D.2 Comment: One reviewer commented that designation and mapping of critical habitat would
also delineate areas for priority conservation actions, including the habitat restoration that the
recovery plan states is critical.

D.2 Response: Critical habitat designation is not required to map areas for priority conservation
actions. The USFWS and independent researchers have already identi?ed areas for priority
conservation actions to bene?t ocelot and have mapped closed canopy cover in south Texas
which are areas that could be suitable habitat.

E. Translocation

E.1 Comment: Several commenters expressed desire that any translocation must not endanger
the source population and must preserve the ocelot?s full ESA protections.

E.1 Response: The Recovery Team considered the impacts of translocation on the source
population. This evaluation was presented in the PVA. The 2009 plan for the translocation of
ocelots in Texas and Tamaulipas states that actions must ?ensure no adverse impacts to source
populations in Mexico result from translocation? (Translocation Working Group 2009). It was
not stated in the draft ocelot recovery plan, and an action item has been added to address this
important need: 3.1.3. Monitor effects of translocation from the source population(s). Part of this
evaluation is to estimate the distribution and population size in Tamaulipas prior to translocation,
and monitor population demographics in Mexico after translocation. Ocelots translocated from
the wild into current populations would retain their endangered status.

E.2 Comment: There should be more emphasis on translocation versus natural dispersal given
fragmentation caused by the border infrastructure and expanding human population.

E.2 Response: The USFWS believes that natural dispersal of ocelots between the U.S. and
Mexico is a better alternative to arti?cial translocation, but recognizes the immense challenges
on the landscape and therefore has provided a suite of alternatives to provide an opportunity for
recovery of the ocelot that might entail the use of translocations.

E.3 Comment: Reintroduced populations separate from wild populations in the U.S. would be
essential to the survival of this species in the wild and therefore must not be designated as ?non-
essential? under ESA section 10j. Similarly, the reviewer stated that ?individuals or populations
that augment or are not physically separate from wild individuals or populations must retain their
endangered status.?

E.3 Response: The 1982 amendments to the Act included the addition of section 100), which
allows for the designation of reintroduced populations of listed species as experimental
populations. Under section 100) of the Act and our regulations at 50 CFR 17.81, the USFWS
may designate an experimental population as a population of endangered or threatened species
that has been or will be released into suitable natural habitat outside the species? current natural
range. With the experimental population designation, the relevant population is treated as
threatened for purposes of section 9 of the Act, regardless of the species? designation elsewhere

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in its range. At this time, the USFWS does not anticipate designation of an experimental
population of ocelots.

E.4 Comment: Are you trying to assist ocelot recovery range-wide by managing the US.
population or trying to recover a speci?c subspecies? Later in the plan, you do reference
translocations. How would using a different subspecies be perceived?

E.4 Response: Because the ocelot is listed throughout its range, the USFWS is working toward
recovery of the entire listed entity. However, because we have little ability to manage species
conservation outside US. borders, the USFWS is working with partners to maintain a level of
genetic diversity in the species by protecting and maintaining ocelot populations at healthy levels
while recovering those populations that are most at risk, namely those of the sonoriensis and
albescens subspecies. At this time, the USFWS does not anticipate translocations across
subspecies, but we recognize that if conditions worsen, this may become a potential
consideration in the future. Translocations across subspecies would have to be carefully
evaluated.

F. Border Infrastructure

F.1 Comment: The recovery plan should explicitly call for modifying or removing the border
wall and other border infrastructure in places necessary to establish connectivity between ocelots
in the US. and in Mexico. The agency must specify realistic mechanisms that can more directly
address the profound and vast scale of threats to ocelot recovery presented by border security
activities, including how the agency plans to manage border habitat, access roads, arti?cial night
lighting, and other security activities.

F.1 Response: Urbanization and wildlife-limiting infrastructure in the border region of Arizona
and Texas are concerns, and the USFWS routinely makes recommendations to avoid and
minimize any impacts to this area that would impact habitat from direct loss or reduced
connectivity. Modi?cation or removal of existing border infrastructure would create greater
connectivity for endangered cats and other wildlife between Mexico and the US. However, the
Secure Fence Act of 2006 limits the ability to affect border infrastructure. The
Department of Homeland Security has worked with the Department of the Interior to provide
funding to mitigate for habitat loss of the ocelot in Texas. The US. Border Patrol has
implemented an environmental stewardship training developed by the USFWS and has
established Public Lands Liaison Agents to assist with environmental concerns on public lands.
Furthermore, the USFWS continues to work with CBP to modify and update best management
practices and procedures as needed.

F.2 Comment: The USFWS must put more emphasis on meaningfully addressing the signi?cant
threats to ocelot habitat and cross-border connectivity presented by border security activities.
The lack of baseline data that informs pre- and post-border wall construction effects from which
to compare and monitor environmental impacts is a signi?cant obstacle to the preservation of
unique habitats and species. Of special concern is the monitoring of federally protected areas,
threatened and endangered species, and cross-border watersheds.

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F.2 Response: As mentioned in Response F.l above, the USFWS is aware of the negative
effects on endangered species' survival and recovery due to urbanization and wildlife-limiting
infrastructure in the border regions of Arizona and Texas. It is the USFWS's practice to
consistently recommend avoidance and minimization measures that favor endangered species
survival and recovery when providing input on activities in these areas. However, the speed at
which the border infrastructure was planned and built made it impossible to provide pre-
construction data to assess the effects of the project. In Texas, the border infrastructure is
undoubtedly a signi?cant impediment to the long-term recovery of the ocelot. It fragments at-
risk ocelot populations in Texas from populations in Tamaulipas, Mexico. The plan now
includes an action (2.2.3) to recommend alternative methods for maintaining national security at
the border, other than structures that limit wildlife connectivity.

F.3 Comment: The USFWS must further research the ef?cacy of ?cat doors? for ocelots to
determine whether this type of recovery action is even feasible, much less needed or preferred.

F.3 Response: At the request of CBP, the USFWS provided locations for the proposed wildlife
openings in the infrastructure. However, fewer wildlife openings were installed than the
USFWS recommended and they were not located according to wildlife needs. An uncon?rmed
observation of a bobcat using a wildlife opening was reported in south Texas, but no photograph
has been provided. Even if used by other species, we agree with the reviewer that the ef?cacy of
the openings for use by ocelots should be investigated. Existing wildlife openings have not been
maintained and have ?lled in with silt, such that their utility for wildlife is limited.

F.4 Comment: There are no major habitat threats at present and the biggest limitation on the
animal's distribution are highways and industrial developments including the planned completion
of a border fence that will restrict any further northward movement of ocelots into Arizona. Are
there pipes that would allow ocelots but not people to pass under the border fence?

F.4 Response: Major threats in the US. to ocelot recovery are mortalities from vehicle strikes,
development, habitat loss and fragmentation. We agree that existing and planned border
infrastructure would remove habitat, limit habitat use, and limit dispersal and regular movements
of ocelots along the U.S.-Mexico border. It is unlikely that an opening in a barrier intended to
curtail illegal immigration could be designed that would allow for the free movement of ocelots
and still meet its intended purpose. In Arizona, some segments of the infrastructure are intended
to prevent passage of vehicles and are quite permeable by wildlife. Ocelots could potentially
pass through these areas of permeable infrastructure if lighting and the traf?c from vehicles used
by the US. Border Patrol were limited.

F.5 Comment: There was no explicit analysis of the location of the fence relative to likely areas
of connectivity or any descriptions of whether the fence has or could be modi?ed to allow
ocelots to pass. Are there existing openings that are of a size that would permit passage by an
ocelot? Has this been tested? Is the fence continuous in the regions where connectivity is most
crucial?

F.5 Response: The reviewer is correct that there was a paucity of information in the draft plan
regarding the infrastructure. More information is included in the ?nal plan, given that the

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USFWS now knows the extent and design of the current infrastructure. According to the Secure
Fence Act, additional infrastructure may be built and it is not necessary those plans follow
standard ESA consultation regulations, and the location and design of these structures could be
more detrimental to the long-term recovery and conservation of ocelots.

There are nearly 100 cut-out openings, approximately 21 cm wide by 29 cm tall, in the steel
bollard fence design in the 115 km of fence in the Lower Rio Grande Valley of Texas. The
distance between openings varies greatly and the openings were not installed according to the
recommendations of the USFWS. The openings have not been tested for any wildlife use to the
best of our knowledge. Many segments of the fence still have opening for vehicular traf?c,
although there are plans to install large metal gates in those locations. The USFWS has data of
bobcats using these large openings quite extensively.

F.6 Comment: Is there nothing that can be added, in terms of recommendations that can be
made now, that will help mitigate the effects of the border fence?

F.6 Response: The recommendations that have been included in the plan include: 1) limit the
footprint of any infrastructure that is deemed necessary to maintain homeland security, 2) limit
increased human and vehicular disturbance in key areas, as identi?ed by the USFWS, due to
increased patrols, 3) seek alternative measures (that can curtail illegal immigration) to physical
infrastructure which limits wildlife connectivity ?smart? infrastructure and airplane
drones).

F.7 Comment: We believe the USFWS should discuss the concrete actions it will take to ensure
that US. (and northern Mexico) ocelot population recovery will occur despite the likely enduring
barriers to natural movement and increasing levels of disturbance along most of the border. For
example, Congress has appropriated $50 million speci?cally for endangered species mitigation
activities related to the construction and maintenance of border barriers and associated
infrastructure, and another $40 million for environmental compliance, monitoring and mitigation
projects. The draft plan should describe the numerous projects the USFWS has implemented or
will likely implement using this funding.

F.7 Response: In south Texas, the USFWS has stated that all mitigation funds will be used to
acquire lands that will make the mission of the Refuges in the area achievable again. In relation
to the ocelot, this means acquiring lands that will provide habitat connections between ocelot
populations. The USFWS will continue to maintain a land acquisition and land-partnerships
program easements and agreements) focusing on protecting the riparian corridor along the
Rio Grande for literally hundreds of species of trust resources, but projects such as the Border
Infrastructure have limited the utility of habitats adjacent to the Rio Grande for land-based
migrations and connectivity for wildlife populations.

In Arizona, the USFWS applied ?mds towards research and monitoring for ocelots and jaguars,

as well as building teams of citizen scientists to assist in monitoring for jaguar and ocelots, and
developing programs to reach the public about the conservation of these rare native felines.

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F.8 Comment: We support Recovery Action 2.2 to identify potential ocelot border crossing of
high priority, but we urge the USFWS to be far more speci?c about how it will seek to manage
habitat, roads, and arti?cial night lighting, all of which could prevent or discourage successful
population interchange in these areas.

F.8 Response: The USFWS encourages all federal agencies to follow environmental regulations
including following the NEPA process and the consultation process under section 7 of the BSA
for federal actions. Best management practices and standard operating procedures have been
developed and implemented to some degree by CBP and the USFWS will continue to work with
CBP to modify and update best management practices and procedures. The USFWS will
continue to work through the appropriate channels, such as at the Borderland Management Task
Force Meetings, to address speci?c issues.

F.9 Comment: We also urge the USFWS to provide maps or otherwise offer precise
information about lands the Recovery Team believes are crucial to maintain and enhance.

.9 Response: Many actions in the plan are aimed at identifying and prioritizing lands for
conservation. In particular, recovery actions 1.1.6, 1.1.7 and 1.1.11 address these concerns.
Identifying and prioritizing those lands most critical to target for conservation of the ocelot is an
ongoing process, as changes in land use outside ocelot habitat can affect ocelot movements. The
identi?cation of linkages will be a critical component of a comprehensive habitat conservation
model. Priority should be given to areas with minimal need for habitat restoration and a
maximum potential for long-term protection as well as proximity to existing ocelot populations.

.10 Comment: Actions on behalf of the ocelot will need to consider the cumulative impacts of
fencing, lighting, highway traf?c, and habitat avoidance due to human activities. The plan
includes the measure that it will partner with Homeland Security and Border Patrol on these
border issues 4.1.7 on p. 42), but FWS needs to go further. The agency (and the Ocelot
Recovery Plan) must be clear on how and what measures must be taken to protect the ocelot
from this threat suf?cient to recover it.

F.10 Response: The plan offers a suite of recovery actions that range from relying upon natural
dispersal around barriers and across the U.S.-Mexico border to arti?cial movements 
translocation) to protect the ocelot from the threat of increased patrolling by Border Patrol and
increased development of infrastructure in the area. In particular, Recovery Actions 2.2.1, 2.2.2,
2.2.3, and 2.2.4 are speci?c measures to avoid, reduce, and minimize impacts on ocelot habitat
and behavior from U.S.-Mexican border infrastructure, maintenance, and development. These
actions have been modi?ed and expanded from the draft plan to better address this ongoing
threat. In addition, the USFWS continues to use the appropriate regulatory mechanisms for
avoidance and minimization of these threats from human border activity as an ongoing strategy,
while working with DHS and CBP to conserve wildlife.

F.11 Comment: The presentation of border issues under threats is incomplete and unbalanced.
We are aware of no studies which document that any of the border infrastructure or operational
activities have impacted survival and/or recovery of ocelot. For example, while CBP border
control activities, including fence construction, have been cited as precluding movement of

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ocelots between US. and Mexico, based on DNA and other evidence as presented in the draft
plan, several authors have concluded that movement of ocelots between the two countries has
been reduced to insigni?cant levels for a number of years. Further, even if there were movement
of ocelots between the two countries, there is no evidence that the pedestrian fence is
impermeable to ocelot. There is photographic evidence that adult bobcats, which are
substantially larger than ocelots, are able to ?t between the bollards of the pedestrian fence.

F.11 Response: There are studies that document how border infrastructure or operational
activities could have an impact on survival and recovery of ocelots. In 2004, Grigione and
Mrykalo published a scienti?c peer-reviewed article indicating that activity patterns for ocelots
and their prey would be altered under arti?cial night lighting conditions, that evening activity
levels would either be reduced or redirected towards areas with dense vegetation away from
well-lit areas, and that ocelot foraging success would likely be altered in those disturbed areas.
The data recently collected by the USFWS (ca. 2006-2015) regarding the strong negative effect
of concrete traf?c barriers on ocelot dispersal and survivorship when ocelots attempt to cross
roads, clearly demonstrates that barriers can be a serious impediment; therefore reduction of
barriers, and minimization of impermeable designs should have been a more negotiation
process between agencies. 


Conservation genetics indicates that at least one genetic exchange per generation will maintain
genetic diversity within a population. Any additional barrier that reduces the probability of
genetic exchange is detrimental to recovery. With so few ocelots in the US. and the greater
genetic diversity of the Tamaulipas population, the movement of any ocelots across the border is
signi?cant to the conservation of the species along the border.

Although it might be physically possible for an ocelot to move through wildlife openings
installed by CBP, the USFWS knows of no evidence that openings in the border infrastructure
make it permeable to ocelots. The USFWS has not been presented with any photographic
evidence that bobcats have moved through any wildlife openings in the border infrastructure.
Sections of the infrastructure associated with concrete walls, such as the 12-16 foot high walls in
Hidalgo County, Texas, do not have wildlife openings and are not permeable to ocelots or any
other terrestrial wildlife.

F.12 Comment: Changes are needed to the entire passage on ocelots and border crossings as it
was based on speculation as to where and how often ocelots cross the Arizona-Sonora border in
either direction. It was very weak on linking actual border obstacles to likely or even suspected
suitable ocelot habitat. Much of the obstructed border seems very unlikely to have any value in
terms of ocelot movement.

F.12 Response: We agree that little is known about the characteristics of ocelots moving across
the Arizona-Sonora border, but additional information about known movements and border
infrastructure has been incorporated into this ?nal plan. The wildlife-impermeable border
infrastructure in Arizona is located within or immediately adjacent to border cities in the US.
The vast majority of the fencing in Arizona is permeable to smaller wildlife such as medium-
sized carnivores and smaller.

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F.13 Comments: Recovery actions will likely have adverse impacts on the CBP mission and
will require further evaluation prior to inclusion in the plan.

.13 Response: The USFWS does not determine whether recovery actions should be included
due to impacts on mission or the mission of any other agency. Instead, recovery actions
are developed in accordance with what is needed to achieve recovery of the species. It is
unlikely that the issuance of a plan will have any effect on mission until the recovery
actions outlined are implemented. CBP will be able to work with the USFWS to ensure that both
agencies? needs are met. CBP should relay any specific issues and concerns about actions
implemented by the USFWS through the appropriate channels, such as through the Borderland
Management Task Force Meetings.

F.14 Comment: Recovery actions likely to directly impact the CBP mission to secure US.
borders need further evaluation prior to their inclusion in the plan. There are two recovery
actions contained in the draft plan with potential to directly or indirectly impact the CBP border
security mission and operations. These actions should be removed from this plan until their
impacts on the CBP mission have been fully addressed. In particular, the reviewer suggested
removal of the following recovery action: Maintain and enhance habitats or similar
vegetative structure near the border.

.14 Response: and structurally similar habitats along border riparian zones are
especially important to encourage river crossings by ocelots and other wildlife and also to
provide cover for movement to and from water sources for drinking. Human-caused fires can
reduce the density of cover and encourage establishment of invasive grasses which
are even more ?re-prone. However, dense or structurally similar habitat may be a
deterrent to illegal border crossings by humans due to the immense effort required for humans to
traverse it, potentially making its maintenance or restoration attractive and bene?cial to
enforcement authorities. Communication and relationship development with enforcement
authorities, as described in Recovery Actions 2.1.4.1, 2.2.2, 2.2.3, 2.2.4 and 2.3 are critical to
making progress in this area.

F.15 Comment: Apprehension of individuals entering these dense and similar
habitat types increases risk to CBP agents. CBP will work with USFWS to determine if suitable
areas can be identi?ed for maintenance or restoration of ocelot habitat that would not inhibit the
border protection mission, but CBP cannot accept this as a general action under the plan.

F.15 Response: The USFWS will collaborate with CBP and other federal agencies to ?nd ways
to recover the ocelot. The USFWS will also continue to share resources such as intelligence
gathered during the maintenance of wildlife game cameras that document illegal activities,
reporting illegal activities witnessed by USFWS personnel, and continued collaboration between
the USFWS dispatch of?ce and the CBP dispatch call centers in the Rio Grande Valley Sector.
The USFWS will continue to meet and discuss issues at the Borderlands Management Task
Force Meetings or similar groups to work toward a mutually bene?cial resolution.

Native is exceedingly rare in the LRGV. Where it is found, it provides a very dense
layer of thorny brush even at the height of 1-2 feet above the ground. Dense brushlands of this

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type are the restoration goal of the USFWS for a multitude of species, as this was one of the
many native growth forms in the area and this is the growth form that is most suitable for the
ocelot. The growth form that is referred to as being used by undocumented immigrants are most
likely that has been disturbed by humans through burning brush areas, creating roads
and trails, grazing of livestock, farming, developing lands, draining nearby wetlands, and other
forms of disturbance. These are areas that should be restored to the densest brush type possible,
Where appropriate. The USFWS would suggest that dense woodlands, as formerly existed in
many areas, if restored and maintained, would provide an opportunity to funnel undocumented
immigrants into more open areas where they could more easily be detained.

F.16 Comment: The draft plan does not acknowledge that the expanding population, poverty,
and high unemployment in the Rio Grande Valley area might be partially due to illegal
immigration in the area and that an increase in border security which controls illegal immigration
is likely to have an indirect bene?cial effect on ocelot habitat.

.16 Response: Border security infrastructure has led directly to increased roads, additional
habitat loss, increased habitat fragmentation, and increased light and noise pollution in ocelot
habitat. These impacts clearly have a negative impact on ocelot habitat. The role of illegal
immigration as a cause of the development of that infrastructure and the effect of the segments of
border infrastructure on limiting the sociological drivers responsible for illegal immigration is
well beyond the scope of this plan. Instead, the USFWS has focused on collaborating with other
federal agencies, such as CBP, to minimize and mitigate impacts caused by the actions of those
federal agencies.

G. Arizona-Sonora Management Unit

Comment: The Arizona-Sonora ocelot subspecies (L. p. sonoriensis) has no known
reproducing individuals in the United States.

G.1 Response: Although we do not currently have information that there is an extant, self-
sustaining ocelot population in Arizona, ocelots in Sonora near the international border are
capable of dispersing into suitable habitat in Arizona, and with appropriate habitat protection and
restoration, it may be possible to maintain a self-sustaining population of ocelots in Arizona.

G.2 Comment: Establishment of Recovery Goals for the Arizona-Sonoran Recovery Unit
(ASMU) is unwarranted. A more thorough analysis of the historic and current records of ocelots
in Arizona needs to be conducted: if there ever was a breeding population in the ASMU, what is
the suitable habitat and the current extent of that suitable habitat in the ASMU, and what
information is available or needed to determine acceptable downlisting criteria for ocelot as part
of the We recommend that the analysis needs to take into account the time it takes to
propose and make ?nal a reclassi?cation ruling.

G.2 Response: The USFWS agrees that a more thorough evaluation needs to determine if there
is an extant breeding population of ocelots in Arizona. Recent data suggest that ocelots found
near the Arizona-Sonora border are capable of moving between the two states and data provided
from researchers in Sonora demonstrates that there is a viable breeding population in the state of

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