To: USFWS Re: CoP15 FWS-R9-IA-2009-N0103; 96300-1671-0000 FY09 R4 

Thank you for considering measures to help protect the tiger and other exotic cats.  I am writing specifically about tigers and bobcats, but the perils they face include all species of exotic cats.  In the case of the tiger, there are U.S. facilities that openly market lion meat in restaurants such as Spotos in Dunedin, FL, Czimer's in Chicago, IL and on the Internet at 1/800-Steaks.com.  No one can discern between lion meat (legal) and tiger meat (illegal)

Tigers:  There are less than 3,500 tigers left in the wild and we are losing one tiger per day to poaching.  The demand for tiger parts has continued to rise as developing nations have become more affluent.  China is the largest consumer of illegal tiger parts with the U.S. running a close second.  The private possession of live tigers in China and the U.S. have provided a legal cover for an illegal trade.  Until such practices are banned there will be no way to effectively protect the tiger in the wild.  Demand for tiger parts will always place a higher value on authentic, wild caught tigers.  Killing a tiger in the wild is much cheaper than raising a tiger to a size necessary to fill demand when it costs $7,500 a year to feed and care for a captive tiger who will not reach full size for 4-5 years. 

These must be done to save the tiger: 

1.  Ban the private possession of tigers.

2.  Repeal the exemption for "generic" tigers from the Captive Bred Wildlife permit requirement and require that all tigers be registered in a publicly accessible database, accounted for during their life and upon death, microchipped, and kept from breeding outside of AZA sanctioned Species Survival Plans.

3.   Demand that all who parties who possess more than 8 tigers at any one facility provide a written plan for how they will immediately stop breeding and begin scaling back on their numbers of tigers held by placing them in legitimate sanctuaries that are open to public scrutiny.

Keeping tigers captive is clearly a violation of the intent of the Endangered Species Act.  Being bred into a life of confinement and deprivation as part of a collection, whether that collection be publicly or privately owned, violates the definition of “take” provided in the ESA on several levels.  

First of all, the definition clearly says endangered species and those similar enough in appearance to “substantially facilitate the enforcement” (ie: tiger bones vs. lion bones) may not be collected.  That statement alone would prohibit all captive collections of endangered species, such as tigers, leopards, jaguars, cheetahs and most other exotic cats.   

Harming, harassing and killing are also prohibited by law.  When cubs are ripped from their mothers to be used as photo props, that is a violation.  When adults are killed to make room for new babies for display, that too is a clear violation.  When big cats are hoarded into tiny, filthy cages and given only putrid food, inadequate amounts of food and algae covered water to drink that too is a violation of the Endangered Species Act. 

Even at the height of prosperity in this country there was never enough funding to properly regulate the trade in exotic cats.  In this economic downturn there will be even less oversight of an industry that should not exist.  Captivity by its very nature is inherently cruel to wild animals who were designed to roam over many miles.  There are only a handful of offenders who breed exotic cats for their own profit and pleasure.  More than 75% of the public polled said they would support bans on ALL exotic animals in private possession.  Of the estimated 5,000+ tigers in the U.S. only 256 are in the AZA sanctioned Tiger Species Survival Plan.  The rest should be sterilized and phased out over time as they die of old age. 

Bobcats:  Due to the Russian demand for bobcat fur, their pelts now draw some of the highest prices among trapped furs, commanding as much as $550 for a single hide. As the price has gone up, the number of bobcat skins exported by the U.S. has nearly tripled in five years, to 49,700 in 2006.  Some trappers are capturing bobcats in states with quotas and bringing them to Wyoming, which has no limits, said Scott Adell, a Wyoming Game and Fish Department investigator.  No one really knows how many bobcats live within their state boundaries and scientists have found that births are dropping rather dramatically.  As a rehabber we are seeing case after case of bobcats who are suffering from the effects of a poisoned environment, such as mercury in their food sources.  Bobcats live in areas where the endangered Canada Lynx is struggling against extinction and the same traps that are set for bobcats injure and kill their endangered cousins.  For these reasons as well as moral ones the bobcat should not be removed from Appendix II protection. 

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