Comments on the Draft Recovery Plan for the Sonoran Pronghorn, Second Revision and U.S. Fish and Wildlife Service (FWS) response to comments

Public Review A draft of Recovery Plan for the Sonoran Pronghorn, Second Revision (hereafter referred to as “plan”) was published and distributed for review to all interested parties. The Service published a notice in the Federal Register on July 2, 2015 (80 FR 38226) to announce that the document was available for public review and comment. The comment period lasted for 30 days and closed on August 3, 2015. An electronic version of the draft plan was posted on the FWS’s Southwest Region website (http://www.fws.gov/southwest/es/Documents/SpeciesDocs/SonoranPronghorn/SonoranPronghorn_DraftRecoveryPlan_Final_December2014.pdf) and the Arizona Ecological Service’s website (https://www.fws.gov/southwest/es/arizona/Documents/SpeciesDocs/SonoranPronghorn/SonoranPronghorn_DraftRecoveryPlan_Final_December2014.pdf) Peer Review We asked 6 individuals to serve as peer reviewers of the document, including 3 from Mexico and 3 from the U.S. Five reviewers provided comments. The qualifications of the peer reviewers are in the administrative record for this plan. Public Comments Received We received comments from 5 federal agencies (in the U.S. and Mexico), 1 state agency, 1 non-profit organization, and 1 individual citizen. Responses to Comments The FWS appreciates the thoughtful comments provided during the public comment period and recognizes the importance of public involvement in the recovery of the Sonoran pronghorn. The FWS reviewed all comments received for substantive issues and new information. These are addressed in the following summary and the draft Recovery Plan was revised as appropriate. The final Recovery Plan, Second Revision is the product of many years of work on the part of the Recovery Team and numerous federal, state, and local organizations. Nearly all comments provided were supportive of the recovery plan overall and offered constructive advice that has improved the plan. Some commenters suggested editorial changes to the text of the plan and we have incorporated suggestions as appropriate. Some commenters suggested additions and clarifications, and we tried to clarify the document and have accommodated these suggestions as appropriate. Substantive comments were taken into consideration in this final version of the plan, and specific responses are provided below. Many of the comments are summarized below for brevity. Comments are arranged into nine categories based on the related topics of the comments: (A) threats; (B) current management; (C) goal,

strategy, objectives; (D) conservation units; (E) recovery criteria; (F) recovery actions; (G) research; (H) implementation schedule; and (I) appendices. Acronyms BLM: Bureau of Land Management BMGR: Barry M. Goldwater Range CBP: Customs and Border Protection CPNWR: Cabeza Prieta National Wildlife Refuge MCAS: Marine Corps Air Station Yuma (managers of the Barry M. Goldwater Range West) NPS: National Park Service, Organ Pipe Cactus National Monument ORPI: Organ Pipe Cactus National Monument PVA: Population Viability Analysis RBP: Reserva de la Biosfera El Pinacate y Gran Desierto de Altar (Pinacate Biosphere

Reserve) RMO: 56th Range Management Office at Luke Air Force Base (managers of the Barry M.

Goldwater Range East) USBP: U.S. Border Patrol WWP: Western Watersheds Project

A. Threats Commenter

Affiliation Comment FWS Response

1 BLM Quartzsite Solar project area is outside the 10(j) area.

We corrected the text.

2 BLM Sonoran Solar is outside the 2015 distribution range of Sonoran pronghorn.

It is within the nonessential experimental population area.

3 BLM Maricopa Solar Park is outside the 2015 distribution range of Sonoran pronghorn.

It is within the nonessential experimental population area, but in an area that does not currently have pronghorn.

4 BLM The Brenda SEZ is outside the 10(j) area. We corrected the text. 5 BLM Not all roads or transmission corridors are

likely to hinder or preclude pronghorn movement through the area.

We corrected the text.

6 BLM Most unfenced roads are likely not barriers to movement. The level of impact associated with roads depends on the volume of traffic.

We added new information based on new observations.

7 BLM Suggest consideration of Sonoran Rapid Ecoregional Assessment climate models and discussion. Strittholt, J.R., S.A. Bryce, B.C. Ward, and D.M. Bachelet. 2012. Sonoran Desert Rapid Ecoregional Assessment Report. http://www.blm.gov/wo/st/en/prog/more/Landscape_Approach/reas/sonoran.html#memo

We reviewed and added information from the report in the plan.

8 BLM There is no documentation that Brassica We deleted Sahara mustard from this paragraph.

presence is related to fire, nor does it increase fire frequency (under Altered Fire Regimes).

9 BLM BLM treats NEPs as Proposed Species (according to BLM Manual 6840) requiring conference with the USFWS on actions or activities that are likely to adversely affect the species.

To clarify this, we added: The BLM has additional requirements in their policy manual (Manual 6840) that direct them to confer with the USFWS on actions or activities that are likely to adversely affect the species.

10 AGFD Throughout the text paved roads are often not distinguished from dirt roads and two tracks. There is no question public paved roads with fences are significant barriers to pronghorn movement. It is not clear that lightly used dirt roads and two tracks are barriers to movement. The text should make distinctions between road types and the effect as a barrier.

We clarified this in text.

11 NPS As noted for the Quitovac population that mining is a major possible threat, it would be consistent to note in the Cabeza population that border issues are one of the greatest adverse influences on this population.

Human disturbance is discussed in detail beginning on page 54.

12 NPS Commenter noted that there is a 5.2-mile pedestrian fence on ORPI within the range of Sonoran pronghorn.

This is one exception to the "most" of the fence that is passable by pronghorn discussed in the plan. Pronghorn avoid urban areas where the much of the pedestrian fence is placed.

13 NPS Regarding grazing, mention that though grazing has not been present in our area for 40 years, the adverse effects are still recovering, we have a long way to go before the ranges even remotely resemble what existed prior to the heavy impacts imposed by cattle in the 19th and 20th centuries

Pronghorn are generalists in selecting forage, so although we agree the vegetation has not recovered to the pre-grazing state, the vegetation species composition is suitable for pronghorn now.

14 NPS In vehicle collisions section: In April 2015, a pronghorn fawn, unknown sex, was struck and killed by a vehicle on HWY 85 in Organ Pipe Cactus NM.

We included this information.

15 Peer Reviewer #1

Page 1: "In summer 2002, the U.S. population of Sonoran pronghorn was almost extirpated due to the most severe drought on record in southern Arizona." add: The effects of which were exacerbated by other threats, including restriction of available habitat, rapid increase in border-related human disturbance, disease, and others.

We will add these factors to the text (on page 1) with the exception of disease, which is not well known. These threats are discussed in detail in the threats section of the text.

16 Peer Reviewer #1

Page 42, table 3: Maybe change this [capture myopathy] to “capture-related mortality” since some are due to physical

We made this change.

trauma (e.g. spinal injury), not myopathy. 17 Peer

Reviewer #1 Page 57, altered fire regimes, says "Fires burn creosotebush, which is a very competitive species, and create openings for plants that are more valuable as forage for pronghorn." On the other hand, in spring greenup after average winter rains, growth of forbs (pronghorn forage) is typically tallest and most dense around and under creosote, because of the creosote’s shading effect creating a slightly cooler/moister microclimate.

We added this counterpoint, but also add that we do not have documentation of high utilization of forbs to the point where they are unavailable. There appear to be too few pronghorn within a very large landscape for the forage to be impacted (J. Hervert pers. com.)

18 Peer Reviewer #1

Page 57: Fire can also have adverse effects by causing mortality of ironwood, mesquite, paloverde, and other desertscrub trees/shrubs, which provide thermal cover and important browse.

We added this point. We also stated more clearly that little is actually known about the influence of fire on Sonoran pronghorn.

19 Peer Reviewer #1

Commenter suggested that we more include literature (examples provided) regarding fire and vegetation change. Commenter noted the loss of creosote during the 2002 and 2009 droughts. ORPI and others have repeat-photo documentation.

Fire is discussed in various sections of the plan, including the recovery actions where we include investigating the effect of fire on Sonoran pronghorn.

20 Peer Reviewer #1 and NPS (similar comments)

Regarding buffelgrass distribution, it distributed widely across ORPI and CPNWR (see NPS reports on buffelgrass management). Peer reviewer provided more detailed information on its distribution. Commenter noted it is also found along the international border with Mexico. Control and removal efforts are ongoing.

We added this information to the text.

21 Peer Reviewer #1

Commenter remarked that contaminants should be mentioned as a possible threat factor and specifically mentioned the potential for lead exposure on the target areas on BMGR.

Fawn production is good, and pronghorn are increasing on the BMGR, so we do not suspect contaminants are a threat on the BMGR.

22 WWP The work of WWP’s Arizona office (established in 2007) has especially emphasized the adverse impacts of large, domesticated, non-native herbivores on the Sonoran desert landscape and its unique species. These impacts extend to the direct and indirect imperilment of the Sonoran pronghorn, and public lands management in pronghorn habitat Arizona that allows ongoing cattle grazing is in fundamental conflict with the recovery and resilience of the pronghorn population.

Livestock grazing is discussed in various sections of the plan and limiting such grazing is included as a recovery action.

23 WWP Commenter remarked that while the draft plan recognizes that livestock grazing on

As a means to reduce grazing where needed, the recovery team included action: 2.5.1.1.3. Provide

BLM-administered land is a valid use under the Taylor Grazing Act of 1934 (TGA), the Federal Lands Policy and Management Act of 1976 (FLPMA), and the Public Rangelands Improvement Act of 1978 (PRIA; draft RP at 41), it is worth noting that none of these laws require public lands to be grazed. Under the TGA, the Secretary of the Interior is supposed to designate lands that are chiefly valuable for grazing in order to promote their highest use. 43 U.S.C § 315. Under FLPMA, public lands are to be managed in a manner that will protect the scientific, scenic, historical, ecological, environmental, air and atmospheric, water resources and archeological values. P.L. 94-579 as amended. The PRIA admits that vast segments of the public rangelands are “producing less than their potential for livestock, wildlife habitat, recreation, Working to protect and restore Western Watersheds and Wildlife forage, and water and soil conservation benefits,” and authorizes the Secretary to determine that grazing uses on certain lands should be discontinued temporarily or permanently. P.L. 95-514.

financial incentives/ and other income opportunities to ranchers to reduce livestock grazing.

24 WWP The FWS should develop the recovery plan in accordance with the best science rather than to maintain the entrenched land uses that continue to degrade pronghorn habitat. If the BLM can’t manage grazing in accordance with the recovery plan criteria, then grazing must yield. The experimental, nonessential classification for the Kofa area pronghorn doesn’t mean the agencies are free to thwart full recovery of the species. Under 7(a)(1) of the Endangered Species Act, BLM must conserve listed species. Section 7 of the Endangered Species Act requires consultation, and 10(j) populations are to be treated as a proposed species for this purpose. This means a conference may be conducted instead of a full consultation. Under 50 C.F.R. §402.10, such a conference should document any recommendations provided by the Service to the federal agency; the outcomes and recommendations of the conference on the Kofa pronghorn should be disclosed and incorporated into

The best science available has been used to develop the recovery plan. The plan includes a thorough discussion on how 10(j) populations are treated under section 7. Any conference opinions written are posted on the AESO website.

the recovery plan. The Service may also request a conference, and based on some of the information below, may find this path advisable.

25 WWP There are two active allotments within the range of the Cabeza Prieta population and 20 active allotments in the Kofa population area, and about 44 percent of this area occurs within BLM allotments. Draft RP at 41. This makes adverse grazing impacts a dominant threat to the 10j population, and worth addressing in the recovery plan with firm monitoring plans and compliance criteria.

The statement that 44% of the Kofa population area is within BLM allotments is outdated and has been replaced. Only 27% is within BLM allotments. Although monitoring actions are included in the recovery plan (see the recovery actions), compliance criteria are not a part of recovery planning because recovery plans are guidance documents and implementation is voluntary.

26 WWP The summary of threats identifies livestock grazing as contributing to habitat loss, reduced forage quality, altered habitat structure, and human disturbance, contributing to ESA listing factors A and E. But livestock grazing also contributes to habitat fragmentation, reduced access to water and reduced availability of water, and potentially increases the threats of disease and high mortality, which are issues that the draft plan fails to address. While studies specific to livestock grazing’s effects on the Sonoran pronghorn are scarce (due, in part, to the fact that much of the range prior to the Kofa reintroductions was ungrazed), numerous other studies documenting the impacts of livestock grazing on other subspecies can be used to infer potential effects on the Arizona populations. A comprehensive review of those studies is contained in Hall, et al 2006, “Impacts of Livestock Grazing in the Sonoran Desert,” and includes effects such as interspecies agonism, competition, habitat alteration, disease transmission, and range nfrastructure. One study documented impacts to fawning sites based on livestock avoidance (McNay and O’Gara 1982 in Hall et al 2006 at 8.20), and evidence of cattle-to-pronghorn aggression and fawn flushing and trampling.

Livestock grazing is also considered a source of habitat fragmentation and disease in conceptual models (Appendix A). Also, in the threats section on "habitat fragmentation caused by habitat conversion" the recovery plan states: Fragmentation is caused by the same sources as for “habitat loss” discussed above (mining, agriculture, and livestock grazing). The summary of threats table in the recovery plan lists "habitat conversion" as a source of habitat fragmentation. Habitat conversion includes excessive livestock grazing, when it occurs to a level that destroys habitat. This level is documented in Sonora, Mexico Sonoran pronghorn habitat, but has not been documented in the U.S.

27 WWP Scientific studies suggest that forage competition may be lessened when rangelands are in good condition, but competition between pronghorn and cattle can potentially occur on a seasonal basis or during drought conditions. Yoakum et al

The effects of cattle grazing are discussed in the threats section. We added in "Kofa" to the threats tracking table (for excessive grazing contributing to reduced forage quality). Also see action 5.9.

1996 in Hall et al at 8.20. 28 WWP The sensitivity of pronghorn to grazing

livestock appears to be underestimated in the draft plan. Though the draft plan discusses ranching activities (road use, haul trucks, and human presence) as being potentially disruptive, the very proximity to cattle could cause unnecessary physiological stress, particularly in areas where livestock are only occasionally present (e.g. ephemeral allotments). Haul trucks are also more common disturbances on allotments with ephemeral authorizations, as numerous livestock will be turned on and off of allotments within a short period of time rather than the annual round-up common with year-long grazing operations. These impacts would certainly affect pronghorn stress levels and the FWS should seek agreements with BLM to restrict livestock use within pronghorn habitat.

The effects of human disturbance (including disturbance from ranching activities) is included in the human disturbance section. Ranching activities are considered one source of human disturbance (see appendix A: conceptual models). Please see the recovery action narrative for numerous actions designed to reduce effects of livestock grazing and human disturbance.

29 WWP The hot season preference of pronghorn for desert washes also sets up a source of conflict with grazing operations. The washes offer vegetation diversity and thermal cover properties that are not extant on adjacent uplands; cattle prefer these ecotypes as much as pronghorn do. Because of social avoidance and forage competition, the presence of livestock on BLM allotments and in washes makes these sites less hospitable to pronghorn, undermining the recovery potential of these lands.

We added to the threats section: Cattle may compete with Sonoran pronghorn for forage and preferred thermal cover; however, no studies have focused on this topic, therefore we do not know the extent to which this may occur in areas where Sonoran pronghorn and cattle overlap. See action 5.9.

30 WWP Additionally, shallow groundwater withdrawn or surface water impounded for livestock use in the uplands negatively affects the flows in ephemeral and perennial washes that would otherwise provide metabolic water and forage for pronghorn.

Any capture of runoff is miniscule in comparison to the amount that runs off.

31 WWP The effect of livestock infrastructure on pronghorn habitat should be examined in the plan and recommendations to limit or remove grazing related hydrological disruptions should be included for grazed lands. Though the draft plan admits that fences are a cause of habitat fragmentation, it does not include livestock grazing as a fundamental cause of this barrier to movement and source of mortality. The

We added that some fences are associated with livestock management and that we don’t have an estimate of the length of barriers, including fences.

draft plan doesn’t identify the number of fences within the current range of pronghorn or the number of fences that have been modified to be pronghorn “friendly.”

32 WWP The increased frequency and severity of drought is also amplified by the impacts of livestock on the grazed lands within the recovery area, something the draft plan fails to discuss. Livestock-induced soil compaction and increased erosion cause reduced water retention in the desert soils when the rains do come.

The effects of drought are exacerbated by all threats, and a statement has been added to the plan.

33 WWP The discussion of habitat structure alteration fails to discuss the impacts of livestock grazing on hiding cover and multi-layered canopy cover. The draft focuses instead on the contribution of grazing to increased shrub cover. Though shrub encroachment and increased density can be attributed to excessive grazing, a major impact of grazing is the diminishment of the understory of nurse/canopy trees. Livestock congregate in these shady places, knocking down the vines and shrubs and young cacti that are exploiting the same microhabitats. This leaves fewer places for concealment for pronghorn, and this effect is not measured by BLM in its standard monitoring protocols.

Concealment is not very important to adult Sonoran pronghorn, but could possibly affect fawning areas. Thermal cover in hot summer months is important to pronghorn. However, we have no evidence that diminishment of the understory can impact Sonoran pronghorn thermal cover positively or negatively.

34 WWP It is not clear why the draft plan neglects to discuss the Kofa population as being threatened by livestock grazing. Clearly, the recovery of the pronghorn throughout its range on BLM lands depends on reducing livestock grazing impacts to the species.

Recovery actions for reducing the threat of livestock grazing on the Kofa population are in the recovery action narrative and implementation schedule. At the time the first threats analysis was conducted, the Kofa population was not ranging into active allotments and the population was not added to threats tracking table. As the population has ranged farther, we added recovery actions to address threats from grazing, and have now added the Kofa population to the threats tracking table.

35 PBR In the PBR, burros occur mainly in the mountainous areas and we are working to control and eradicate them.

We added this to the plan.

36 PBR Commenter noted that salt cedar should be included as an issue for pronghorn since it grows in high dense patches along playas of the Sonoyta river, potentially blocking pronghorn access to water.

We added this to the plan.

B. Current Management Commenter

Affiliation Comment FWS Response

1 BLM In 2004-2005, BLM closed 55,000 acres (Cameron Allotment) to livestock grazing to improve habitat conditions for pronghorn, removed fences from around 2 dirt tanks and 2 wildlife water catchments and installed 3 ground level water troughs at wells to improve pronghorn access to water.

We added text to the plan.

2 NPS Table 4: How is survival defined? In other words, how long must an animal live, post release, to be defined as survival?

We use until the end of September the following year (so not a whole year, about nine months depending on when we release them). It is tied somewhat to how long some of the collars work, but more importantly we believe that if they can get through their first summer in the wild, they have “survived”.

3 Peer Reviewer #1

The BMGR monitoring program should be listed as an ongoing conservation effort. Pronghorn use the live-firing areas frequently, sometimes in large groups. It is reasonable to conclude that the monitoring/redirect program, in place for almost 15 years, has prevented some pronghorn mortalities. The fact that no firing-related mortalities were ever documented prior to this program is not very meaningful. There was little or no effort to look for mortalities.

We added the program to ongoing conservation efforts. We changed the statement to say no mortality has been documented since the inception of the BMGR monitoring program.

4 Peer Reviewer #1

Page 61: The fences were removed, not just modified.

We added this text to the plan.

5 Peer reviewer #1

Name all forage enhancement plots. Are they all functional?

We added a map of pronghorn waters and forage enhancement plots with names. We clarified that as of October 2015, two out of the five plots are working.

6 Peer reviewer #1

Are all pronghorn waters used? How frequently?

We noted that pronghorn have been observed routinely using the developed waters.

7 Peer reviewer #1

Commenter remarked that Sonoran pronghorn are not being domesticated through the breeding program and provided rationale for this. The plan should acknowledge that there may be some habituation of captive-bred pronghorn to human presence, but that this habituation is generally temporary and pronghorn become less habituated the longer they have been in the wild. Some examples from the field were provided. A question was raised about the effects of possible temporary habituation

We agree with the comment on domestication. Regarding habituation, there has been much debate and counterpoints made about this topic and we solicited input from both sides of the debate, and included some of their text and responses. We reworded the discussion in the plan to present your observations.

– could it be beneficial as pronghorn may be less prone to human disturbance or could it be detrimental as pronghorn might put themselves in danger (like moving to close to roads).

8 Peer reviewer #1

"From 2006 to 2014, 128 pronghorn from this pen have been released into the wild." It might help to specify here that the 128 all went into the Cabeza population, and others went to Kofa.

We revised Table 4 to clarify this.

9 RBP Commenter requested that we update information on the number of species managed by CONANP under the PROCER.

We updated the plan accordingly.

10 RBP Commenter requested that we include information on the pronghorn studies being conducted by RBP and Espacios Naturales A.C. Specific information was provided.

We updated the plan accordingly.

11 RBP Commenter requested that we include information on CONANP’s authorities to manage pronghorn in the zone of influence of the reserve; and the agreements between CONANP and CEDES to recover pronghorn. Specific information was provided.

We updated the plan accordingly.

C. Goal, Strategy, Objectives Commenter

Affiliation Comment FWS Response

1 NPS Define viable in the strategy section. Viable is defined in the recovery criteria. 2 NPS Add text in bold: “The recovery goal is to

conserve and protect the Sonoran pronghorn and its habitat so that its long-term survival is secured, so that populations within the CUs can be self-sustaining and capable of enduring and surviving the multiplicity of threats, and it can be removed from the list of threatened and endangered species (delisted).

Changed to: The recovery goal is to conserve and protect the Sonoran pronghorn and its habitat so that its long-term survival is secured, populations within the conservation units are capable of enduring threats, and it can be removed from the list of threatened and endangered species (delisted).

3 NPS Add an objective: “Where possible, feasible and advantageous, restore habitats and forage diversity using native species favored and browsed by pronghorn.”

Sonoran pronghorn habitat restoration is included in recovery action 2.2.4.2.

4 Peer reviewer #2

Recovery strategy, page 72, states: "To achieve that goal, the recovery strategy is to secure a sufficient number of Sonoran pronghorn populations that are viable under appropriate management scenarios within select areas throughout their historical

The recovery criteria section provides more specific information on what is considered sufficient.

range." Could a more concrete term than "sufficient" be used?

5 Peer reviewer #2

"Natural state" is highly subjective and debatable; suggest changing to "pre-Columbian."

We don't know what the pre-Columbian state is either. We changed the first sentence to "The Recovery Team’s objective is to conserve Sonoran pronghorn in as natural of a state as possible, meaning that least amount of active management required to recover the pronghorn will occur."

6 Peer reviewer #2

Perhaps consider removing this [objective of resiliency]? I wonder if Sonoran pronghorn populations were ever very large. The species may have persisted primarily through redundancy, rather than high resiliency. In such a harsh landscape, with a species that already shows very large home ranges, it seems likely that large populations could be ecologically impossible. It might be challenging to maintain large numbers of pronghorn in some areas. This would affect the recovery plan by shifting focus towards greater redundancy.

Our recovery guidance requires that the 3 Rs be addressed in recovery plans. Although Sonoran pronghorn populations are not as large as other pronghorn populations, population size (for Sonoran pronghorn) is still an important aspect of maintaining resilient populations.

7 Peer reviewer #2

Recovery goal: change "survival" to "persistence." The former is a demographic term.

We used the words "long-term survival" because it is used in the FWS definition of recovery.

8 Peer reviewer #2

Recovery objective 1: can "multiple viable populations" be replaced with a number? >3?

The recovery criteria section defines multiple viable populations (at least 3 free-ranging populations).

9 Peer reviewer #3

In several places, the plan refers to positive growth. Is this really a goal, or is having populations up around K the goal? These aren’t the same thing, and pronghorn demography will look very different under the two scenarios. If the goal of the plan is for populations to expand beyond their recovery areas, which would lead to long term growth despite being at K within the recovery areas, this should be clearly stated in the recovery plan.

We rewrote this to say: “To be considered viable, a population must meet or exceed the abundance targets and demonstrate a population growth rate that is stable or increasing (r ≥0) for at least five of seven years." Populations are not close to K, so it is unlikely they will expand beyond recovery areas.

10 Peer reviewer #3

Objective 2 is heavy on monitoring and low on well-defined habitat improvements. I would suggest investing this effort instead in habitat modification and restoration and direct monitoring efforts towards pronghorn responses to these habitat changes, a more experimental approach.

Recovery Objective 2 says, "Ensure that there is adequate quantity, quality, and connectivity of Sonoran pronghorn habitat to support populations." Action 2.1. is to "Assess the quantity and quality of Sonoran pronghorn habitat" so we can begin adaptive management and track changes over time as we implement management actions. After that, Recovery Actions 2.2. through 2.8. are to protect and restore habitat.

D. Conservation Units Commenter

Affiliation Comment FWS Response

1 NPS Add text in bold: “The Mexico Conservation Unit includes the historical range of Sonoran pronghorn (delete in Mexico) in the Mexican state of Sonora.”

Added: primarily in the Mexican state of Sonora.

2 Peer Reviewer #4

Commenter provided positive feedback on Conservation and Management Units and the importance of pronghorn populations in Mexico discussed in the plan. A comment was made about past evidence of pronghorn moving between management units, with a question regarding how separate these groups of pronghorn are both socially and with respect to genetic diversity. Traffic along Highway 2 has increased recently, both frightening and respresenting a physical threat to pronghorn. More needs to be known on when, how, and how often wildlife passages under Highway 2 are used. Recommend including an action to rebuild highway fences to funnel pronghorn to the passages to avoid dangerous highway crossing; and monitor their usage.

Barriers between Sonoran and Arizona and between Quitovac and Pinacate are discussed in the plan. We agree that more should be studied regarding movements of animals in Sonora and their potential use of the recently installed wildlife underpasses on Mexico Highway 2. These are addressed under recovery action 2.6 in the plan.

3 Peer reviewer #2

Conservation units: …2) are "important" to the recovery of Sonoran pronghorn. Vague. Could a more specific term be used…”constituting a substantial portion of the Sonoran pronghorn’s current or former range”

Added: (e.g., constitute a substantial portion of the Sonoran pronghorn’s current and historical range)

4 Peer reviewer #2

Change last sentence of description of U.S. Conservation Unit to: Sonoran pronghorn in the U.S. are nearly geographically separated from Sonoran pronghorn in Mexico due to Mexico Highway 2 and associated fencing (add: and U.S. Customs and Border Protection associated roads, fencing, and patrol actions.)

Sonoran pronghorn cross dirt roads routinely, so we did not add language about the CBP roads. We also explain in the plan that the international border fence between Mexico and ORPI and CPNWR is primarily a vehicle barrier fence that is passable by pronghorn. The sentence was changed to: Sonoran pronghorn in the U.S. are effectively geographically separated from Sonoran pronghorn populations in Mexico due to the physical barriers of Mexico Highway 2 and associated fencing.

E. Recovery Criteria Commenter

Affiliation Comment FWS Response

1 MCAS Commenter remarked that the increase from 250 to 300 animals in the Quitovac recovery

The probability of extinction modeled for other populations was much lower: Pinacate (6.1%), Kofa

criteria as not warranted or properly justified because the 9.2% probability of extinction has not surpassed 10%.

(1.4%), and Cabeza Prieta (0.6%); warranting extra precaution for the Quitovac population. Also, as indicated in the justification: the larger target value for Quitovac reflects that population’s comparatively higher levels of instability, based on the judgment of species experts participating in this analysis because of the following: 1) considerable fluctuations in population abundance; 2) relatively higher levels of demographic instability in its current habitat; and 3) higher levels of uncertainty regarding how the population will respond to threats such as climate change.

2 MCAS Commenter remarked that the recovery criteria should be wholly attainable in the U.S. as U.S. agencies have an expectation to implement recovery of the species.

Service policy mandates that we must address recovery of the listed entity, which includes pronghorn in Sonora. We could not biologically justify not including the populations in Mexico in the criteria.

3 MCAS Commenter remarked that the California Reintroduction Management Unit be fully considered and analyzed and included as one of the possible three populations to achieve recovery. Among other things, this would make recovery more achievable and allow more management flexibility.

The California Reintroduction Management Unit is too early in the planning process to be fully analyzed; however, recovery criteria were modified to allow for different combinations of populations to achieve the criteria that at least 3 free-ranging populations are viable.

4 NPS Commenter remarked that the demographic delisting criteria leave open the possibility for the populations to crash four times in 14 years as the long-term trend is positive.

We recognize that this may be a reality; populations may decline below management targets from time to time, but with the management actions implemented since 2002, the objective for a long-term positive growth rate seems achievable.

5 NPS "The Recovery Team defined a viable population of Sonoran pronghorn as one that has less than a 10% probability of extinction over 50 years and a positive growth rate." Populations should grow when initially established, then level off and fluctuate.

Text has been changed to "The Recovery Team defined a viable population of Sonoran pronghorn as one that has less than a 10% probability of extinction over 50 years and a growth rate that is stable or increasing."

6 NPS Commenter remarked that delisting criteria numbers are the same as downlisting criteria, and that questioned whether population numbers for the downlisting criteria should be lower than for delisting. 150 animals is arbitrary.

The downlisting criteria are for 5 out of 7 years; the delisting criteria are for 10 out of 14 years. The team felt that maintaining population goals over a longer time period would ensure that recovery is not temporary. It would give us confidence that we could succeed with the environmental fluctuations that could influence the population over a longer time period. The 150 pronghorn number figure for Cabeza Prieta is the raw abundance target arrived at from the PVA.

7 Peer reviewer #2

Add contiguous: 1. At least three of the four current free-ranging populations are viable for at least five out of seven contiguous years

We did not expect the targets to be met in contiguous years; therefore we did not accept this change in the text. We may consider waiting for downlisting if the last year of the seven was one of the two years in which the population target was not

met. 8 Peer

reviewer #2 Does the long-term average growth rate need to be positive, or does the growth rate need to be positive in each of 5 years? It could be very hard to maintain a positive growth rate for five years especially if pronghorn are at the viable population size. In a generally stable population, the population growth rate is only positive half the time.

Text has been changed to "The Recovery Team defined a viable population of Sonoran pronghorn as one that has less than a 10% probability of extinction over 50 years and a growth rate that is stable or increasing."

9 Peer reviewer #5

Consider the MER in Mexico. (Método de evaluación del riesgo de extinción de las especies silvestres en México - Extinction Risk Evaluation Method)

USFWS must follow their own policy when considering downlisting or delisting; however, we added: When considering downlisting or delisting the Sonoran pronghorn, the FWS will collaborate with Mexican partners, including CONANP and CEDES, and consider the requirements and scoring in Mexico’s MER.

10 AGFD Commenter remarked that although the Recovery Team should continue to provide support for pronghorn recovery in Mexico, the recovery criteria should not be dependent on population status in Mexico where the U.S. has no authority to implement recovery actions. If the criteria outlined in the plan for the populations in Arizona are met, AGFD supports downlisting or delisting the subspecies.

Service policy mandates that we must address recovery of the listed entity, which includes pronghorn in Sonora. We could not biologically justify not including the populations in Mexico in the criteria.

11 AGFD Downlisting/Delisting Criteria 2 and 4 are not well defined nor are there references to other locations in the text where they are defined. It is essential that the criteria are specific and well defined so that there is no question when the criteria are met. Specifically Criteria 2 does not define contiguous. Would habitats connected by wildlife movement barrier crossing structures be considered contiguous?

From the justification: "Contiguous habitat contains no barriers to Sonoran pronghorn movement; and is accessible to and inhabitable by Sonoran pronghorn throughout." We added "within each unit" to the text to clarify contiguity means within each management unit, and not between management units. We added to the justification that the criteria is to retain 90% of the amount of habitat available in the baseline year of 2016.

12 AGFD Criteria 2 seems a bit unachievable and somewhat subjective (lack of definition) depending on whose call it is for retained and contiguous.

We can measure and track how much habitat and contiguity is lost by updating satellite imagery maps. We can produce maps similar to those currently shown in the Recovery Plan for the Quitovac pronghorn population. Recovery action 2.1.5 addresses the creation of this map, which is complete for most of Cabeza Prieta, but not for Kofa, Sauceda, or the Mexico CU.

13 AGFD Criteria 3: Using three out of four population units means that we have to rely on habitat efforts in Mexico to recover the

Service policy mandates that we must address recovery of the listed entity, which includes pronghorn in Sonora.

species. 14 AGFD Under Criteria 4, human disturbance and

alleviate are not defined. Examples were provided.

We added to the justification of criteria #4 to provide clarification.

15 NPS Criteria #5 says "Genetic diversity, as measured by heterozygosity and allelic richness for nuclear DNA markers, and (if relevant) number of unique mitochondrial DNA haplotypes, has been retained or increased from current levels. The minimum level of genetic diversity of all populations is within 10% of the most diverse population (currently, the Cabeza Prieta South Pen population)." This is not possible if one out of four populations is lost, as allowed under criterion 1. Maybe, make it three out of four, to be consistent.

Criteria #5 will be changed to "Genetic diversity, as measured by heterozygosity and allelic richness for nuclear DNA markers, and (if relevant) number of unique mitochondrial DNA haplotypes, has been retained or increased from current levels. The minimum level of genetic diversity of each population is within 10% of the most diverse population (currently, the Cabeza Prieta South Pen population)."

16 Peer reviewer #1

Page 80 (about PVA) "The Recovery Team evaluated model outputs for those models featuring a 15% drought frequency (one drought year out of every seven years)." Insert “severe.” Data show that most of the last 20 years have been drought, with severe drought years about every 7 years: 1995, 2002, 2009.

We made this change.

17 Peer reviewer #3

Commenter remarked that the recovery of Sonoran pronghorn should not be dependent on recovery of the species in Mexico.

Service policy mandates that we must address recovery of the listed entity, which includes pronghorn in Sonora. We could not biologically justify not including the populations in Mexico in the criteria.

18 Peer reviewer #3

The downlisting criteria stipulate that populations must both be secure (based on PVA analyses) and experiencing positive growth. If populations grow to K, growth would be expected to stop. Thus the population would be recovered but would not meet the positive growth requirement for delisting. In addition, if estimates of K are high (actual K is lower), it may be reached quite quickly, and the population/s will not be able to increase unless further habitat improvements take place or more habitat is made available.

Text has already been changed in response to similar comments to "The Recovery Team defined a viable population of Sonoran pronghorn as one that has less than a 10% probability of extinction over 50 years and a growth rate that is stable or increasing."

19 Peer reviewer #3

On page 79, the plan lists estimated carrying capacity. Are these estimates taking habitat modifications into account, or are they based on current conditions?

They take current management (water, supplemental feed, and captive breeding) into account.

20 Peer On page 80, it is stated that droughts occur Yes, that’s why we added a 50% buffer to account

reviewer #3 at least every 7 years, so a 15% drought frequency was used in PVA modeling. I take at least to mean that droughts occur that often, or more often, so the long-term average is likely to be higher than 15% of years. Given that we’re dealing with an endangered species, it seems that erring on the side of higher drought frequency (say 20%) is called for.

for the unknown effects of climate change. Drought has been occurring every 7 years in recent records as discussed in the plan; however, we expect they may become more frequent with climate change.

21 Peer reviewer #3

On page 81, and elsewhere refer to population augmentation to achieve target numbers. If habitat improvements are working, K should be going up, which would put existing populations further below K, which in turn should lead to higher population growth rates. If augmentation is necessary to achieve positive population growth, then habitat modifications are not working as planned. This needs to be specifically addressed and accounted for in the plan, and population responses (independent of augmentation) need to be the benchmark by which habitat modifications are judged.

We don’t think K is likely to rise much, or at all, with our actions. Sonoran pronghorn are not near K for most areas. Improvements are primarily protection and waters for some of the populations. Populations could not be increasing for other reasons, though, such as human disturbance. The captive breeding program is not intended to be a long-term part of the recovery process.

22 Peer reviewer #3

On page 82, there is a stated goal of preserving 90% of current habit. Given that the populations are in trouble with 100% of current habitat, allowing for a 10% reduction in habitat seems counterproductive. If this is acceptable because improvements in quality and connectivity will more than (substantially more than) increase habitat quality enough to compensate for the 10% loss, then this should be made clear, and benchmarks for confirming this should be put in place.

The population criteria and carrying capacity for the Pinacate population was based on amount of habitat that currently exists in the Pinacate Management Unit, so losing up to 10% of the habitat could reduce carrying capacity. However, implementation of actions such as developing pronghorn waters and removing fences could increase carrying capacity. Carrying capacities for other populations are well above the population criteria, so those populations may still be able to meet the targeted population criteria if some habitat is lost.

23 Peer reviewer #3

On page 83, it states that threats should be stabilized or reduced. Given the current state of desert pronghorn, stabilizing threats at current levels does not appear to be a reasonable goal. Given the low numbers of these animals, reduction of threats would appear to be the only action/s that could be reasonably justified.

Reducing all threats may not be feasible. Some threats are at an acceptable level so they only need to be stabilized.

F. Recovery Actions Commenter

Affiliation Comment FWS Response

1 BLM Regarding Action 2.5.1.1., the objective Changed language to "2.5.1. Limit livestock grazing

should be to reduce impacts to pronghorn habitat. Reducing livestock numbers is one of several management prescriptions that could be applied to achieve that objective.

where it impacts Sonoran pronghorn habitat" and "2.5.1.1: Reduce the amount of livestock grazing where it impacts Sonoran pronghorn habitat in the Mexico Conservation Unit, Cabeza Prieta Management Unit and the Arizona Reintroduction Management Unit." Reducing livestock numbers (Action 2.5.1) is stated as one recovery action. Action 2.5.2 Reduce the impacts of livestock grazing where it will continue, is also listed as a separate recovery action. Both of these recovery actions are intended to achieve Objective 2: Ensure that there is adequate quantity, quality, and connectivity of Sonoran pronghorn habitat to support populations.

2 BLM Recovery Action 2.5.2.4. assumes a need to reduce or remove livestock without evaluating whether current use levels are precluding the development of a vegetative community necessary for Sonoran pronghorn conservation.

We support this type of quantitative evaluation, if needed. Please note this recovery action also applies to Mexico (see 2.5.2.4.1), where BLM standards are not in place. In addition, the BLM monitoring protocol is not for the purposes of maintaining pronghorn habitat and thresholds may differ between what is required for sustainable livestock forage and what is required for Sonoran pronghorn. The action does not assume a need to reduce or remove livestock unless thresholds are exceeded. We have reworded the action to make that clear.

3 BLM Regarding Recovery Action 2.5.2.4, "Adequate forage and habitat for pronghorn" needs to be described quantitatively. Quantitative description of the habitat needs of the Sonoran pronghorn (plant community, species composition, abundance, structure and cover, within the ecological potential) are necessary for the BLM to review existing livestock grazing operations to determine the need for management changes, using existing management authorities. A quantitative Desired Plant Community (DPC) that is essential to support Sonoran pronghorn conservation and recovery is needed to effectively manage the habitat of this species and should be included in or the development of which, should be an objective within this Recovery Plan.

Adequate forage and habitat for pronghorn are described generally as key ecological attributes for the species. We agree they should be described more quantitatively for adaptive management of pronghorn habitat. A list of quantitative habitat indicators of Sonoran pronghorn habitat will be created as part of this recovery action (Please see the 2005 Wildlife Society Bulletin Special Section: Can the Sonoran pronghorn survive? for a quantitative description of SPH habitat).

4 BLM The recovery plan states (in action 2.5.3.1): "Feral (unmanaged wild) livestock damage Sonoran pronghorn habitat by spreading invasive plants, overgrazing forage, causing erosion, and compacting soil." Comment: These are things that potentially could

We added the word "can."

occur, unless documentation of cause and effect are documented within Sonoran pronghorn habitat.

5 BLM Provide literature for the statement, "Feral burros will deny access to ungulates at water sources and their urine and feces can rapidly degrade water sources, making them unsuitable for pronghorn."

These effects have been observed in Sonora, Mexico. We changed "will" to "can". These observations have been made by AGFD and Kofa NWR personnel as well. We added "(personal communication John Hervert, AGFD).

6 BLM Regarding action 2.5.8: Change text: Stipulations are usually site specific and result from site specific evaluation of effects. Most Resource Management Plans (RMPs) list the standard operating procedure of evaluation on a case-by-case basis to insure the decisions and mitigation is not arbitrary and capricious. Existing RMPs address fragmentation avoidance. Mitigation is allowable to the extent necessary to achieve resource objectives described in RMPs. Mining mitigation can be applied to the extent allowable and consistent with 43 CFR 3809.

We changed, as recommended, to: 2.5.8. Establish Best Management Practices (BMPs) for U.S. projects on BLM land, to minimize habitat loss and prevent habitat fragmentation. BLM will work with the Recovery Team to create recommendations for BMPs and potential mitigation for all actions that may impact Sonoran pronghorn and their habitat.

7 BLM Delete action 3.7., as this is covered by 3.4.and 2.5.8.

Deleted.

8 BLM Delete action 7.5 (rationale provided) Deleted. 9 BLM Remote sensing interpretations should be

validated with monitoring of vegetation to quantify species composition and production. Greenness is a qualitative indicator but does not allow for comparison between areas, seasons or years nor does it represent the condition of the vegetative community relative to potential.

We realize that we will need to quantify our monitoring indicators. We will work with AGFD to quantify greenness.

10 NPS Commenter noted that actions needed must include restoration in reducing human disturbances such that restoration will mitigate some of the habitat fragmentation and reintroduce favorable browse.

Restoration of Sonoran pronghorn habitat and reduction of human disturbance are included as recovery actions in the plan.

11 NPS Commenter recommended that estimated costs must factor in restoration of disturbed lands and reseeding and provided an estimate. A part of restoration will be continued cooperation with the USBP.

Recovery action 2.2.4.2. in the Implementation Schedule includes the cost of restoration ($1.75 million).

12 Peer Reviewer #4

Commenter stressed the importance of waiting for the results of genetic studies before making decisions on which subspecies is appropriate for reintroduction in Baja California; and provided detailed information on pronghorn subspecies and that Mexican law prohibits the introduction

We agree.

of subspecies into habitat of another subspecies.

13 NPS Organ Pipe will also monitor restored routes to ensure that vegetation has reestablished and the habitat is potentially suitable for pronghorn.

This will be very useful information and we look forward to reviewing/discussing results at future recovery team meetings.

14 NPS Regarding action 2.1.7, Organ Pipe has a number of weather stations and weather data is available for several decades. It is unlikely that Organ Pipe will need additional weather stations in this effort.

We noted Organ Pipe's weather stations and mention that other land management agencies already have stations, but there is a need to link and standardize information so it is more of a network.

15 Peer Reviewer #1

Regarding action 2.1.2, beware of the assumption that vegetation change is: 1) happening significantly at all, and; 2) results in significant decrease in pronghorn habitat quality. So far, the document lacks objective, data-supported documentation of vegetation change as a significant factor. There isn’t enough data presented to support making vegetation-management prescriptions.

We agree that there is a lack of data-supported documentation of vegetation change, which is why this action to record the amount and severity of change is needed. We are trying to determine how much seasonal and permanent vegetation changes may be affecting pronghorn before making vegetation management prescriptions as suggested.

16 Peer Reviewer #1

Regarding action 2.1.5.2, most of CPNWR also has been mapped (for vegetation).

We are aware that portions of CPNWR have been mapped and included this text in the action.

17 Peer Reviewer #1

Regarding action 2.1.7, it is worth noting that weather stations exist on BMGR-E, CPNWR, and ORPI.

We added this information.

18 Peer Reviewer #1

2.5.5 Didn’t the Team also develop a statement about CBP limiting use of low-level (e.g. <1000 ft) helicopter operation over important pronghorn areas, and at critical times?

This action has been included in 3.1.3 and has been incorporated in Biological Opinions.

19 RMO 2.8.5.1: Include ADWR for consultation/permitting.

Added: Coordination with other entities and acquisition of necessary permits may also be required.

20 RMO Combine 5.11 and 5.17 We combined them. 21 Peer

Reviewer #5 Add a recovery action under 1.1.3, Promote the Sonora State PACE. Such a program could facilitate actions between Arizona and Sonora.

We included this as action 6.3.

22 Peer Reviewer #5

Add a recovery action under 3.2, Consider closing some areas in Pinacate to recreational activities.

We added this as action 3.2.4.

23 Peer Reviewer #5

Add an action 6.1. regarding establishing an agreement between the US and Mexico to recovery pronghorn.

We revised action 6.2. and included your suggestion as 6.2.1.

24 Peer Reviewer #5

Add an action under objective 6 for Sonora state government to develop a PACE for the Pronghorn.

Added as action 6.3.

25 Peer Reviewer #5

Add an action under objective 6 to develop specific information (videos, pamphlets,

We added this to action 6.9.

posters) for those that live in the pronghorn areas and/or support the recovery plan.

26 Peer Reviewer #5

Add "training and participation" to the end of 6.11.

We added training to the action which is now 6.13.

27 WWP The FWS should be aware that a BLM allotment’s compliance with the Standards of Rangeland Health doesn’t necessarily equate to good habitat for pronghorn. For example, the BLM’s methodology for evaluating forage production on the Bishop allotment uses non-traditional monitoring methods, including intentionally placing monitoring plots in areas with the most vegetation. Previous Rangeland Health Assessments entailed sampling in just a handful of key areas for allotments containing tens of thousands of acres. Moreover, none of BLM’s standard monitoring methods evaluate the impact of livestock grazing on ephemeral production and rarely does the agency sample for utilization. Thus, at the critical times of livestock-pronghorn competition, there will be no data collected to see how much of the desert’s productivity is being effectively donated to private business

See action 2.5.2.4 (now 2.5.2.4.) Establish utilization monitoring protocol, including utilization thresholds for reducing or removing livestock, as needed to maintain adequate forage and habitat for pronghorn. This action was developed because of the potential differences between good habitat for pronghorn and BLM Standards of Rangeland Health. See our response to comment RA-2, and see action 5.9.

28 Peer Reviewer #3

Water and habitat quality figure prominently in this plan, as does predation. It may be advisable to examine which types of environments lead to the highest predation rates. Effective antelope predators are most likely ambush hunters that need fairly heavy cover to be effective. The recovery team could capitalize on this by paving the way for reintroduced or augmented populations with extensive habitat modification well before reintroduction or augmentation. These habitat modifications could lead to reduced predator effectiveness and numbers, making the environment safer for naïve antelope. I would suggest one or two years of intensive habitat modification work (to give predator populations time to respond), before reintroduction or augmentation.

However, thermal cover is also important, so we need to have a mix of habitat structure. Predation was a more critical issue when there were only 40-50 pronghorn in the wild, but is less of a threat now. Although we mention it in the recovery plan, it is not a key threat. We do have actions in the plan to investigate the relationship between cover and predation, especially in areas burned by military activities.

29 Peer Reviewer #3

Livestock and disease are discussed separately and should be integrated. Vaccination programs will only be needed if antelope are in contact with carriers (primarily livestock). Separating antelope from livestock should be viewed as an

Actions in the plan to limit livestock should address disease transmission.

integrated habitat improvement and disease reduction program, so complete separation will be necessary.

30 Peer Reviewer #3

It may be worthwhile to consider the artificial creation of migration routes before reintroductions take place. Specifically, establish crossing structures over canals and over or under roads. This way, naïve antelope immediately find places that facilitate movement rather than explore dangerous options.

This is a great point, but the reintroductions are ongoing, and overcrossings are unlikely to be installed prior to reintroductions.

31 Peer Reviewer #3

In several places the plan refers to working with private companies to minimize habitat degradation and restore degraded habitat. In Mexico, the Fresnillo Mining Company is planning a $2 billion expansion of operations and it is unlikely that mitigation efforts will offset the negative impacts to habitat quality, resulting in a net loss of antelope habitat. Given that the U.S. has minimal pull with such companies, this would support the idea of establishing recovery targets independent of Mexican antelope population status.

Service policy mandates that we must address recovery of the listed entity, which includes pronghorn in Sonora. We could not biologically justify not including the populations in Mexico in the criteria.

32 Peer Reviewer #3

Given the threat of disease, combined with habitat degradation, the removal of livestock from antelope habitat should be a goal regardless of whether drought or fire are affecting habitat (2.5.2.3.).

Given that removal of all cattle from Sonoran pronghorn habitat is likely to be unachievable, we have instead put in recovery actions 1.1.2.1. and 1.1.2.2, which are to vaccinate Sonoran pronghorn.

33 Peer Reviewer #3

Supplemental feeding (2.7.2.2) is likely to confound efforts to evaluate habitat improvements. Habitat improvements should be the vehicle used to increase forage quality and quantity. Supplemental feeding is likely to prop populations well above current environmental carrying capacity and may contribute to habitat degradation during times when supplemental feed is not available. I would suggest letting habitat quality drive population growth rather than artificially driving growth with supplemental feed. This way, antelope populations will be in sync with environmental carrying capacity and less likely to themselves degrade habitat.

Populations are not near K, so habitat degradation is not likely to occur when supplemental feed is not available. Also, the supplemental feeding program is a seasonally and geographically focused, small scale program.

34 Peer Reviewer #3

Regarding water, it seems that the FWS and other agencies managing antelope need to become water shareholders with guaranteed allotments just like agriculture and municipal users. To this end, is dedicated

We don’t have access to canals, pronghorn waters use collected rainwater.

water impoundment and options? This would allow for evening out the water supply, or mimicking natural water cycles that have been altered to human use (competition) or climate change. In addition, owing water and storing may allow for buffering the near-term effects of climate change. Beyond this, long-term habitat recovery is likely to require a fair amount of water – recovered habitats won’t stay that way in the face more and deeper droughts. Dedicated water will help ensure that habitat recovery lasts.

G. Research Commenter

Affiliation Comment FWS Response

1 BLM Determine quantitative habitat needs; plant species composition, abundance, structure and cover within the ecological potential. A quantitative Desired Plant Community description would facilitate evaluation of habitat quality and review of project impacts.

Please see the 2005 (Volume 22, Number 1) Wildlife Society Bulletin Special Section: Can the Sonoran pronghorn survive?

H. Implementation Schedule Commenter

Affiliation Comment FWS Response

1 NPS Organ Pipe will also: Monitor restored roads on CPNWR, BLM-Ajo block, and Organ Pipe to ensure that vegetation has reestablished and the habitat is potentially suitable for pronghorn. Figures to calculate costs were provided.

We added this information to the Implementation Schedule.

2 RMO Cost estimates need better explanation or need to be recomputed. An example was provided.

Cost estimates were rounded from the original workbook and may not add up due to rounding differences.

3 WWP Commenter urged FWS to insist BLM to fully analyze and select the “No Grazing Alternative” under NEPA when evaluating grazing permits in pronghorn range to benefit pronghorn and desert tortoise. Commenter remarked that FWS should examine habitat characterizations conducted by BLM. Commented noted that the BLM

We appreciate this information; however, project-level recommendations are specific to the action involved, and are too specific to be covered in a recovery plan. However, working with the agencies to implement recommendations falls under recovery actions 2.5.1 (especially 2.5.1.1.1. Coordinate with appropriate agencies to examine the need to reduce livestock numbers); and 2.5.2. We will meet with

uses automatic renewals to extend the permits for another decade and there is no regulatory pressure to complete Land Health Evaluations outside of the permit renewal process.

the BLM to discuss their grazing program as it relates to pronghorn recovery.

4 WWP Note that the total active authorization for these allotments is 24,557 AUM, which is at least the equivalent of 19,645,600 lbs of forage each year. The FWS should determine how many native pronghorn could survive on the equivalent amount of vegetation in Area A, and note that this number does not include the ephemeral authorizations on any of the allotments.

The amount of forage does not seem to be a limiting factor for pronghorn in years with sufficient rainfall. There are not that many places where Sonoran pronghorn and cattle occur together in the U.S. Yoakum (2004) cites wide variation in estimates of AUMs required by pronghorn in different areas and vegetation types. No calculations have been made for the Sonoran desert, and at this time it is impossible to calculate how many Sonoran pronghorn could survive on this amount of forage.

I. Appendices Commenter

Affiliation Comment FWS Response

1 RMO Page 218, PVA table: Consider adding the Sauceda and potentially the California population Sub-Units to this list.

We cannot add them yet, because the PVA requires population data, and there is no pronghorn population data for these areas.