No matter where you live, America's lion needs your voice.
Public Comments Processing
Attn: Docket No. FWS-R5-ES-2015-0001
U.S. Fish and Wildlife Service, MS: BPHC
5275 Leesburg Pike
Falls Church, VA 22041-3803
OPPOSED: Removing Eastern Puma (Cougar) From the Federal List of Endangered and Threatened Wildlife,
Docket No. FWS-R5-ES-2015-0001
Dear U.S Fish and Wildlife Service,
The undersigned organizations and individuals are committed to protecting and restoring sustainable puma (cougar, mountain lion, or panther) populations across the historic range of the puma. We urge USFWS to draft a recovery plan that ensures protection for pumas and evaluates measures to reintroduce the species into suitable habitat throughout their historic range in the United States.
The best available science recognizes a single North American puma subspecies.
The USFWS Eastern puma review notes: "Young and Goldman's (1946) taxonomy of pumas was inadequate, even by the standards of their time. Their results were based on very small sample sizes, the samples were from an extremely small portion of the alleged eastern puma's range (samples from Vermont and Quebec were available, but not examined), their work was not peer reviewed, their taxonomy lacked statistical analysis, and their work would likely be rejected...Young and Goldman's (1946) and Hall's (1981) conclusions concerning taxonomy of the eastern puma may be wrong."
Recent analyses indicate that those animals once designated under the "eastern cougar" subspecies were in fact taxonomically indistinguishable from puma populations to the west (Culver et al, 2000). The USFWS must not declare the Eastern puma subspecies to be extinct when the best available science demonstrates that it simply never existed. Instead, we recommend the Service accept the findings of Culver et al. (2000) of a single North American puma subspecies.
Puma concolor has been extirpated from the U.S. east of the Missouri River and north of Florida.
There is no documented verification of wild breeding populations of pumas in this region in more than a century.
Pumas within their extirpated range meet all of the qualifications for protection under the Endangered Species Act.
These include "(A) the present or threatened destruction, modification, or curtailment of the species' habitat or range, (B) overutilization for commercial, recreational, scientific, or educational purposes, and (D) the inadequacy of existing regulatory mechanisms through all of the North American puma's historic, extirpated range." (Assessment of Species Status, ESA Section 4) These qualifications exist in, and are not limited to, the states of Kansas, Oklahoma, Minnesota, Iowa, Missouri, Arkansas, Louisiana, Wisconsin, Illinois, Kentucky, Tennessee, Alabama, Michigan, Indiana, Ohio, New York, Pennsylvania, New Jersey, West Virginia, Virginia, Maryland, Delaware, Vermont, Massachusetts, Connecticut, New Hampshire, Maine, North Carolina, South Carolina, and Georgia.
Designation of pumas as a Distinct Population Segment is consistent with the intent of Congress in establishing the classification.
Pumas that exist within or enter into their extirpated range meet all the requirements for classification as a DPS (61 Fed. Reg. 4722, 2/7/1996). First, such pumas are "distinct" as defined by USFWS since they are geographically isolated from breeding populations elsewhere in the United States. Second, the puma's former range east of the Mississippi River and north of Florida presents a significant gap.
There are ecological and public safety imperatives for classifying pumas as a Distinct Population Segment (DPS) within their extirpated range.
Policy C (2) of the Interagency Policy for the Ecosystem Approach to the Endangered Species Act states that "recovery plans shall be developed and implemented in a manner that conserves the biotic diversity... of the ecosystems upon which the listed species depend."
Ecosystems lacking breeding populations of pumas currently suffer from a severe overpopulation of ungulates with attendant ecological impacts and loss of human life.
Chronic white-tailed deer over-browsing has triggered biodiversity collapse (Goetsch et al 2011), and declines in mast production (McShea et al. 2007), understory recruitment and ground-nesting habitat (U.S. Forest Service 2008) across eastern deciduous forests. Multiple long-range studies have demonstrated that apex predators such as pumas maintain biodiversity and ecosystem functioning (Ripple et al. 2014).
Puma restoration would also significantly reduce the acute public safety risk of vehicle collisions with deer and the attendant mitigation costs (Gilbert et al. 2016) as well as the human health issues associated with deer ticks as a vector for Lyme disease (Kilpatrick et al. 2014).
We urge greater protection for puma populations in - and dispersers from - the prairie states.
To allow the species to begin recovering breeding populations in the extirpated regions, we urge the USFWS to better protect pumas in the prairie states. Human-caused mortality of pumas in these states has reduced the viability of these populations and has limited puma dispersal to the east. (Tucker, 2014; Cougar Rewilding Foundation, 2015). Dispersing individual pumas are essential for recolonization.
Reclassifying pumas in Florida as a Distinct Population Segment must maintain their protected status.
As the lone surviving population of the North American puma subspecies east of the Missouri River, pumas in Florida are essential to the recolonization of the entire extirpated range. Whether genetically or only geographically separate from western pumas, with fewer than 180 panthers remaining in the wild, these animals must remain protected as federally endangered, and their recovery must be ensured.
Florida panthers must be considered as source animals for puma reintroduction efforts at any suitable locations in the Southeastern United States, including but not limited to urgently needed efforts to establish breeding populations of the panthers in central and north Florida.
We recommend the USFWS develop a recovery plan for the North American puma subspecies within its extirpated range by reclassification as a Distinct Population Segment (DPS) under the Endangered Species Act.
As precedent for the federal recovery of species ranging across the United States we reference federal law (16 U.S.C. 668-668d), international treaties (Migratory Bird Treaty Act) and the recovery plans developed to protect the bald eagle (USFWS Northern States Bald Eagle Recovery Plan) and American peregrine falcon (USFWS Monitoring Program for the American Peregrine Falcon).
Also, we note that the gray wolf reintroduction into the Greater Yellowstone Ecosystem was successfully carried out by the USFWS under some of the same logic that can and should be applied to restoring pumas to the eastern United States. Gray wolves retained robust populations in Canada and Alaska, and yet it was clear they were extirpated from large portions of their historical range. While the gray wolf restoration effort remains unfinished in other regions (Pacific Northwest, Southwest, Southern Rockies, and potentially the Northeast) the precedent remains for the USFWS to work to restore carnivores to regions where they have long been extirpated.
In the case of pumas, such a recovery effort must explore such issues as habitat protection and connectivity, reducing mortality in current breeding populations of pumas, protection of dispersers, and the reintroduction of pumas into suitable habitat. In addition, it will be necessary to gauge public attitudes towards pumas, to encourage science-based education about the species, to engage in efforts to mitigate any loss of tolerance that may have resulted from extirpation, and to promote coexistence.
Pumas are an icon of the American wilderness, a critical component of healthy ecosystems, contribute to human health and safety, and maintain priceless cultural value. By acknowledging the best available science, we can begin a national conversation and the elements needed to restore this essential species throughout its historic range.
We hope you will make the most of this opportunity to work towards a future where pumas once again roam the American landscape, coast to coast. Thank you for your consideration.
Sincerely,YOUR NAME WILL GO HERE
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The Mountain Lion Foundation, founded in 1986, is a national nonprofit organization protecting mountain lions and their habitat.
We believe that mountain lions are in peril.
Our nation is on the verge of destroying this apex species upon which whole ecosystems depend. Hunting mountain lions is morally unjustified, and killing lions to prevent conflicts is ineffective and dangerous.
There is a critical need to know more about the biology, behavior, and ecology of mountain lions, and governments should base decisions upon truthful science, valid data, and the highest common good. Conserving critical lion habitat is essential.