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Transcript
PYGMY RABBIT PETITION CONTENTS
I. Petitioners
II. Executive Summary
III. Nomenclature and Classification
Characteristics of Lagomorphs and Leporids
Taxonomic Status of the Pygmy Rabbit
Washington Rabbits, Near Extinct in the Wild, Have Been Placed in Separate DPS
IV. Description and Life History
General Appearance
Movement – Slow, Scampering Gait and Vulnerability in Open Areas
The Pygmy Rabbit Has Limited Reproduction Potential
Coprophagy Enhance Survival Under Stress
Social Behavior and Interactions
Periods of Activity
V. Specialized Habitat Requirements
Highly Specialized diet
Specialized Summer Habitat Use
Specialized Winter Habitat Use
Additional Habitat Components
Complex Structural Attributes of Big Sagebrush Habitats
Specialized Energy Conservation Strategies for Coping with Extremes of High Desert
Climates
Specialized Soil Requirements for Burrows
Specialized Burrow Locations and Characteristics
Use of Specific Topographical Features
Limited Home Range and Use Areas
Broad Array of Avian and Mammalian Predators
Extreme Habitat Specialization
Summary of Specialization
Limited Dispersal Ability Amplifies Effects of Habitat Fragmentation on Increasingly
Isolated Populations
VI. Historical and Current Distribution in Areas of Concern and Documented
Declines and Some Factors Causing Declines
Historic Geographical Distribution
Pygmy Rabbit Has Long Been on IUCN Red List
Current Population Distribution and Declines
Washington
Montana
Idaho
Wyoming
Utah
Nevada
California
Oregon
Summary of Rangewide Declines and Some Dispersal Barriers
How Much Has the Range of the Pygmy Rabbit Contracted Due to Habitat Loss and
Fragmentation
The Pygmy Rabbit Meets All Five Criteria for ESA Listing
VII. The Present or Threatened Destruction, Modification or Curtailment of Habitat
and Range and Factors Affecting the Species Survival
Evidence from ICBEMP and Other Sources Demonstrates the Extraordinary Loss
and Degradation of Habitat Faced by the Pygmy Rabbit
Upland Habitat Destruction and Alteration Rangewide
Riparian Habitat and Interfacing and Bordering Big Sagebrush Communities Have
Been Greatly Altered Rangewide
Landscape Level Fragmentation
Widespread Predicted Downward Trends in Big Sagebrush Habitats Rangewide
Impacts of Dramatic Loss and Fragmentation of Sagebrush Habitats to
Sagebrush-Obligate Species
Dire ICBEMP Population Viability Prediction
Separate ICBEMP Avian Analysis Further Demonstrates Shrub-Steppe Declines
USFWS 2002 Analysis Identifies Many Shrub-Steppe Avian Species of Concern
Settlement Impacts and Destruction of Sagebrush Habitats
Unresilient Sagebrush Communities Are Now Shattered
VIII. Factors causing Continued Modification and Curtailment of Habitat or Range
and Threats to Species Survival
Agricultural Expansion and Intensification Infringe on Big Sagebrush Habitats
Increased Efficiency of Irrigation Removes Habitat and Corridors
Water Projects – Dams, Reservoirs, Stock Ponds - Destroy Habitat and Are Barriers
to Dispersal
Exotic Species and Weeds Pose Alarming Threat to Pygmy Rabbit Habitats
BLM Westwide Weed EIS Demonstrates Agency Failure to Address Causes of
Alarming Weed Spread
Cheatgrass Invasion of Sagebrush Communities Precludes Use by the Pygmy Rabbit
Livestock Grazing Causes a Broad Array of Harmful and Ecologically Calamitous
Impacts Often Down-played by Agencies
Livestock Grazing Causes Behavioral Disturbance of Pygmy Rabbits
Livestock Grazing Increases Pygmy Rabbit Vulnerability to Predation and/or Shifts
Predator Balance with Unexpected Repercussions
Livestock Trampling Compacts Soils and Alters Soil Structure at Burrow Sites
Livestock Trampling Collapses Burrows and May Kill or Injure Pygmy Rabbits
Livestock Grazing and Trampling Cause Widespread Erosion of Soils and Loss of
Microbiotic Crusts Leading to Weed Invasion
Livestock Grazing Destroys Composition of Big Sagebrush Communities
Livestock Grazing Radically Alters Shrub Structure
Livestock Fences Degrade and Fragment Upland Habitats and Aid Predators
Livestock Water Developments Degrade and Destroy Pygmy Rabbit Habitats and
Benefit Predators
Water Hauling for Livestock Demolishes Pygmy Rabbit Habitats and Benefits
Predators
Livestock Wells and Pipelines Destroy Sagebrush –New Well Drilling Underway
Riparian Fencing Shifts Intensive Livestock Use to Unresilient Sagebrush Uplands
Placement of Salt and Mineral Supplements in Uplands Destroys Big Sagebrush
Habitats
Holistic Grazing/Intensive Herding Destroys Big Sagebrush Habitats
Rest Rotation Grazing Schemes Flood Rabbit Habitats with Livestock
Drought Exacerbates Livestock Grazing Impacts and Competition
Fire Kills Pygmy Rabbits and Destroys Critical Sagebrush Habitats
Fire Impacts - Montana
Fire Impacts - Idaho
Fire Impacts - Wyoming
Fire Impacts - Utah
Fire Impacts - Nevada
Fire Impacts - California
Fire Impacts - Oregon
BLM Plans to Weaken NEPA and Project Review
Escalating Agency Fire Plans and Vegetation Manipulation Threaten Big Sagebrush
Habitats
Juniper Increases in Big Sagebrush Sites Caused by Grazing Can Not Be “Treated”
with Fire Without Killing Sagebrush and Opening Sites to Weed Invasions
Increased Herbicide and Pesticide Use Looms for Sagebrush Wild Lands
Land Disposal and BLM Proposal to Dispose of Surface Rights to Ranchers
Powerlines Dissect Habitat, Provide Predator Perches, and Result in Predator Travel
Corridors and Weed Expansion
Roads Dissect Habitat, and Provide Weed and Predator Travel Corridors
Road Improvement and Proliferation Intrudes on Big Sagebrush Habitats
Exploding ORV Use on Public Lands Threatens Pygmy Rabbits and Critical Big
Sagebrush Habitats
Snowmobile Use Disturbs Winter Habitats Crushing Shrubs and Compacting Snow
and Subnivian Tunnels
Recreational Site Development Threatens Big Sagebrush Habitats
Expanded Military Training Range Infrastructure and Extreme Noise and Disturbance
Infringe on Big Sagebrush Habitats
Hard Rock Mining Exploration, Development and Expansion Threaten Big
Sagebrush Habitats
Runaway Oil and Gas and Coal Bed Methane Exploration and Production Are
Destroying Habitat and Pose Dire Threats to Wyoming Populations
New Wind Power Boom and Energy Speculation Threatens Sagebrush Habitats
Geothermal Exploration and Development Boom Threaten Pygmy Rabbit Habitats
Fragmentation of Sagebrush Habitats is Accelerating Throughout the Range of the
Pygmy Rabbit Due to All Preceding Activities and Disturbance
Habitat Connectivity Has Been Severed, and Natural and Human-Caused Barriers
Prevent Pygmy Rabbit Dispersal
IX. Overutilization for Commercial, Recreational, Scientific or Educational
Purposes
Hunting Harms Populations at Low Levels
Research Activities May Harm Populations at Low Levels
Persecution of Rabbits by Ranchers and Farmers Impacts Populations
X. Disease or Predation
Disease Poses Serious Threats to Pygmy Rabbit Populations
Predation May Impact Small Populations in Degraded and Altered Habitats
Sagebrush Mortality Agents May Kill Essential Sagebrush
Flooding May Kill Rabbits, Flood Burrows and Erode Deeper Soils
XI. Inadequacy of Existing Regulatory Mechanisms
Federal Efforts to Protect the Pygmy Rabbit Have Utterly Failed
Federal Agencies Fail to Protect Special Status Species Habitats
BLM Land Use Plans Are Woefully and Illegally Outdated
Livestock Grazing Use Standards Are Known to Result in Harm to Sagebrush
Communities – 50% or Higher Use is Routine
No Agency Standards Measure or Mitigate Livestock Physical Damage to Sagebrush
Habitats
Enforcement of Grazing Use Standards is Very Lax
BLM Analyses Routinely Ignore Valid Assessment of Habitats
Limited Agency Budgets Result in General Neglect of Special Status Species
BLM Decisionmaking Routinely Defies Agency Policy for Special Status Species
and Ignores Science: Hawley Creek “Bunny Heaven”
BLM Decisionmaking Processes Are Stalled, Protected or Thwarted by Livestock
Interests So Environmental Harm Continues
Habitat Needs of Aquatic ESA Species Trump Concerns for Sagebrush Uplands
Narrow Scope of USFWS Bull Trout Critical Habitat and Recovery Plan Threatens
Even More Shifting of Grazing Impacts to Pygmy Rabbit Upland Habitats
Agencies Blatantly Disregard Needs of Sagebrush Obligate Species
Harmful Single Species Management Mindset Plagues Agency Planning Efforts and
Actions
Long-Standing Range Profession Biases Against Big Sagebrush Have Gained New
Momentum with Current Agency Fire and Vegetation Manipulation Frenzy
Agency Failure to Restore Burned Lands Threatens Recovery Of Native Sagebrush
Habitats
Chronic and Unalleviated Livestock Degradation and Destruction of Sagebrush Wild
Lands Continues Uncontrolled Throughout the Range of the Pygmy Rabbit
BLM Fails to Designate Areas of Critical Environmental Concern to Protect Critical
Sagebrush Habitats
Land Managers and Some Researchers Fail to Forthrightly Acknowledge and
Address Livestock Grazing Harms
Federal Wild Land Fire Management Policy Threatens Sagebrush Habitats
National Energy Policy Accelerates Energy Activities That Destroy and Fragment Big
Sagebrush Habitats
Management of Protected Areas with Recent Pygmy Rabbits Populations is
Incompatible with Pygmy Rabbit Habitat Needs
DOE-INEEL Sagebrush Steppe Reserve Fails to Protect 60% of Lands from
Intensive Livestock Grazing
USFWS Sheldon-Hart National Refuge is Rapidly Burning Up Critical Big
Sagebrush Habitats
Snake River Birds of Prey National Conservation Area Suffers from Ill-regulated
Grazing, and Fire and Weeds
State Efforts Have Been Ineffective or Nonexistent
Conservation Status of the Pygmy Rabbit
XII. Other Natural or Human-Caused Factors Affecting the Species Continued
Existence
Many Facets of Intraspecific and Interspecific Competition Impact Pygmy Populations
Competition with Other Pygmy Rabbits for Food or Space
Competition with Other Native Species for Food or Space
Competition with Exotic Species for Food or Space
Predator killing as a Result of Livestock Presence May Upset Natural Balances and
Increase Predation Impacts
Predator Killing Avoids Addressing Habitat Loss and Destruction
XIII. Severe Population Level Impacts of Habitat Loss, Degradation and
Fragmentation of Big Sagebrush Habitats
Environmental Stochasticity and Catastrophic Events Effect Extinction Risk of Pygmy
Rabbit Populations
Variable High Desert Sagebrush Environment Increases Extinction Risk
Perils of Low or Depressed Population Size: Demographic and Genetic Stochasticity
Increases
Extinction Risk
Vulnerability of Pygmy Rabbit Populations to Extirpation
Other Factors Affecting Population Viability and Fitness
Pygmy Rabbit Biological Traits and Extremely Specialized Habitat Characteristics
Increase Extinction Risk
Pygmy Rabbits May Now Exist Primarily in Peripheral Habitats and Populations
Importance of Geographically Peripheral Populations
Population Cyclicity
Habitat Degradation, Fragmentation, Barriers and Landscape Effects
Landscape Level Protection and Immediate Management Change Is Critical
Importance of Maintaining All Current Populations
Discovery of Any More Larger Populations Is Very Unlikely
Perils of Reintroductions of Captive Rabbits
XIV. Critical Habitat Designation Requested to Protect Pygmy Rabbits in the
Intermountain and Great Basin Region from Extinction
XV. Benefits of ESA Listing
XVI. Emergency Listing May Be Warranted
XVII. Conclusion
Pygmy Rabbit Petition Bibliography