Letter of comment on the draft of the Lynx Conservation Assessment and Strategy (3rd edition); submitted collectively by Montana, Colorado, Idaho, Wyoming, Utah, New Mexico, and Oregon state wildlife departments

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This letter provides comment submitted collectively by seven western states’ wildlife agencies on the draft of the Lynx Conservation Assessment and Strategy (LCAS), 3rd edition, which had been written and sent out for comment in 2012 by the Interagency Lynx Biology Team, prior to a desired 2013 publication date. This letter presents specific concerns and suggested edits regarding issues of habitat designations, climate change, threat factors, vegetation management, incidental trapping take and illegal shooting, highways, recreation, research and monitoring, and Interagency Lynx Biology Team membership. Overall, the document was found by the state representatives to be a good compilation of some of the recent science pertaining to lynx. But the states were not supportive of the document as written, citing concerns about an unclear purpose for the revision, disregard of the importance of a true state–federal partnership in moving lynx conservation forward, lack of a true assessment of the status of lynx and effectiveness of conservation measures, and negative speculation about potential impacts of activities that are not presented in context of actual impacts on lynx viability. The states were disappointed that, after more than 12 years and significant accomplishments by the federal land management agencies to address the threat that had been cited by the U.S. Fish and Wildlife Service—lack of adequate regulatory mechanisms, there has been no effort to develop a recovery plan and work towards delisting. This failure, in the states’ view, is a major impediment toward developing an acceptable recovery plan and delisting.

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