These are comments made to the Natural Resources Commission last week.

Notice of Intended Action-Chapter 77, Endangered and Threatened Plant and
Animal Species
Amendments are proposed to the list of endangered, threatened, and special
concern mammals, reptiles, and amphibians.

 According to the Notice of Intended Action:
These proposed amendments reflect new survey information, regional status,
distribution changes since 1930, estimated habitat changes in the next ten
years, and population trends.

It appears that there has been no actual survey of the Bobcat and that much
of the data collected is anecdotal evidence.  The worksheet used unfairly
judges the Bobcat because of the time period involved, even though the
number of sightings statewide is quite low.  Previous to 2000, approximately
58 Bobcats have been sighted, with 20 of those sightings during the 1980s,
38 during the 1990s, and 8 total during 2000 and 2001 until the notice of
intended action was posted.  This might indicate a slight increase in their
population, however, an estimated 40% of those sighted were dead animals.
Over the past 22+ years, a total of approximately 40 live Bobcats have been
sighted statewide - an average of fewer than two animals per year.

It is unreasonable to remove an animal from Endangered status with these
reported numbers.  The animal will continue to have threats to its survival
that it currently has (vehicles, poisons, traps, accidental and intentional
shooting, etc.) and will be under more pressure if it is removed from this
listing.  Is the population large enough to safely support their recovery,
with small reported numbers spread across our large state?

Instead, a down-listing from Endangered to Threatened status would indicate
the animal is making progress in its recovery and would avoid a "delisting".
We maintain that there is not enough information and, because of the low
numbers on the records it is not statistically significant.

HABITAT

How will habitat changes in the next ten years benefit this species?  In the
last few years, Iowa has seen a loss of Conservation Reserve acres and a
conversion of wild areas to farmland, hog confinements, dams and urban
sprawl.  Scrubby areas and fencerows are being cleared for farmland or
prairie reconstruction, or to manage for other species with other habitat
needs.  What predictions is the DNR making about habitat changes, and how
will those habitat changes enhance recovery of the Bobcat?  What has the DNR
done to enhance its recovery besides protecting it from harvest?  What will
the DNR do to enhance its recovery?

Based on our concerns about the low numbers of Bobcats, and concerns for the
continued threats to its survival and continued loss of habitat, we
recommend that the Bobcat be listed as Threatened or special concern.

We would further recommend that the River Otter remain on the Threatened
list or special concern.

Thank you for considering our comments.

Jane R. Clark
Conservation Chair
Sierra Club of Iowa

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