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 - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - To get off the IOWA-TOPICS list, send any message to: [log in to unmask]