Dr. Charles W. Dane, Chief
Office of Scientific Authority
Mail Stop: Room 725
Arlington Square
Washington, D.C. 20240

Dear Dr. Dane:

The American Society of Mammalogists is a professional scientific society that consists of nearly 4000 members from over 60 countries. One of the Societyıs principal interests is the conservation of rare or threatened mammal species. Accordingly, The American Society of Mammalogists would like to comment on the petition to downlist the cheetah from endangered to threatened in the Republic of Namibia.
Although we recognize the potential value of providing landowners in Namibia with an economic incentive to conserve cheetahs residing on private lands, we have several concerns regarding the Fish and Wildlife Service proposal to reclassify the cheetah in Namibia.
First, information regarding the current population size of cheetahs in Namibia is uncertain, and the basis for the often cited estimate of 2000-3000 cheetahs is unclear. As most cheetahs in Namibia exist on private farmland and an estimated 500 cheetahs are killed on farms annually (Marker-Kraus et al. 1996. Cheetah Survival on Namibian Farmlands. Cheetah Conservation Fund, Windhoek, Namibia), the size of the population at this time is uncertain. Data on cheetah numbers, distribution, and current harvest (both legal and illegal) are necessary to set biologically meaningful hunting quotas. Furthermore, data on sex and age ratios are lacking, and such information is critical to predict population responses to changes in harvest levels.
Second, the effects of limited hunting quotas established by CITES in 1992 must be reviewed. An argument in favour of downlisting the cheetah is that importation of trophies into the United States would be permitted, thereby providing an economic incentive for landowners to conserve cheetahs. We believe the following questions must be answered before downlisting is approved: Over the last four years, has there been a documented improvement of the status of this species in Namibia? Have the numbers of cheetahs killed on farms declined? Have attitudes towards cheetahs on private lands changed? What have been the economic impacts of limited trade? This information is critical for an evaluation of the effects of current quotas before expansion of trade is warranted.
Because of these uncertainties, the American Society of Mammalogists does not support the petition to downlist the cheetah in Namibia from endangered to threatened. We appreciate your consideration of our position of this matter, and we request that this letter become part of the Federal Register. Thank you for allowing us to comment on this proposal.

Sincerely,

Alicia V. Linzey, Ph.D.
President

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