN LIONS, LYNX, TIGERS.....
Oppose De-Listing the Mexican Bobcat under the ESA
Comments Needed by August 17, 2005
In response to a petition from the National Trappers Association, the U.S. Fish and Wildlife
Service has published a proposed rule to delist the Mexican race of the bobcat (Lynx rufus escuinapae), a subspecies
that is currently listed as Endangered under the Endangered Species Act (ESA). To view the proposed rule, go to www.fws.gov/policy/library/05-10002.pdf. Your action is needed before the comment due date of August 17, 2005.
Background
Bobcats are the most heavily trapped and traded species of cat. Over 30,000 specimens, mostly
skins, were exported in 2002, mostly from the U.S. and Canada. International trade in bobcats is regulated under the Convention
on International Trade in Endangered Species of Wild Fauna and Flora (CITES) where the species (Lynx rufus) is listed
on Appendix II.
The proposed rule appears to represent the latest effort by the Service to de-regulate international
trade in bobcats. In 1992, the U.S. successfully lobbied CITES to transfer the Mexican bobcat from CITES Appendix I (which
does not allow international commercial trade) to Appendix II, thus opening international trade in the subspecies. However,
Mexican bobcat skins cannot currently enter the U.S. because ESA Endangered status protects the subspecies from U.S. markets
(it is illegal to trade in Endangered species).
At the last international Conference of the Parties to CITES in 2004, the U.S. proposed
to delist bobcats (Lynx rufus) from the CITES Appendices. However, the U.S. withdrew this proposal in response to concerns
raised about the lack of information on bobcat populations in Mexico.
The ESA defines "species" as "any subspecies of fish or wildlife or plants, and any distinct
population segment of any species." The Service uses three arguments in support of the delisting: the subspecies is not taxonomically
valid, it is not a "distinct population segment," and/or it does not meet the criteria for listing under the ESA.
Take Action Today
Send letter to:
Chief, Division of Scientific Authority
U.S. Fish and Wildlife Service
4401 N. Fairfax
Drive, Room 750
Arlington, VA 22203
703-358-2276 fax
scientificauthority@fws.gov
Comment deadline: Wednesday, August 17, 2005
Points to make in your letter:
Support the continued listing of the Mexican bobcat as an Endangered species under
the ESA. Oppose the Service’s proposal to delist the species under the ESA.
Taxonomists consider the subspecies to be valid. No evidence is presented in the proposed
rule or the petition that taxonomists question the validity of the subspecies; documents cited in the proposed rule support
the taxonomic validity of the subspecies.
The Mexican bobcat constitutes a "distinct population segment" because it has distinctive
traits (including cranial measurements and fur color); it is the only subspecies that occurs solely in Mexico; it occupies
the most southerly part of the distribution of the species and is the only subspecies to occur below 23 degrees N latitude;
and because of its unique distribution, loss of this subspecies would significantly affect the distribution of the species.
The proposed rule provides no scientifically-based evidence that the Mexican bobcat does
not meet the criteria for listing as Endangered under the ESA. The Service quotes unnamed "experts" and Mexican government
officials who have reportedly stated that the Mexican bobcat is abundant and widespread. However, the international community
and conservation organizations convinced the U.S. to withdraw its 2004 CITES proposal to delist the bobcat because it was
concerned about the lack of information on bobcat populations in Mexico. In fact, the proposed rule states that "no population
estimates are available" for the subspecies. The IUCN Cat Specialist Group states that regarding Lynx rufus, "there
is little information from the south of its range in Mexico" and that "the dry scrub and oak and pine forest habitats used
by bobcats in Mexico have suffered the highest rates of transformation and degradation relative to other habitat types." In
addition to lack of information on the status of the wild populations of Mexican bobcat, or its habitat, there is no information
on the impact of trapping, hunting and trade on the subspecies. Although the Mexican government regulates take, and exports
skins, it does not have a management program in place to ensure that take is sustainable.
For more information, please contact Barry Kent MacKay at mimus@sympatico.ca or 905-472-9731, or Camilla Fox at chfox@earthlink.net or 916-447-3085 x215.
Thanks to our Fur Free Alliance partner, the Humane Society of the United States, for
sharing this alert. For a copy of API’s letter drafted on behalf of the Fur Free Alliance, please contact Camilla Fox
at chfox@earthlink.net or 916-447-3085 x215.
