I am the chairman of the Pima Natural Resource Conservation District (PNRCD), one of many local units of government on whose behalf biologist Dennis Parker submitted comments on the draft Jaguar Recovery Plan.

In his article, “Endangered Species, And The Wall That Could Silence Them,” Arizona Republic/USA Today writer Brandon Loomis mistook Mr. Parker for an attorney representing us. Mr. Parker, in fact, is retired from the practice of law. He represented us solely in the capacity of a biological consultant.

Moreover, Mr. Loomis plucked from Mr. Parker’s comments just a single snippet relating to a single issue, and presented it out of context. He ignored the many other very serious factual issues Mr. Parker actually raises — all of which are cited to verifiable sources and none of which, like the survival of the jaguar as a species, depend on whether a border wall is constructed or not. A few of those many important issues, which Mr. Parker discussed in considerable detail, are presented for your readers’ further information and consideration below.

First, the historical range of the jaguar covers 19 countries in the Western hemisphere. At the bare northern extreme of this species’ multi-continental range lie Arizona and New Mexico. Jaguar presence there is characterized by sparse detections of lone, transient males from time to time along the Mexican border, few females over time, and not even one verified breeding record. In fact, no report of any naturally present female jaguar has come out of New Mexico – ever.

The U.S. Fish and Wildlife Service (USFWS), however, has legal jurisdiction only within the boundaries of the United States and its Territories. Its actual authority, therefore, only covers less than one out of every one hundred acres within the jaguar’s multi-continental range as a species, and less than one jaguar for every 10,000 jaguars in its entire range-wide population. Nonetheless, this agency proposes to spend at least $605,648,000 in U.S. taxpayer money, mostly in northern Mexico, for jaguar recovery over the next 50 years.

Second, according to the Arizona Game & Fish Department (AGFD), habitat that is critical, i.e., “essential” to the jaguar’s conservation or existence as a species does not exist in either Arizona or New Mexico, “under any scientifically credible definition of that term.” Nor do either AGFD or the New Mexico Department of Game & Fish (NMGF) concur with the USFWS’s opinion that its proposed recovery actions in Arizona and New Mexico (AZ/NM) will likely benefit the conservation of jaguars as a species, as the Endangered Species Act also requires. Instead, these state wildlife agencies concur that they will not.

Third, archaeological evidence of jaguars in AZ/NM does not exist, at least since the Pleistocene era. Moreover, the fossil record for Arizona presents no evidence of jaguar presence whatsoever.

Fourth, while the draft recovery plan proposes action only in Arizona, New Mexico and northern Mexico, the USFWS nonetheless insists that all 18 foreign, sovereign nations within the jaguar’s actual range must fully meet its recovery goals before it will even consider de-listing the species in the United States. In two of those nations, the jaguar is presently extinct. In many others, like Brazil, it is currently abundant.

Fifth, the draft recovery plan prioritizes transient jaguar presence over national and citizen security. It does so by also requiring the establishment of at least two, permanent “trans-border linkage corridors” on the U.S. southern border. The agency claims such linkages are “essential” to the jaguar’s overall existence as a species, despite its own admission that these combined corridors might collectively benefit, at most, just 6 jaguars (sex unspecified) over the course of the next 50 years. The USFWS also expects most if not all of these jaguars would be lone transient males.

One of the proposed corridors is located very close to Fort Huachuca, home to the U.S. Army Intelligence Center and the NETCOM / 9th Army Signal Command. That area is already a major corridor for ongoing drug and illegal immigration smuggling operations. The Mexican drug cartels are now working with jihadists dangerously close to the U.S. border as well.

Another corridor the draft plan proposes lies west of Nogales. It too is already a major route for both drug and illegal immigration smuggling operations. Nonetheless, the USFWS would use this recovery plan to prohibit nighttime lighting and other than minimal human presence on the U.S. side of these border linkage corridors.

Sixth, the recovery plan effectively cedes our nation’s sovereignty over both any jaguar delisting decision and control of our southern border, within these trans-border linkage corridors, to the International Union for Conservation of Nature (IUCN). The IUCN is a foreign-domiciled, nongovernmental corporation that is entirely unaccountable to the citizens of the United States.

The recovery plan specifically cedes U.S. national sovereignty to the IUCN by requiring that the status of the jaguar, as classified in the “Red List” criteria of the IUCN, be changed to “Species of Least Concern” in each of 18 sovereign foreign nations, before the USFWS will even consider delisting the jaguar in the U.S.

Ironically, the IUCN has never classified the jaguar as endangered or threatened. Instead, as the USFWS admits in its own draft recovery plan, the IUCN lists the jaguar globally as “Near Threatened.”

The livestock industry further opposes this misguided plan because it threatens the very existence of iconic centuries-old border ranches. It does so by proposing to take away those ranches’ ability to use the waters they own and developed. It would reallocate the use of those waters as “shared” waters for jaguars. It further proposes to set aside vast swaths of currently highly productive and sustainably managed livestock range in AZ/NM as “livestock-free areas.” — all ostensibly for exclusive use by no more than possibly six transient, male jaguars over the course of the next 50 years.

Contrary to the tenor of Mr. Loomis’ article, the predator that ranchers and rational people of common sense fear the most is obviously not the jaguar. Rather, that predator is an overly zealous federal bureaucracy that is completely irrational, bereft of scientific credibility, and clearly out of any semblance of responsible control.