Endangered and Threatened Wildlife and Plants; 12-Month Finding on a Petition and Proposed Rule To Remove the Morelet's Crocodile From the Federal List of Endangered and Threatened Wildlife

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DEPARTMENT OF THE INTERIOR Fish and Wildlife Service 50 CFR Part 17 [Docket No. FWS-R9-ES-2010-0030; 92210-1113-0000-C6] RIN 1018-AV22 Endangered and Threatened Wildlife and Plants; 12-Month Finding on a Petition and Proposed Rule To Remove the Morelet's Crocodile From the Federal List of Endangered and Threatened Wildlife AGENCY:

Fish and Wildlife Service, Interior.

ACTION:

Proposed rule.

SUMMARY:

Under the authority of the Endangered Species Act of 1973, as amended (Act), we, the U.S. Fish and Wildlife Service (Service), announce a 12-month finding on a petition and a proposed rule to remove the Morelet's crocodile ( Crocodylus moreletii ) throughout its range from the Federal List of Endangered and Threatened Wildlife due to recovery. This action is based on a thorough review of the best available scientific and commercial data, including new information that became available after we received the petition, which indicates that the species' status had improved to the point that the Morelet's crocodile is not likely to become threatened within the foreseeable future throughout all or a significant portion of its range. If this proposed rule is finalized, the Morelet's crocodile will remain protected under the provisions of the Convention on International Trade in Endangered Species of Wild Fauna and Flora. We are seeking information, data, and comments from the public on this proposed rule.

DATES:

To ensure that we are able to consider your comments on this proposed rule, they must be received or postmarked on or before June 27, 2011. We must receive requests for public hearings, in writing, at the address shown in the FOR FURTHER INFORMATION CONTACT section below by June 13, 2011.

ADDRESSES:

You may submit comments by one of the following methods:

• Federal eRulemaking Portal: http://www.regulations.gov. Search for docket number FWS-R9-ES-2010-0030 and then follow the instructions for submitting comments.

• U.S

2011. We must receive requests for public hearings, in writing, at the address shown in the FOR FURTHER INFORMATION CONTACT section below by June 13, 2011.

ADDRESSES:

You may submit comments by one of the following methods:

• Federal eRulemaking Portal: http://www.regulations.gov. Search for docket number FWS-R9-ES-2010-0030 and then follow the instructions for submitting comments.

• U.S. mail or hand-delivery: Public Comments Processing, Attn: FWS-R9-ES-2010-0030; Division of Policy and Directives Management; U.S. Fish and Wildlife Service; 4401 N. Fairfax Drive, Suite 222; Arlington, VA 22203.

We will not accept comments by e-mail or fax. We will post all comments on http://www.regulations.gov. This generally means that we will post any personal information you provide us (see the Public Comments section below for more information).

FOR FURTHER INFORMATION CONTACT:

Janine Van Norman, Chief, Branch of Foreign Species, Endangered Species Program, U.S. Fish and Wildlife Service, 4401 North Fairfax Drive, Room 420, Arlington, VA 22203, U.S.A.; telephone 703-358-2171; facsimile 703-358-1735. Individuals who are hearing-impaired or speech-impaired may call the Federal Information Relay Service at 800-877-8339 for TTY assistance 24 hours a day, 7 days a week.

SUPPLEMENTARY INFORMATION:

Public Comments

Any final action resulting from this proposed rule will be based on the best scientific and commercial data available and be as accurate and effective as possible. Therefore, we request comments or information from other concerned government agencies, the scientific community, industry, or other interested parties concerning this proposed rule. The comments that will be most useful and likely to influence our decisions are those supported by data or peer-reviewed studies and those that include citations to, and analyses of, applicable laws and regulations. Please make your comments as specific as possible and explain the basis for them

gencies, the scientific community, industry, or other interested parties concerning this proposed rule. The comments that will be most useful and likely to influence our decisions are those supported by data or peer-reviewed studies and those that include citations to, and analyses of, applicable laws and regulations. Please make your comments as specific as possible and explain the basis for them. In addition, please include sufficient information with your comments to allow us to authenticate any scientific or commercial data you reference or provide. In particular, we seek comments concerning the following:

(1) New biological, trade, or other relevant information and data concerning any threat (or lack thereof) to the Morelet's crocodile.

(2) New information and data on whether or not climate change is a threat to the Morelet's crocodile, what regional climate change models are available, and whether they are reliable and credible to use as step-down models for assessing the effect of climate change on the species and its habitat.

(3) The location of any additional populations of Morelet's crocodile.

(4) New information and data concerning the range, distribution, and population size and population trends of the Morelet's crocodile.

(5) New information and data on the current or planned activities within the geographic range of the Morelet's crocodile that may affect or benefit the species.

(6) New information and data concerning captive breeding operations in Mexico, Belize, and Guatemala.

(7) New information and data on the Morelet's crocodile in Guatemala that would enhance our analysis of whether this population qualifies as a Distinct Population Segment under the Act (16 U.S.C. 1531 et seq. ), and whether this population warrants continued protection under the Act.

species.

(6) New information and data concerning captive breeding operations in Mexico, Belize, and Guatemala.

(8) Information and data concerning the status and results of monitoring actions for the Morelet's crocodile, including those implemented under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), the Belize-Guatemala-Mexico Tri-national Strategy for the Conservation and Sustainable Use of Morelet's Crocodile, and the Belizean monitoring plan that are discussed under the Post-Delisting Monitoring section below.

(9) Information pertaining to Belize's efforts to fully enact national legislation and/or their efforts to ensure Belize's compliance with CITES.

Please note that submissions merely stating support for or opposition to the action under consideration without providing supporting information, although noted, will not be considered in making a determination, as section 4(b)(1)(A) of the Endangered Species Act of 1973, as amended (Act; 16 U.S.C. 1531 et seq. ) directs that a determination as to whether any species is an endangered or threatened species must be made “solely on the basis of the best scientific and commercial data available.”

Prior to issuing a final rule on this proposed action, we will take into consideration all comments and any additional information we receive. Such information may lead to a final rule that differs from this proposal. All comments and recommendations, including names and addresses, will become part of the administrative record.

You may submit your comments and materials concerning this proposed rule by one of the methods listed in the ADDRESSES section

will take into consideration all comments and any additional information we receive. Such information may lead to a final rule that differs from this proposal. All comments and recommendations, including names and addresses, will become part of the administrative record.

You may submit your comments and materials concerning this proposed rule by one of the methods listed in the ADDRESSES section. We will not consider comments sent by e-mail or fax or to an address not listed in the ADDRESSES section. If you submit a comment via http://www.regulations.gov, your entire comment—including any personal identifying information—will be posted on the Web site. Please note that comments posted to this Web site are not immediately viewable. When you submit a comment, the system receives

If you mail or hand-deliver a hardcopy comment that includes personal identifying information, you may request at the top of your document that we withhold this information from public review. However, we cannot guarantee that we will be able to do so. To ensure that the electronic docket for this rulemaking is complete and all comments we receive are publicly available, we will post all hardcopy submissions on http://www.regulations.gov.

In addition, comments and materials we receive, as well as supporting documentation used in preparing this proposed rule, will be available for public inspection in two ways:

(1) You can view them on http://www.regulations.gov. In the Enter Keyword or ID box, enter FWS-R9-ES-2010-0030, which is the docket number for this rulemaking.

post all hardcopy submissions on http://www.regulations.gov.

In addition, comments and materials we receive, as well as supporting documentation used in preparing this proposed rule, will be available for public inspection in two ways:

(1) You can view them on http://www.regulations.gov. In the Enter Keyword or ID box, enter FWS-R9-ES-2010-0030, which is the docket number for this rulemaking.

(2) You can make an appointment, during normal business hours, to view the comments and materials in person at the U.S. Fish and Wildlife Service's Endangered Species Program located in our Headquarters office (see FOR FURTHER INFORMATION CONTACT ).

Public Availability of Comments

Before including your address, phone number, e-mail address, or other personal identifying information in your comment, you should be aware that your entire comment—including your personal identifying information—might be made publicly available at any time. While you can ask us in your comment to withhold your personal identifying information from public review, we cannot guarantee that we will be able to do so.

Public Hearing

Section 4(b)(5)(E) of the Act provides for one or more public hearings on this proposed rule, if requested. We must receive requests for public hearings, in writing, at the address shown in the FOR FURTHER INFORMATION CONTACT section by the date shown in the DATES section of this document. We will schedule public hearings on this proposal, if any are requested, and announce the dates, times, and places of those hearings, as well as how to obtain reasonable accommodations, in the Federal Register at least 15 days before the first hearing.

Background

and places of those hearings, as well as how to obtain reasonable accommodations, in the Federal Register at least 15 days before the first hearing.

Background

Section 4(b)(3)(A) of the Act requires the Service to make an initial finding as to whether a petition to list, delist, or reclassify a species has presented substantial information indicating that the requested action may be warranted. To the maximum extent practicable, the finding shall be made within 90 days following receipt of the petition and published promptly in the Federal Register . If the 90-day finding is positive—that is, the petition has presented substantial information indicating that the requested action may be warranted—section 4(b)(3)(A) of the Act requires the Service to commence a status review of the species if one has not already been initiated under the Service's internal candidate assessment process. In addition, section 4(b)(3)(B) of the Act requires the Service to make a finding within 12 months following receipt of the petition on whether the requested action is warranted, not warranted, or warranted but precluded by higher-priority listing actions. That finding is referred to as the “12-month finding.”

Previous Federal Actions

The Morelet's crocodile was listed as endangered throughout its entire range under the predecessor of the Act via a rule published in the Federal Register on June 2, 1970 (35 FR 8491). Import into, export from, or re-export from the United States, as well as other prohibitions, including movement in the course of a commercial activity and sale in interstate or foreign commerce, of endangered species and their parts and products, are prohibited under the Act unless otherwise authorized. Authorizations for endangered species can only be made for scientific purposes or to enhance the propagation or survival of the species. On July 1, 1975, the Morelet's crocodile was listed in Appendix I of CITES

he course of a commercial activity and sale in interstate or foreign commerce, of endangered species and their parts and products, are prohibited under the Act unless otherwise authorized. Authorizations for endangered species can only be made for scientific purposes or to enhance the propagation or survival of the species. On July 1, 1975, the Morelet's crocodile was listed in Appendix I of CITES. These protections were put in place because the species had suffered substantial population declines throughout its range due to habitat destruction and overexploitation through the commercial crocodilian skin trade. CITES Appendix I includes species that are “threatened with extinction which are or may be affected by trade.”

On May 26, 2005, the Service received a petition from the Government of Mexico's Comisión Nacional para el Conocimiento y Uso de la Biodiversidad (CONABIO 2005) to remove the Morelet's crocodile from the List of Endangered and Threatened Wildlife at 50 CFR 17.11.

Based on the information provided, the Service's 90-day finding on the petition, which was published in the Federal Register on June 28, 2006 (71 FR 36743), stated that the petition provided substantial information to indicate that the requested action may be warranted. In that finding, we announced that we had initiated a status review of the species as required under section 4(b)(3)(A) of the Act, and that we were seeking comments on the petition, as well as information on the status of the species, particularly in Belize and Guatemala. The Service also solicited comments or additional information from counterparts in Mexico, Belize and Guatemala.

This proposed rule to delist the Morelet's crocodile throughout its range also constitutes our 12-month finding that the petitioned action is warranted.

Species Information

Three species of crocodilians occur in Mexico and Central America. The Morelet's crocodile and the American crocodile ( Crocodylus acutus ) co-occur in Mexico, Belize, and Guatemala (Schmidt 1924, pp

Belize and Guatemala.

This proposed rule to delist the Morelet's crocodile throughout its range also constitutes our 12-month finding that the petitioned action is warranted.

Species Information

Three species of crocodilians occur in Mexico and Central America. The Morelet's crocodile and the American crocodile ( Crocodylus acutus ) co-occur in Mexico, Belize, and Guatemala (Schmidt 1924, pp. 79 and 85; Stuart 1948, p. 45). While their ranges overlap, the American crocodile has a much larger range than the Morelet's crocodile, and is found in the United States in the State of Florida, as well as in the Caribbean, on Pacific and Atlantic coasts of Central America and northern South America in Venezuela, Colombia, Ecuador, and northern Peru. A third species, the common or spectacled caiman ( Caiman crocodilus ) occurs in Mexico and Guatemala, but is absent from Belize. The distribution of the common caiman also extends into northern South America (Ross 1998, pp. 14-17; Thorbjarnarson 1992, pp. 82-85). The Morelet's crocodile was named after a French naturalist, P.M.A. Morelet (1809-1892), who discovered this species in Mexico in 1850 (Britton 2008, p. 1). The type locality of the species was later restricted to “Guatemala, El Peten, Laguna de Peten” when the species was scientifically described. In Mexico, the Morelet's crocodile is known as “lagarto” or “swamp crocodile” (Rodriguez-Quivedo et al, 2008).

The Morelet's crocodile is a “relatively small species” that usually attains a maximum length of approximately 9.8-11.5 ft (3-3.5 m (Sánchez (2005, p. 4); Britton (2008, p. 1)), with most wild adults ranging in length 6.6-8.2 ft (2-2.5 m). Hurley (2005, p. 2), however, reported specimens attaining 15.4 ft (4.7 m). Platt and Rainwater (2005, p. 25) stated that size estimates where shorter lengths were documented were probably based on populations that had been heavily impacted by hunting and which now contained few large adults. The Morelet's crocodile is distinguished et al. 2006, p. 376; Platt et al

in length 6.6-8.2 ft (2-2.5 m). Hurley (2005, p. 2), however, reported specimens attaining 15.4 ft (4.7 m). Platt and Rainwater (2005, p. 25) stated that size estimates where shorter lengths were documented were probably based on populations that had been heavily impacted by hunting and which now contained few large adults. The Morelet's crocodile is distinguished et al. 2006, p. 376; Platt et al. 2008b, p. 294). The Morelet's crocodile has six nuchal scales of similar size compared to other crocodile species, which have either four nuchal scales or four large nuchal scales and two small ones (CITES 2010a, p.11). Unlike most other species of crocodilians, the Morelet's crocodile lacks bony plates beneath the skin (osteoderms), making their skin more valuable as leather (Hurley 2005, p. 9). Adults have a yellowish-olive black skin, usually showing big black spots at the tail and at the back area, which in some adults can be entirely black. The ventral (underside) area is light in color, with a creamy yellowish tone. A thick and soft skin has made the Morelet's crocodile desirable for commercialization (CITES 2010a, p. 3).

Opportunistic carnivores, juvenile Morelet's crocodiles feed on small invertebrates, especially insects and arachnids, while subadults eat a more diverse diet including mollusks, crustaceans, fish, amphibians, and small reptiles. Adult crocodiles consume reptiles, birds, and mammals (Platt et al. 2002, p. 82; Sánchez 2005, p. 7; Platt et al. 2006, pp. 283-285; CITES 2008, p. 9, CITES 2010a, p. 3). This species is also known to exhibit necrophagy (consumption of dead animal carcasses over an extended period (several days)) and interspecific kleptoparasitism (stealing of food from an individual by another individual) (Platt et al. 2007, p. 310).

Morelet's crocodiles attain sexual maturity at about 4.9 ft (1.5 m) in length, at approximately 7-8 years of age

ES 2008, p. 9, CITES 2010a, p. 3). This species is also known to exhibit necrophagy (consumption of dead animal carcasses over an extended period (several days)) and interspecific kleptoparasitism (stealing of food from an individual by another individual) (Platt et al. 2007, p. 310).

Morelet's crocodiles attain sexual maturity at about 4.9 ft (1.5 m) in length, at approximately 7-8 years of age. A growth rate of 0.63 inches (in) per month (1.6 centimeters (cm) per month) was observed in Morelet's crocodiles during the first 3 years of life under protected conditions in Mexico, while a rate of 0.94-1.18 in per month (2.4-3.0 cm per month) was achieved under farming conditions (Pérez-Higareda et al. 1995, p. 173). Adult females build nests and lay 20-40 eggs per clutch (Hurley 2005, p. 3; Sánchez 2005, p. 6), with an average of 35 eggs per clutch (CITES 2008, p. 9, CITES 2010a, p. 3). Nests, usually constructed of leaf mounds at the beginning of the wet season (April-June), are located on the shores of freshwater wetlands, as well as in coastal lagoons and mangrove patches (Platt et al. 2008a, pp. 179-182).

An analysis based on DNA microsatellite data from hatchlings collected at 10 Morelet's crocodile nests in Belize showed that progeny from five of the 10 nests were sired by at least two males (McVay et al. 2008, p. 643). These data suggested that multiple paternity was a mating strategy for the Morelet's crocodile and was not an isolated event. In addition, this information may be useful in the application of conservation and management techniques for the species.

pecies.

The eggs of Morelet's crocodiles hatch in September-October, 65-90 days after they are laid. Females attend the nest during incubation, and can assist the newborns to leave the nest. Both parents protect juveniles against predators and other adult crocodiles (CITES 2010a, p. 3). Nest failures due to flooding and predation, both avian and mammalian, are common (Platt et al. 2008a, p. 184). Expected lifespan in the wild is 50-65 years (Hurley 2005, p. 4.) The Morelet's crocodile exhibits and shares with other crocodilians many acoustic and visual signals that convey reproductive, territorial, and other types of information (Senter 2008, p. 354).

The Morelet's crocodile occurs primarily in freshwater environments such as lakes, swamps, and slow-moving rivers, but can temporarily inhabit intermittent freshwater bodies, such as flooded savannahs, and occasionally observed in brackish coastal lagoons (Villegas 2006, p. 8). Floating and emergent vegetation provide cover to protect young crocodiles from predators, including cannibalism by adult crocodiles (Sánchez 2005, p. 7). In contrast to the Morelet's crocodile, the American crocodile feeds mainly on fish and occurs primarily in coastal or brackish environments, such as coastal mangrove swamps, brackish and salt water bays, lagoons, marshes, tidal rivers, and brackish creeks. American crocodiles can also be found in abandoned coastal canals and borrow pits and may range inland into freshwater environments preferred by the Morelet's crocodile such as lakes and lower reaches of large rivers. American and Morelet's crocodiles have been known to lay eggs within the same nest mound as conspecifics, suggesting a more gregarious and tolerant demeanor (Brien et al. 2007, pp. 17-18).

The historical distribution of the Morelet's crocodile comprised the eastern coastal plain of Mexico, most of the Yucatan Peninsula, Belize, and northern Guatemala (Hurley 2005, p

species. While not quantifiable or documented by field surveys, Lee (1996, p. 134) characterized the historical distribution and abundance of the Morelet's crocodile in the Yucatan Peninsula of Mexico as follows: “Throughout its range, nearly every local aguada (flood) has (or had) its lagarto, which generally proves to be C. moreletii. ” The same probably could be said about Belize and Guatemala.

It has been widely reported, however, that by the middle of the 20th Century, populations of Morelet's crocodiles were widely depleted due primarily to overharvest for commercial purposes during the 1940s-1950s. In “Crocodiles: An action plan for their conservation,” Thorbjarnarson (1992, p. 68 and the references cited therein) characterized the Mexican populations of Morelet's crocodiles in the early 1990s as very depleted in the Mexican States of Tamaulipas and Veracruz, recovering to some degree and viable in northeastern Mexico, and severely threatened in Tabasco State and Campeche State. However, populations of Morelet's crocodiles were not depleted in southern Chiapas State and eastern Quintana Roo State (Sian Ka'an Biosphere Reserve).

Few historical estimates for the Morelet's crocodile in Belize are available, but based on surveys during 1978 and 1979, Abercrombie et al. i.e., commercial trade in hides). Thorbjarnarson (1992, p. 55) characterized the Morelet's crocodile populations in the early 1990s as generally depleted in the northern part of Belize, but relatively abundant in several other areas. Abercrombie et al. estimated the total population of Morelet's crocodiles older than 9 months of age in Belize at 2,200-2,500 individuals (Abercrombie et al. 1982, p. 16). Nothing was known in the scientific literature at that time about populations in the southern part of Belize

n the early 1990s as generally depleted in the northern part of Belize, but relatively abundant in several other areas. Abercrombie et al. estimated the total population of Morelet's crocodiles older than 9 months of age in Belize at 2,200-2,500 individuals (Abercrombie et al. 1982, p. 16). Nothing was known in the scientific literature at that time about populations in the southern part of Belize. The only available countrywide estimates for the Morelet's crocodile in Belize suggested a total population size of 25,000-30,000 individuals that was declining in number in 1945, was near depletion between 1970 and 1980, and, in response to several protective measures, had undergone a slow recovery by 2000 to about 20,000 individuals (Finger et al. 2002, p. 199).

Thorbjarnarson (1992, p. 64) characterized the Guatemalan populations in the early 1990s as depleted, but capable of recovery. He indicated that 75 individuals had been reported at three lakes in the Petén Region, in the northern portion of the country, and that Morelet's crocodiles were known to be common in other parts of that region.

By the late 1990s, little had changed with regard to our knowledge of the distribution and abundance of the Morelet's crocodile. In “Crocodiles: Status survey and conservation action plan (second edition),” Ross (1998, pp. 46-47) characterized several populations of Morelet's crocodiles in all three countries as depleted. In some areas, however, including the Lacandón Forest (Chiapas State, Mexico) and the Sian Ka'an Biosphere Reserve (Quintana Roo State, Mexico), healthy populations of the Morelet's crocodile existed. These findings were based on anecdotal reports and incidental records; numerical data were not readily available.

Based on extrapolations of habitat relationships ( e.g., vegetation type, size of wetland/riverine feature, and disturbance factors; described in more detail in CONABIO 2005, pp

an Biosphere Reserve (Quintana Roo State, Mexico), healthy populations of the Morelet's crocodile existed. These findings were based on anecdotal reports and incidental records; numerical data were not readily available.

Based on extrapolations of habitat relationships ( e.g., vegetation type, size of wetland/riverine feature, and disturbance factors; described in more detail in CONABIO 2005, pp. 16-19) and frequency of encounter rates (derived from country-specific field research), the potential global population of free-ranging Morelet's crocodiles in 2004 was estimated to be 102,432 individuals (all age classes; 79,718 individuals in Mexico, 8,803 in Belize, and 13,911 in Guatemala), including approximately 19,400 adults (CONABIO 2005, pp. 17-19).

Summary of Factors Affecting the Species

Section 4 of the Act and its implementing regulations, 50 CFR part 424, set forth the procedures for listing, reclassifying, or removing species from the Federal Lists of Endangered and Threatened Wildlife and Plants. “Species” is defined by the Act as including any species or subspecies of fish or wildlife or plants, and any distinct vertebrate population segment of fish or wildlife that interbreeds when mature (16 U.S.C. 1532(16)). Once the “species” is determined, we then evaluate whether that species may be endangered or threatened because of one or more of the five factors described in section 4(a)(1) of the Act. We must consider these same five factors in reclassifying or delisting a species. For species that are already listed as endangered or threatened, the analysis of threats must include an evaluation of both the threats currently facing the species, and the threats that are reasonably likely to affect the species in the foreseeable future following the delisting or downlisting and the removal or reduction of the Act's protections

e factors in reclassifying or delisting a species. For species that are already listed as endangered or threatened, the analysis of threats must include an evaluation of both the threats currently facing the species, and the threats that are reasonably likely to affect the species in the foreseeable future following the delisting or downlisting and the removal or reduction of the Act's protections. We may delist a species according to 50 CFR 424.11(d) if the best available scientific and commercial data indicate that the species is neither endangered nor threatened for the following reasons: (1) The species is extinct; (2) the species has recovered and is no longer endangered or threatened; and/or (3) the original scientific data used at the time the species was classified were in error.

Factor A. Present or Threatened Destruction, Modification, or Curtailment of the Species' Habitat or Range

The overharvest for commercial purposes, rather than habitat destruction or modification, was the primary reason for the Morelet's crocodile being listed under the Act and its inclusion in CITES. However, the Five Factor Analysis under the Act requires an analysis of current and future potential impacts to the species based on modification or destruction of habitat.

The petition (CONABIO 2005) highlights habitat degradation as a potential threat, especially if it involves lack of prey and eventual contamination of water bodies. Currently, the extent of habitat degradation is estimated to be moderate in Mexico and Belize, and slightly higher in northern Petén, Guatemala (CONABIO 2005, Annex 1, p. 10). However, as stated previously, historical estimates of range-wide habitat destruction for the Morelet's crocodile are unavailable or imprecise. We found that the data on habitat destruction was primarily presented separately for each individual country

itat degradation is estimated to be moderate in Mexico and Belize, and slightly higher in northern Petén, Guatemala (CONABIO 2005, Annex 1, p. 10). However, as stated previously, historical estimates of range-wide habitat destruction for the Morelet's crocodile are unavailable or imprecise. We found that the data on habitat destruction was primarily presented separately for each individual country. Therefore, the following analysis of the potential threats to the species from habitat destruction or modification first presents the specific information available for the Morelet's crocodile in each country, and then presents the general information that was available for the species as a whole.

Mexico

The Morelet's crocodile is known historically from 10 states in Mexico (from east to west): Quintana Roo, Yucatán, Campeche, Chiapas, Tabasco, Veracruz, Oaxaca, Hidalgo, San Luis Potosí, and Tamaulipas (Águilar 2005, p. 2). Based on available information and interviews during a 1995 site visit to Mexico by the IUCN Crocodile Specialist Group, Ross (1998, p. 13) suggested “with some confidence” that the Morelet's crocodile was widely distributed throughout most of its original range. At the request of the petitioner, these states were resurveyed to assess current Morelet's crocodile populations in those areas.

Surveys conducted between 2000 and 2004 documented the widespread distribution and relative abundance of wild populations of the Morelet's crocodile in Mexico (Domínguez-Laso et al. 2005, pp. 21-30; also summarized in Sánchez Herrera 2000, pp. 17-19; CONABIO 2005, pp. 11-13 and Annex 5; Sánchez Herrera and Álvarez-Romero 2008, page 415; García et al. 2007, pp. 31-32; Sigler and Domínguez Laso 2008, pp. 11-13). Surveys found Morelet's crocodiles at 63 sites across all 10 Mexican states comprising the species' entire historic range in Mexico (CONABIO 2005, p. 12)

ez-Laso et al. 2005, pp. 21-30; also summarized in Sánchez Herrera 2000, pp. 17-19; CONABIO 2005, pp. 11-13 and Annex 5; Sánchez Herrera and Álvarez-Romero 2008, page 415; García et al. 2007, pp. 31-32; Sigler and Domínguez Laso 2008, pp. 11-13). Surveys found Morelet's crocodiles at 63 sites across all 10 Mexican states comprising the species' entire historic range in Mexico (CONABIO 2005, p. 12). Habitat evaluations based on five environmental components rated habitat quality as excellent at 10 sites (24 percent), or as favorable or suitable at 24 sites (57 percent). Furthermore, evidence of the presence of the Morelet's crocodile was found in cultivated areas and at sites with “intermediate” quality habitats (CONABIO 2005, p. 13). This suggested that the Morelet's crocodile does not require undisturbed habitat in order to occupy a site. Habitat mapping resulted in an estimated minimum of 15,675 mi (25,227 km) of shoreline as suitable Morelet's crocodile habitat in Mexico, which is 72 percent of the estimated suitable shoreline habitat available throughout the species range (CONABIO 2005, pp. 14-16).

Population characteristics of the Morelet's crocodiles in Mexico were also determined during the 2000-2004 field surveys. All age classes were well represented (34 percent juveniles; 47 percent subadults; and 19 percent adults), indicating good recruitment (Domínguez-Laso et al. 2005, p. 31). A higher proportion of males to females (1.55 to 1 overall versus about 1 male per female) was observed in all age classes, except older subadults (Domínguez-Laso et al. 2005, pp. 33-34). Mean frequency of encounter, based on 62 localities surveyed—excluding one outlier site with an atypically large crocodile population—was 5.76 individuals per 0.62 mi (= 1 kilometer (km)) of shoreline (mode = 3.16 individuals per km); Domínguez-Laso et al. 2005, pp. 30, 40). These frequency of encounter rates were similar to those reported for other sites, for example: (1) Sigler et al. (2002, p

. Mean frequency of encounter, based on 62 localities surveyed—excluding one outlier site with an atypically large crocodile population—was 5.76 individuals per 0.62 mi (= 1 kilometer (km)) of shoreline (mode = 3.16 individuals per km); Domínguez-Laso et al. 2005, pp. 30, 40). These frequency of encounter rates were similar to those reported for other sites, for example: (1) Sigler et al. (2002, p. 222) reported rates of 8.33-18.5 individuals per km at various sites throughout Mexico and commented that these were the highest rates ever reported for that country; (2) Cedeño-Vázquez (2002, p. 353) reported rates of 1-2 individuals per km, when present (22 of 40 surveys; 711 individuals counted; all age classes represented; hatchlings in September), at Bahia de Chetumal and Río Hondo, Mexico (n = 17 sites) and commented on the recovery of the species; (3) Cedeño-Vázquez et al. (2006, p. 15) reported rates of 7.6 and 5.3 individuals per km at La Arrigueña, Campeche State, and commented that this suggested a healthy population. A population estimate—based on (a) extrapolations of 3.16 individuals per km, (b) 19 percent adults, and (c) a cautious estimate of occupied habitat (15,675 mi (25,227 km) of river habitat)—produced a result of approximately 79,718 wild individuals (all ages) in Mexico comprising 78 percent of the total wild population, including approximately 15,146 adults in Mexico (Domínguez-Laso 2005, p. 40).

New information now available to the Service documents updates in the geographic distribution of the Morelet's crocodile in Mexico. Because of several unauthorized introductions or escapes from captive-breeding facilities in areas outside of the reported range of the species, the Morelet's crocodile has become established in the wild at three sites: Chacahua, Oaxaca State; Villa Flores, Chiapas State; and Laguna de Alcuzahue, Colima State (Álvarez Romero et al. 2008, p. 415). Several captive-breeding facilities along the Pacific coast in western Mexico contain Morelet's crocodiles

s from captive-breeding facilities in areas outside of the reported range of the species, the Morelet's crocodile has become established in the wild at three sites: Chacahua, Oaxaca State; Villa Flores, Chiapas State; and Laguna de Alcuzahue, Colima State (Álvarez Romero et al. 2008, p. 415). Several captive-breeding facilities along the Pacific coast in western Mexico contain Morelet's crocodiles. These facilities are located in areas outside of the reported range of the species, but potentially with appropriate habitat for this species. Concerns have been raised about these introductions and the potential negative impacts of this “exotic” or “invasive” species on the local biota (Álvarez Romero et al. 2008, pp. 415 and 417). The Government of Mexico is making efforts to diagnose potential threats to the native American crocodile caused by hybridization with the introduced Morelet's crocodile on the Pacific coast of Mexico. The goal of these efforts is to generate morphological and molecular identification materials and study the population dynamics of the American crocodile. It will include monitoring and harvest of Morelet's crocodiles and hybrids for scientific research (CITES 2010a, p. 6).

According to the information presented in CONABIO 2005, the Morelet's crocodile in Mexico occupies at least 12 protected areas (CONABIO 2005, p. 30 and Annex 6). Part of the Sistema Nacional de Áreas Naturales Protegidas (SINANP or National System of Protected Natural Areas, described more fully in the Factor D section, Inadequacy of Existing Regulatory Mechanisms), encompasses 13 percent of the species' range and include the following areas: Los Tuxtlas Biosphere Reserve, Pantanos de Centla Biosphere Reserve, Laguna de Términos Biosphere Reserve, Hampolol Wildlife Conservation and Research Center, El Palmar State Preserve, Ría Lagartos Biosphere Reserve, Yum Balam Biosphere Reserve, Laguna Nichupte, Sian Ka'an Biosphere Reserve, Bahia Chetumal (Bay) and Río Hondo (River)

3 percent of the species' range and include the following areas: Los Tuxtlas Biosphere Reserve, Pantanos de Centla Biosphere Reserve, Laguna de Términos Biosphere Reserve, Hampolol Wildlife Conservation and Research Center, El Palmar State Preserve, Ría Lagartos Biosphere Reserve, Yum Balam Biosphere Reserve, Laguna Nichupte, Sian Ka'an Biosphere Reserve, Bahia Chetumal (Bay) and Río Hondo (River).

The Government of Mexico's 2010 CITES proposal to transfer the Morelet's crocodile from CITES Appendix I to CITES Appendix II provided updated information on the number of protected areas for the Morelet's crocodile in Mexico. About 77 Federal and certified protected areas in Mexico provide shelter and legal protection to the Morelet's crocodile in its potential range. Of these, 11 have records of the species covering 7,763,147 acres (ac) (3,141,634 hectares (ha)) (CITES 2010a, pp. 11, 17-20). The Government of Mexico designated eight of the eleven protected areas containing Morelet's crocodiles as Biosphere Reserves, and the three remaining protected areas containing Morelet's crocodiles as Flora and Fauna Protection Areas. As stated above, these protected areas are part of SINANP (described more fully in the Factor D section, Inadequacy of Existing Regulatory Mechanisms).

The Government of Mexico's 2010 CITES proposal used both a narrative description (CITES 2010a, p. 11) and a list (CITES 2010a, pp. 17-20) to indicate that there are 11 federally protected areas in Mexico containing Morelet's crocodile. CONABIO 2005 used a narrative description (CONABIO 2005, p. 30) to indicate that there are at least 12 federally protected areas in Mexico containing Morelet's crocodile (CONABIO 2005, p. 30), but did not include a list of the federally protected areas. Based on the information available to the Service, we were unable to find any additional data to explain the difference between in the numbers of federally protected areas cited in these two documents

5, p. 30) to indicate that there are at least 12 federally protected areas in Mexico containing Morelet's crocodile (CONABIO 2005, p. 30), but did not include a list of the federally protected areas. Based on the information available to the Service, we were unable to find any additional data to explain the difference between in the numbers of federally protected areas cited in these two documents. The Government of Mexico's 2010 CITES proposal is the more recent document, and we consider it to contain the best available scientific and commercial data on the number of federally protected areas in Mexico.

The Convention on Wetlands of International Importance especially as Waterfowl Habitat (also known as the Ramsar Convention) is an intergovernmental treaty that provides a framework for international cooperation for the conservation of wetland habitats. CONABIO 2005 did not provide information on whether the Ramsar Convention protects any Morelet's crocodile habitat in Mexico. However, this information was included in the Government of Mexico's 2010 CITES proposal. According to their 2010 CITES proposal, there are 41 Ramsar sites in the potential range of the Morelet's crocodile in Mexico, 13 of which have records of the species covering 6,779,875 ac (2,743,718 ha) (CITES 2010a, pp. 11, 17-20).

According to the information presented in CONABIO 2005, one of the main potential threats to the Morelet's crocodile is habitat destruction and fragmentation due to residential and infrastructure development, such as dams, roads, residential areas, and irrigated fields (CONABIO 2005, Annex 2, pp. 4-5). The information presented in CONABIO 2005 indicated that land reform and the ensuing colonization of undeveloped areas is a potential threat to the Morelet's crocodile, but the Government of Mexico has no such actions planned at this time (CONABIO 2005, p. 33)

residential and infrastructure development, such as dams, roads, residential areas, and irrigated fields (CONABIO 2005, Annex 2, pp. 4-5). The information presented in CONABIO 2005 indicated that land reform and the ensuing colonization of undeveloped areas is a potential threat to the Morelet's crocodile, but the Government of Mexico has no such actions planned at this time (CONABIO 2005, p. 33). This threat of habitat degradation is ameliorated in Mexico by the Ley General de Equilibrio Ecológico y Protección al Ambiente (LGEEPA; General Ecological Equilibrium and Environmental Protection Law). This 1988 law has strict restrictions against land use changes in Mexico, especially for undisturbed habitat such as those areas used by the Morelet's crocodile (CONABIO 2005, p. 25). This law is supported by several others in Mexico

According to the information presented by CONABIO, even in the historic context of prolonged habitat alteration, wild populations of Morelet's crocodiles remained abundant; so much so that large, commercial exploitation of the species was occurring up until Federal and international protections were put in place 40 years ago. Alteration of Morelet's crocodile habitat occurring since then may have produced some additional reductions in local populations, but these reductions are not comparable to those of the past. In addition, even in areas where changes to the original environment are not reversible, evidence points to a certain degree of tolerance by Morelet's crocodiles, especially when the habitat alterations are a result of agriculture or low technology livestock production (CONABIO 2005, p. 25).

of agriculture or low technology livestock production (CONABIO 2005, p. 25).

Based on surveys, it appears that the Morelet's crocodile in Mexico occurs in all 10 states from where it traditionally has been reported (CONABIO 2005, pp. 11-19). Although approximately 49 percent of the original range in Mexico has been altered, much of the altered habitat is still occupied by the Morelet's crocodile. Approximately 77,220 mi 2 (200,000 km 2 ) of undisturbed habitat remains in Mexico, which is equivalent to approximately 15,534 mi (25,000 km) of shoreline. The Government of Mexico protects habitat occupied by the Morelet's crocodile in 11 areas designated by the Government of Mexico as either Biosphere Reserves or Flora and Fauna Protection Areas covering a total of 7,763,147 ac (3,141,634 ha). In addition, the Ramsar Convention protects Morelet's crocodile habitat at 13 sites in Mexico covering 6,779,875 ac (2,743,718 ha). We do not have any information or data on the amount of geographic overlap, if any, between the areas of habitat protected by the Government of Mexico versus that protected by the Ramsar Convention. Therefore, we considered these two protection mechanisms as providing separate, but complimentary, habitat protection as part of our analysis of habitat protection under this proposed rule.

We find that the information presented in the petition, as well as the additional information available to the Service, represents the best available scientific and commercial data on habitat destruction or modification for Morelet's crocodiles in Mexico. Although moderate habitat destruction or modification is currently affecting local populations of Morelet's crocodiles in Mexico, and this is likely to continue in the foreseeable future, these activities would not have a significant impact on the species because they would be subject to conservation measures under the Government of Mexico's regulatory framework

for Morelet's crocodiles in Mexico. Although moderate habitat destruction or modification is currently affecting local populations of Morelet's crocodiles in Mexico, and this is likely to continue in the foreseeable future, these activities would not have a significant impact on the species because they would be subject to conservation measures under the Government of Mexico's regulatory framework. This framework will continue to provide adequate protection to the Morelet's crocodile and its habitat in the foreseeable future. Surveys conducted found Morelet's crocodiles at 63 sites across all 10 Mexican states comprising the species' entire historic range in Mexico (CONABIO 2005, p. 12). Given that Mexico contains more than 85 percent of the species' natural range, an estimated 78 percent of all wild individuals, that 7,763,147 ac (3,141,634 ha) of habitat are protected by the Government of Mexico, and that 6,779,875 ac (2,743,718 ha) of habitat are protected by the Ramsar Convention, we conclude that habitat destruction or modification is neither a threat, nor is it anticipated to significantly impact the Morelet's crocodile in Mexico in the foreseeable future.

Belize

The Morelet's crocodile was historically known from all six states in Belize (from north to south): Corozal, Orange Walk, Belize, Cayo, Stann Creek, and Toledo (Anonymous 1998). According to information provided by CONABIO, virtually all of the country contained suitable habitat for the species. The style of economic development in Belize has not required massive alteration of the natural environment. Thus, in general, no extensive and drastic alteration of Morelet's crocodile habitat has occurred in Belize (CONABIO 2005, p. 26). The current amount of altered versus unaltered current habitat for the Morelet's crocodile in Belize is unknown, but the petitioners estimated the current amount of potentially suitable habitat to be approximately 2,050 mi (3,300 km) of shoreline (CONABIO 2005, pp.14-19)

us, in general, no extensive and drastic alteration of Morelet's crocodile habitat has occurred in Belize (CONABIO 2005, p. 26). The current amount of altered versus unaltered current habitat for the Morelet's crocodile in Belize is unknown, but the petitioners estimated the current amount of potentially suitable habitat to be approximately 2,050 mi (3,300 km) of shoreline (CONABIO 2005, pp.14-19).

While the species is widespread in the northern portion of the country, it is naturally limited to a narrow region of lowlands along the coast in the southern part of Belize, which is otherwise mountainous (Schmidt 1924, p. 80; Abercrombie et al. 1982, pp. 12-16; Platt et al. 1999, p. 395; Platt and Thorbjarnarson 2000a, pp. 25-26). Although the Government of Belize was not a party to the petition, teams not associated with the Mexican effort to delist the species recently surveyed these states, in part, to assess Morelet's crocodile populations in those areas. Based on recent surveys, all six districts historically known to contain Morelet's crocodiles were surveyed in a general characterization of the biodiversity of Belize (Boles 2005, p. 4; Belize Forest Department 2006, p. 22; Biological-Diversity.info website 2009). At Spanish Creek Wildlife Sanctuary, in the north-central part of the country, Meerman et al. (2004, pp. 23-24 and 30-32) determined that the Morelet's crocodile was fairly common at the site (frequency of encounter rate = 1.4-2.4 individuals per km). At Mayflower Bocawina National Park, near the coast in the southeastern part of the country, Meerman et al. (2003b, p. 30) unexpectedly located the Morelet's crocodile at fast-flowing streams such as Silk Grass Creek. While this specimen could have been introduced at the site, its occurrence could also be natural. Along the Macal River, in west-central Belize, Stafford et al. (2003, pp

ls per km). At Mayflower Bocawina National Park, near the coast in the southeastern part of the country, Meerman et al. (2003b, p. 30) unexpectedly located the Morelet's crocodile at fast-flowing streams such as Silk Grass Creek. While this specimen could have been introduced at the site, its occurrence could also be natural. Along the Macal River, in west-central Belize, Stafford et al. (2003, pp. 18 and 20) located a breeding population of the Morelet's crocodile (frequency of encounter rate = 1.48 individuals per km) (2001) and 1.25 individuals per km (2002) at a mountainous site at 1,476 ft (450 m) elevation (higher than expected). A total population size at the Macal River site was calculated to be, at minimum, about 94 individuals (Stafford et al. 2003, p. 19).

Earlier comparisons between spotlight surveys conducted in northern Belize in 1979-1980 and 1992-1997 also showed that Morelet's crocodiles were widely distributed and relatively abundant across several habitat types and levels of human accessibility (Platt and Thorbjarnarson 2000b, p. 23). In addition to an extensive system of nature reserves including significant areas of crocodile habitat, these researchers noted relatively high Morelet's crocodile encounter rates in wetlands surrounding sugarcane fields in this area. Morelet's crocodiles were observed in canals and ditches within the municipal limits of Belize City and Orange Walk, as well as in wetlands easily accessible from many villages (Platt and Thorbjarnarson 2000b, p. 23).

Population characteristics of Morelet's crocodiles in Belize were also determined during these surveys. Size class distribution—25.4 percent adults in the 1990s, compared with 5-10 percent in an earlier study—was consistent with population recovery from past overexploitation (Platt and Thorbjarnarson 2000b, p. 24). Platt and Thorbjarnarson (2000b, pp

ages (Platt and Thorbjarnarson 2000b, p. 23).

CONABIO did not present information about the distribution and abundance of the Morelet's crocodile in protected areas in Belize. Other information obtained by the Service, however, suggests that the species is present in many protected areas in Belize, including: Sarstoon Temash National Park (Meerman et al. 2003a, p. 45), Mayflower Bocawina National Park (Meerman, et al. 2003b, p. 30), and Spanish Creek Wildlife Sanctuary (Meerman et al. 2004, pp. 30-31). Overall, about 18-26 percent of the national territory of Belize is under some form of protection (BERDS 2005b, p. 1; Young 2008, p. 29). In several of these protected areas, natural resource extraction is permitted from the site, thus potentially limiting their contribution to the conservation status of the Morelet's crocodile. However, we have no evidence that resource extraction in these Belizean protected areas is currently or anticipated to affect significantly the Morelet's crocodile.

We find that the data presented by CONABIO, and additional data available to the Service, represents the best available scientific and commercial data on habitat destruction or modification for Morelet's crocodiles in Belize. Although habitat destruction or modification is currently affecting some local populations of Morelet's crocodiles in Belize, and this is likely to continue in the foreseeable future, we do not have any evidence that habitat destruction or modification is currently or anticipated to be a threat to the Morelet's crocodile in Belize

tat destruction or modification for Morelet's crocodiles in Belize. Although habitat destruction or modification is currently affecting some local populations of Morelet's crocodiles in Belize, and this is likely to continue in the foreseeable future, we do not have any evidence that habitat destruction or modification is currently or anticipated to be a threat to the Morelet's crocodile in Belize.

Guatemala

The Morelet's crocodile was historically known from the northern portion of Guatemala (States of Petén and Alta Verapaz; Schmidt 1924, pp. 79-84). According to information provided by CONABIO, the Petén region of Guatemala was scarcely populated by humans before 1960 (an estimated 15,000 to 21,000 inhabitants in approximately 12,960 square miles (33,566 km²) or about one third of Guatemala's area) (CONABIO 2005). In 1961, the Government of Guatemala started an official program to foster colonization in the region, and this caused environmental alteration, as well as increased human conflicts with crocodiles. Slightly more than 50 percent of the potential habitat for the Morelet's crocodile has been altered in Guatemala (CONABIO 2005, p. 26). While the current amount of altered versus unaltered habitat for the Morelet's crocodile in Guatemala is unknown, the petitioners estimated the current amount of potentially suitable habitat to be approximately 4,163 mi (6,700 km) of shoreline (CONABIO 2005, pp.14-19). According to information provided by CONABIO, studies on the status of Morelet's crocodile habitat and population in Guatemala are underway, and the potential threats to the species are under assessment (CONABIO 2005, p. 26).

and the potential threats to the species are under assessment (CONABIO 2005, p. 26).

Recent nationwide survey results are not available for Guatemala, but populations appear to remain in their historical range in the northern part of the country, especially the central portion of the State of Petén, Laguna del Tigre National Park (northwestern portion of the State of Petén) (Castañeda Moya et al. 2000, p.63) and the El Mirador-Río Azul National Park (ParksWatch, 2002, page 3). The Laguna del Tigre National Park, the largest national park in Guatemala and the largest protected wetland in Central America, is home to the largest numbers of Morelet's crocodiles in Guatemala (ParksWatch 2003, p. 1).

While information regarding the distribution and abundance of Morelet's crocodile in Guatemala is sparse, investigations conducted in Laguna del Tigre National Park (date unspecified, reported in 1998) estimated 4.35 individuals per km in the Sacluc River and 2.1 individuals per km in the San Pedro River, with a population structure typical of stable populations (Castañeda Moya 1998a, p. 13). Castañeda Moya (1997, p. 1; 1998a, p. 521) characterized Morelet's crocodile distribution in the northern State of Petén, Guatemala, as fragmented, with the healthiest populations in the northern region of Petén, where human impact was lower. In a follow-up study at Laguna del Tigre National Park Castañeda Moya et al. (2000, pp. 62-63) reported a mean frequency of encounter rate for the entire park of 4.3 individuals per km, with maximum values of 12.28 individuals per km at Flor de Luna and 11.00 individuals per km at Laguna La Pista. The Morelet's crocodile was more frequently encountered in closed aquatic systems than in open aquatic systems. Juveniles were more frequently observed than were adults

ya et al. (2000, pp. 62-63) reported a mean frequency of encounter rate for the entire park of 4.3 individuals per km, with maximum values of 12.28 individuals per km at Flor de Luna and 11.00 individuals per km at Laguna La Pista. The Morelet's crocodile was more frequently encountered in closed aquatic systems than in open aquatic systems. Juveniles were more frequently observed than were adults.

Based on extrapolations of habitat relationships in Mexico (which resulted in an estimated 4,159.8 mi (6,694.5 km) of potential habitat in Guatemala) and an average frequency of encounter of 2.078 individuals per km, CONABIO stated that there is an estimated total Guatemalan population of Morelet's crocodile of about 13,911 individuals in the wild (all age classes) comprising 13 percent of the total wild population, including about 2,643 adults (CONABIO 2005, p. 18). Although this is not a typically constructed population estimate, this population estimate constitutes the best available scientific and commercial data for the nationwide abundance of Morelet's crocodiles in Guatemala.

While Guatemala has regulatory mechanisms in place to protect these habitats, it appears that the Government of Guatemala, until recently, was not able to enforce them adequately. Resource extraction, drug trade, a lack of enforcement, and financial issues limited protected areas' potential contribution to the conservation status of the Morelet's crocodile (IARNA URL IIA 2006, pp. 88-92). For example, the Laguna del Tigre National Park, together with the Laguna del Tigre Protected Biotope, was considered critically threatened by drug trade, land grabs, the presence of human settlements, expanding agriculture and cattle Inadequacy of Existing Regulatory Mechanisms.

rade, land grabs, the presence of human settlements, expanding agriculture and cattle Inadequacy of Existing Regulatory Mechanisms.

Castañeda Moya et al. (2000, p. 61), based on historical references, cited increased destruction of habitat due to human encroachment as having an adverse affect on the species. Based on the research at Laguna del Tigre National Park, Castañeda Moya et al. (2000, pp. 61 and 65) indicated that sibal (sawgrass) ( Cladium jamaicense ) was extensively burned each year. This burning constituted a major impact to the Morelet's crocodile habitat, as sibal habitat offered suitable insulation, food availability, nesting cover, and protection from predators. Furthermore, the fires facilitated the expansion of savannahs consisting almost exclusively of jimbal ( Bambusa longifolia ). Studies on the Morelet's crocodile in Petén suggest fires in jimbal groves prevent Morelet's crocodiles from reproducing since fire affects nesting sites (ParksWatch 2003, p. 13). In a more general sense, USAID (2002, pp. 19-23) and Ruiz Ordoñez (2005, pp. 2-8) indicated several conservation threats at the national level in Guatemala, including habitat loss, habitat degradation, habitat fragmentation, overutilization of resources, environmental contamination, and degradation, and the introduction of exotic species.

For the past ten years, USAID and WCS having been working with other NGOs and the Guatemalan government to combat these issues. In their “Maya Biosphere Landscape Conservation Area, Guatemala, Implementation Plan FY 2008” (WCS 2009, page 3) the WCS highlighted their central goals for ensuring the conservation of wide-ranging target species, including the Morelet's crocodile, was to contain the advance of the Laguna del Tigre agro-pastoral frontier and maintain the comparatively intact eastern bloc of the Maya Biosphere Reserve (MBR) forest

osphere Landscape Conservation Area, Guatemala, Implementation Plan FY 2008” (WCS 2009, page 3) the WCS highlighted their central goals for ensuring the conservation of wide-ranging target species, including the Morelet's crocodile, was to contain the advance of the Laguna del Tigre agro-pastoral frontier and maintain the comparatively intact eastern bloc of the Maya Biosphere Reserve (MBR) forest. Strategies to reduce impacts to wildlife in the MBR landscape include involving people in local communities, forest concessions, governments, and NGOs in local conservation efforts; developing adaptive management strategies to address tactically threats across the landscape; and educating local communities on best management practices across the MBR and beyond. Since 2003, however, efforts by the Wildlife Conservation Society (WCS) have reduced areas burned in the MBR in Guatemala. Through educating locals on best management practices, conducting aerial flights, utilizing remote sensing to monitor changes in forest cover and fire, and establishing and patrolling a 47-kilometer fire break, along with regularly reporting to the Guatemalan and provincial governments and national media, WCS's efforts have resulted in a 90% reduction in areas burned in the Laguna del Tigre portion of the MBR (WCS 2009).

In addition, the president of Guatemala recently deployed 250 specially trained soldiers to recover fully all the protected zones of El Peten in Laguna del Tigre National Park. The contingent, called the “green battalion” will work jointly with the Guatemalan Attorney General's Office. This effort is aimed at combating drug trafficking and removal or destruction of natural and archeological resources in Laguna del Tigre, El Peten region of the MBR (Latin American Herald Tribune, 2010).

El Mirador-Río Azul National Park in northeastern Guatemala is located in the department of Petén maintains a population of Morelet's crocodiles (ParksWatch 2002, page 3)

orney General's Office. This effort is aimed at combating drug trafficking and removal or destruction of natural and archeological resources in Laguna del Tigre, El Peten region of the MBR (Latin American Herald Tribune, 2010).

El Mirador-Río Azul National Park in northeastern Guatemala is located in the department of Petén maintains a population of Morelet's crocodiles (ParksWatch 2002, page 3). The park is composed of two sections, which are divided by the Dos Lagunas Biotope. The western section is known as El Mirador and the eastern part is known as Río Azul. This area is considered by World Resources Institute to be the last pristine Guatemalan rainforest. It is also one of the few protected areas that have experienced little deforestation over the years. No permanent human residents live within the park borders or in its immediate surrounding areas. El Mirador-Río Azul National Park is considered vulnerable, by ParksWatch, meaning that immediate conservation measures are not needed at this time, but monitoring is necessary to ensure the protection and maintenance of its biological diversity in the near future (ParksWatch, 2002, page 3). NGO's such as Asociación Balam, WCS-Guatemala, the Asociatión of Forest Communities of Petén (ACOFOP), the Guatemalan National Park Service (CONAP), the Guatemalan Archeological Institute (IDAEH), and the office of the Executive Secretary of the President of Guatemala formed an alliance called the “Mesa Multisectorial para el Area Natural y Cultural de Mirador-Rio Azule”. This alliance was formed to develop consensus among its team members regarding the long-term protection of the park and provide sustained economic contribution to the people of the MBR and of Guatemala.

rmed to develop consensus among its team members regarding the long-term protection of the park and provide sustained economic contribution to the people of the MBR and of Guatemala.

While CONABIO estimated that slightly more than 50 percent of the potential habitat for the Morelet's crocodile has been altered in Guatemala, they gave no information indicating to what extent (CONABIO 2005, p. 26). Very little information has been collected about the consequences of forest fires, hunting, and habitat fragmentation to the Morelet's crocodile. However, Mexico saw the presence of the Morelet's crocodile in cultivated areas and at sites with “intermediate” quality habitats (CONABIO 2005, p. 13) and Belize noted relatively high Morelet's crocodile encounter rates in wetlands surrounding sugarcane fields, canals and ditches within the municipal limits of Belize (Platt and Thorbjarnarson 2000b, p. 23). This information suggests that the Morelet's crocodile does not require undisturbed habitat in order to occupy a site. The current amount of altered versus unaltered habitat for the Morelet's crocodile in Guatemala is unknown, but the petitioners estimated the current amount of potentially suitable habitat to be approximately 4,163 mi (6,700 km) of shoreline (CONABIO 2005, pp.14-19).

Other Threats to the Species' Habitat

Recreational and Educational Activities

Nonconsumptive recreational or educational uses in the form of ecotourism are ongoing and may grow in magnitude in the future. While CONABIO did not present precise information about the number of companies or sites visited by tourists, an informal Internet search suggested that large numbers of ecotourism companies and nature sites in all three range countries were involved in this activity. At Tikal National Park in Guatemala, for example, the number of visitors has increased from 14,594 visitors in 1981 to 141,899 visitors in 2002 (IARNA URL IIA 2006, p. 103)

ormation about the number of companies or sites visited by tourists, an informal Internet search suggested that large numbers of ecotourism companies and nature sites in all three range countries were involved in this activity. At Tikal National Park in Guatemala, for example, the number of visitors has increased from 14,594 visitors in 1981 to 141,899 visitors in 2002 (IARNA URL IIA 2006, p. 103). Many of these visitors potentially visited Morelet's crocodile areas in the Petén Region that are in the immediate vicinity of the park as part of their ecotourism experience.

While we cannot completely rule out the potential for adverse effects to the Morelet's crocodile due to disturbance

Mazzotti et al. (2005, p. 984), however, did identify the following negative impacts associated with tourism development at Sian Ka'an Biosphere Reserve (Mexico):

(1) Habitat loss;

(2) Alteration of surface and underground water flow;

(3) Ground water pollution;

(4) Extraction of resources;

(5) Erosion and sedimentation;

(6) Decrease in biodiversity; and

(7) Reduced traditional and recreational use for local communities.

Visual pollution, including trash, as well as “jeep safaris” (caravans of small convertible sports utility vehicles being driven through the reserve) and boat traffic, is also increasing at Sian Ka'an Biosphere Reserve (Mazzotti et al. 2005, p. 992). While none of these factors was specifically linked to the Morelet's crocodile, all could apply were the situation to deteriorate. However, we do not have any information to indicate that the situation will deteriorate in the future. Biosphere Reserves in Mexico are part of the United Nations Educational, Scientific, and Cultural Organization's (UNESCO) “Man and the Biosphere” program and are legally protected under Mexican federal laws. Key features of biosphere reserves are core zones of complete protection of key resources surrounded by mixed-use buffer zones

on to indicate that the situation will deteriorate in the future. Biosphere Reserves in Mexico are part of the United Nations Educational, Scientific, and Cultural Organization's (UNESCO) “Man and the Biosphere” program and are legally protected under Mexican federal laws. Key features of biosphere reserves are core zones of complete protection of key resources surrounded by mixed-use buffer zones. These buffer zones are particularly important given the pressures on the Sian Ka'an Biosphere Reserve from tourism, and its culturally and archeologically significant areas (Mazzotti et al. 2005, p. 982). Recognizing these potential negative factors, geographically dispersed ecotourism involving limited numbers of visitors under controlled conditions to observe and photograph specimens from canoes, photographic blinds, or hiking trails can provide relatively benign opportunities to local residents for economic benefits that can serve as an alternative or disincentive to harvest the Morelet's crocodile (CONABIO 2005, p. 28).

There is also evidence that ecotourism, as well as scientific research and wildlife conservation, are compatible activities with respect to the Morelet's crocodile. In Mexico, for example, ecotourists accompany biologists associated with the Amigos de Sian Ka'an group as they conduct surveys of the Morelet's crocodile at Sian Ka'an Biosphere Reserve, along the eastern coast of the Yucatan Peninsula, Quintana Roo State (EcoColors Tours 2010, pp. 1). At another site, the La Ventanilla Eco-tourism Project in Oaxaca State, Mexico, international volunteers assist local residents and biologists to conserve the Morelet's crocodile, turtles, iguanas, and other species of wildlife (Volunteers for International Partnership—Mexico 2010, 1-4)

ere Reserve, along the eastern coast of the Yucatan Peninsula, Quintana Roo State (EcoColors Tours 2010, pp. 1). At another site, the La Ventanilla Eco-tourism Project in Oaxaca State, Mexico, international volunteers assist local residents and biologists to conserve the Morelet's crocodile, turtles, iguanas, and other species of wildlife (Volunteers for International Partnership—Mexico 2010, 1-4). In Belize, tourists, as well as wildlife researchers from the United States and their Belizean counterparts, are implementing an ecological field study of the Morelet's crocodile at Lamanai Outpost Lodge and Research Station that eventually will lead to the development of a national management plan for the species (The Croc Docs 2010, pp. 1-6). If the biological data, in part collected by the ecotourists, support harvest, and effective enforcement regulations can be developed and implemented, this plan may include commercial exploitation of the Morelet's crocodile. In Guatemala, scientists and ecotourists are working cooperatively with the ProPetén group to undertake conservation work at the Scarlet Macaw Biological Station in the Maya Biosphere Reserve (ProPeten 2009, p. 1). While these activities differ with regard to specific details, in general they provide positive conservation benefits to the Morelet's crocodile and demonstrate that ecotourism, as well as scientific research and wildlife conservation, can be compatible with respect to the species.

Agriculture, Grazing, and Infrastructure Development

Agriculture, grazing, and infrastructure development (such as dams, roads, residential areas, and irrigated fields) generally are indirect impacts in that the purpose of the action is not focused on the crocodile. These activities can be either consumptive (for example, destruction of nests and eggs by machinery) or nonconsumptive (for example, loss of access to traditional nesting or feeding sites), and are generally manifested through habitat loss or fragmentation

ads, residential areas, and irrigated fields) generally are indirect impacts in that the purpose of the action is not focused on the crocodile. These activities can be either consumptive (for example, destruction of nests and eggs by machinery) or nonconsumptive (for example, loss of access to traditional nesting or feeding sites), and are generally manifested through habitat loss or fragmentation. Depending on the nature and extent of these activities, they may have a substantial negative impact on local Morelet's crocodile populations. Although agriculture, grazing, and infrastructure development are currently affecting local populations of Morelet's crocodiles, and this is likely to continue in the foreseeable future, we do not have any evidence that these activities are currently or anticipated to be a range-wide threat to the Morelet's crocodile.

Summary of Factor A

Although some habitat degradation has occurred in Mexico, this threat is ameliorated by the LGEEPA. This law has strict restrictions against land use changes in Mexico, especially for undisturbed habitat such as those areas used by the Morelet's crocodile (CONABIO 2005, p. 25). The Sistema Nacional de Áreas Naturales Protegidas (SINANP) also provides significant habitat protection in Mexico. The SINANP created designated protected areas because these areas contain key or representative ecosystems or species, or ecosystems or species that are at risk and require strict control. In Mexico, at least 11 protected areas contain populations of the Morelet's crocodile (CITES 2010a, pp. 17-20). In Belize, at least three protected areas contain Morelet's crocodile populations (Meerman et al. 2003a, p. 45; Meerman et al. 2003b, p. 30; and Meerman et al. 2004, pp. 30-31). Mexico and Belize contain the majority of all wild Morelet's crocodiles (87 percent) and the majority of the potentially suitable habitat throughout the species' range (81 percent)

let's crocodile (CITES 2010a, pp. 17-20). In Belize, at least three protected areas contain Morelet's crocodile populations (Meerman et al. 2003a, p. 45; Meerman et al. 2003b, p. 30; and Meerman et al. 2004, pp. 30-31). Mexico and Belize contain the majority of all wild Morelet's crocodiles (87 percent) and the majority of the potentially suitable habitat throughout the species' range (81 percent). We find that, although habitat destruction and modification is affecting individual crocodiles locally, the overall level of habitat protection in Mexico and Belize is currently adequate and we anticipate that it will remain so.

Based on current information, Guatemala contains the remaining 13 percent of the wild Morelet's crocodiles and the remaining 19 percent of the potentially suitable habitat throughout the species' range. Although the Morelet's crocodile occupies at least two protected areas in Guatemala (Castañeda Moya et al. 2000, p. 63), one, the El Mirador-Río Azul National Park has no permanent human presence either in or surrounding the park and contains the last pristine rainforest in Guatemala which has experienced very little deforestation. The NGO community has partnered with the President of Guatemala to establish a coalition to ensure long-term protection of this important national park, while providing for sustainable economic incentives to the people of the MBR and of Guatemala. The second protected

Despite the localized impacts in all three countries, the current range-wide distribution of Morelet's crocodile now closely resembles historical range-wide distribution. The species has existing available high quality habitat, healthy population distribution, is abundant at known sites and it is expanding into new sites. Even in the face of habitat alteration, this species has been shown to occupy disturbed habitat. There have been observed increases in the relative abundance of the species, and a total population size of approximately 19,400 adults in the three range countries

s existing available high quality habitat, healthy population distribution, is abundant at known sites and it is expanding into new sites. Even in the face of habitat alteration, this species has been shown to occupy disturbed habitat. There have been observed increases in the relative abundance of the species, and a total population size of approximately 19,400 adults in the three range countries. Species experts now widely characterize Morelet's crocodile populations as healthy. Although some local factors continue to affect the habitat for Morelet's crocodile, we have no information to indicate that these local factors are of sufficient magnitude to have a range-wide impact on the species to the point that would cause the Morelet's crocodile to meet the definition of either an endangered or a threatened species. Therefore, we find that the present or threatened destruction, modification, or curtailment of its habitat or range is not likely to threaten or endanger the Morelet's crocodile in the foreseeable future.

Factor B. Overutilization for Commercial, Recreational, Scientific, or Educational Purposes

Commercial Harvest (Legal and Illegal Trade)

The Morelet's crocodile was included in Appendix I of CITES on July 1, 1975. Species included in Appendix I are species threatened with extinction that are or may be affected by trade. CITES prohibits international trade in specimens of these species unless the trade is found to be not detrimental to the survival of the species, the specimens in trade were legally acquired, and the purpose of the import is not for primarily commercial purposes or the specimen meets one of the exemptions established under the CITES Treaty. A more thorough explanation of CITES is found in the “ Convention on International Trade in Endangered Species of Wild Fauna and Flora” discussion under the section Factor D. Inadequacy of Existing Regulatory Mechanisms

trade were legally acquired, and the purpose of the import is not for primarily commercial purposes or the specimen meets one of the exemptions established under the CITES Treaty. A more thorough explanation of CITES is found in the “ Convention on International Trade in Endangered Species of Wild Fauna and Flora” discussion under the section Factor D. Inadequacy of Existing Regulatory Mechanisms.

Overexploitation for commercial purposes prior to 1970 is widely accepted as the primary cause of a drastic, range-wide population decline of Morelet's crocodile (Platt and Thorbjarnarson 2000b, p. 21; CONABIO 2005, p. 27). Historically, commercial overexploitation, through the harvest of adult animals from the wild, was a much greater threat to the Morelet's crocodile than habitat loss. During the first half of the 20th century, hundreds of thousands of skins per year were marketed (CITES 2008, pp. 17, 20). The precise magnitude of the trade is unclear however, because trade data for the Morelet's crocodile was recorded at a higher taxonomic level incorporating other crocodilians. See, for example, Loa Loza 1998a, pp. 134-135; Arroyo-Quiroz et al. 2007, p. 933. It is reported that prior to 1975, hide dealers in Belize purchased up to 12,000 skins annually, and an unknown number of skins were exported illegally in contravention to Mexican law (Plat and Thorbjarnarson 2000b, p. 21). Precise estimates of historical trade from Mexico or Guatemala were unavailable. Even now, the commercial market for designer fashion items made from high quality crocodile skins, such as leather belts, footwear, wallets, and handbags, is highly lucrative. For example, a single pair of shoes may retail for hundreds of dollars, a handbag for several thousand dollars, and a tote bag for tens of thousands of dollars

s of historical trade from Mexico or Guatemala were unavailable. Even now, the commercial market for designer fashion items made from high quality crocodile skins, such as leather belts, footwear, wallets, and handbags, is highly lucrative. For example, a single pair of shoes may retail for hundreds of dollars, a handbag for several thousand dollars, and a tote bag for tens of thousands of dollars.

Legal Trade

In 1997, the Government of Mexico established a system for registering, supervising, and enforcing Unidad de Manejo y Administración (UMAs; Conservation Management and Administrative Units) for intensive reproduction of economically valuable natural resources, including the captive breeding of Morelet's crocodiles (CONABIO 2005, Annex 3, pp. 3-5). Commercial use of Morelet's crocodiles in Mexico for domestic trade was strictly limited to animals raised in closed-cycle, captive-breeding operations regulated by the Government of Mexico under the UMA system. For international trade, commercial trade was restricted to animals raised in these closed-cycle, captive-breeding operations registered with the CITES Secretariat. In order for these closed-cycle, captive-breeding operations to be successful, great care was given to satisfying the biological requirements of the species (Cremieux et al. 2005, p. 417; Brien et al. 2007, pp. 1-26). According to León Velázquez (2004, p. 52), there were approximately 30,000 Morelet's crocodiles in captive-breeding facilities in Mexico in 2004. There were 38,449 Morelet's crocodiles housed in 19 Mexican closed-cycle captive-breeding operations in 2008 (CITES 2010a, p. 24). Currently, the annual production of Morelet's crocodiles in Mexican closed-cycle captive-breeding operations does not exceed 40,000 individuals (CITES 2010a, p. 8).

p. 24). Currently, the annual production of Morelet's crocodiles in Mexican closed-cycle captive-breeding operations does not exceed 40,000 individuals (CITES 2010a, p. 8).

Under Mexican law, closed-cycle captive-breeding operations wishing to make their Morelet's crocodiles available for commercial use must demonstrate that they are able to go beyond the F2 generation of reproducing individuals. This requirement supports the use of Morelet's crocodiles that is compatible with conservation of the species by offsetting the demand for crocodiles taken from the wild. Such facilities produced a variety of items including skins/hides, meat, live individuals as pets, stuffed figurines, and leather products (fashion accessories) for both domestic and international trade.

Based on CITES annual reports for the period 1996-2005, Caldwell (2007, pp. 6-7) noted relatively low levels of international legal trade in products from Mexican captive-breeding operations during 1996-1999 (fewer than 200 skins/year), but higher levels during 2000-2005 (2,430 skins in 2001; 1,591 skins in 2002; and below 1,000 skins per year during the rest of the period). Japan has been the main importer of products from Mexican captive-breeding operations, with lesser quantities going to France, Italy, the Republic of Korea, and Spain (Caldwell 2007, p. 6).

The United Nations Environment Programme—World Conservation Monitoring Centre (UNEP-WCMC) manages a trade database on behalf of the CITES Secretariat. Each Party to CITES is responsible for compiling annual reports to the CITES Secretariat regarding their country's trade in species protected under CITES. UNEP-WCMC enters the data from these annual reports into a trade database, which is used to analyze trade in CITES specimens

Programme—World Conservation Monitoring Centre (UNEP-WCMC) manages a trade database on behalf of the CITES Secretariat. Each Party to CITES is responsible for compiling annual reports to the CITES Secretariat regarding their country's trade in species protected under CITES. UNEP-WCMC enters the data from these annual reports into a trade database, which is used to analyze trade in CITES specimens. Due to the time needed to compile the data, the most recent year

In general, prior to 2010, international legal trade consisted of small quantities of unfinished hides/skins or finished leather products, exported primarily from Mexico to Japan and European countries, as well as biological specimens destined for research. These countries process the unfinished hides/skins into leather products such as belts, footwear, wallets, and handbags that in turn are sold within their own country or re-exported for sale to other countries. Due to the listing status of the species under the Act, the United States cannot be a commercial destination for Morelet's crocodile skins and products. It is currently illegal to import Morelet's crocodile skins and products into the United States, unless the import is for scientific or enhancement purposes.

In 2010, the Government of Mexico submitted a proposal to the 15th Meeting of the CITES Conference of the Parties (CoP15) to transfer the Morelet's crocodile throughout its range to Appendix II of CITES with a zero quota for trade in wild specimens because the Government of Mexico concluded that the Morelet's crocodile no longer met the criteria for inclusion in Appendix I (CITES 2010a, p. 1). Consistent with a request from Guatemala (CITES 2010a, Annex 4, page 25), the Government of Mexico amended their proposal by adding the words “for commercial purposes” after “with a zero quota for trade in wild specimens”

ta for trade in wild specimens because the Government of Mexico concluded that the Morelet's crocodile no longer met the criteria for inclusion in Appendix I (CITES 2010a, p. 1). Consistent with a request from Guatemala (CITES 2010a, Annex 4, page 25), the Government of Mexico amended their proposal by adding the words “for commercial purposes” after “with a zero quota for trade in wild specimens”. In addition, the Government of Guatemala opposed the initial CITES proposal to downlist the species throughout its range based on the lack of knowledge of the population and population trends in Guatemala, threats to the species from deforestation and pollution in Guatemala, and the possibility of illegal, cross-border trade taking place from Guatemala. Because of Guatemala's concerns, Mexico requested that the vote be split, with the Mexico and Belize populations considered separately from the Guatemala's population. The proposal to downlist the Mexico and Belize populations to CITES Appendix II with a zero quota for wild specimens for commercial purposes was adopted by consensus. Mexico then withdrew its proposal to downlist the Guatemala population, leaving that population in CITES Appendix I. As a result, only Morelet's crocodiles in Mexico and Belize were transferred to CITES Appendix II. Morelet's crocodiles in Guatemala remain in CITES Appendix I (CITES 2010b, p. 1). The new CITES designations became effective on June 23, 2010. Please see the discussion in the Factor D section, Inadequacy of Existing Regulatory Mechanisms, for additional information on the change in CITES designation for the Morelet's crocodile.

elet's crocodile.

According to the 2010 CITES proposal to transfer the Morelet's crocodile to Appendix II, the UNEP-WCMC CITES Trade Database showed that, until 2007, the parts and derivatives of the Morelet's crocodile most commonly found in trade were skins, skin pieces and leather products, although other products include live specimens, eggs, bodies, scales, skulls and shoes were also traded. The largest exporter between 2001 and 2007 was Mexico (8,498 skins, 750 skin pieces and 1,193 leather products), followed by Belize with 116 bodies, 766 eggs and 3,124 specimens for scientific purposes (exported to the United States). The major importing countries were Japan (6,170 skins), United States (3,124 specimens for scientific purposes), Italy (1,219 skins), the Republic of Korea (560 skins), France (375 skins) and Spain (162 skins) (CITES 2010a, p. 8).

According to the CITES (CITES 2010a) proposal to transfer the Morelet's crocodile to Appendix II, the national harvest of animals from closed-cycle operations authorized in Mexico amounts to fewer than 2,000 skins per year since the year 2000. In the period between 2000 and 2009, 119 CITES export permits were issued in Mexico for a total of 12,276 Morelet's crocodile skins. However, the total potential production from closed-cycle captive-breeding operations was about 16,500 individuals and approximately 10,000 skins per year (CITES 2010a, p. 7).

We examined the information on Mexico's closed-cycle, captive breeding operations in Annex 3 of the 2010 CITES proposal. According to the information provided in the Annex, there were 19 closed-cycle captive-breeding operations registered as UMAs for the Morelet's crocodile in Mexico. Only four of the 19 UMAs had a captive population sufficient to support commercial trade, and only two of these four could support international commercial trade—both of which were registered with CITES. As of 2008, the captive population in these four UMAs ranged from 1,237 to 28,673 individuals

19 closed-cycle captive-breeding operations registered as UMAs for the Morelet's crocodile in Mexico. Only four of the 19 UMAs had a captive population sufficient to support commercial trade, and only two of these four could support international commercial trade—both of which were registered with CITES. As of 2008, the captive population in these four UMAs ranged from 1,237 to 28,673 individuals. The two UMAs that were not registered with CITES had the potential to produce 1,100 skins per year for local commercial trade (CITES 2010a, Annex 3, p. 24). The population levels for the remaining 15 UMAs were relatively low by comparison, ranging from six to 576 individuals. Rather than supporting commercial trade, four of the remaining 15 UMAs supported exhibition, seven had no commercial production, three contributed to the economic support of the local community, and one was used for research.

Three of these 19 Mexican captive-breeding operations were also registered with CITES, and could therefore commercially trade Morelet's crocodile products internationally, as well as domestically while the species was listed under Appendix I. However, one of these CITES-registered captive breeding operations contains only six individuals, and is used for exhibition purposes. Only two of the three CITES-registered captive breeding operations commercially produce enough Morelet's crocodile skins with the annual production potential for international trade. These two captive breeding operations have the potential to produce an estimated 2,500 skins annually for international trade (CITES 2010a, pp. 7 and 24, Annex 3). Please see the discussion in the Factor D section, Inadequacy of Existing Regulatory Mechanisms, for additional information on the three CITES-registered captive breeding operations.

ex 3). Please see the discussion in the Factor D section, Inadequacy of Existing Regulatory Mechanisms, for additional information on the three CITES-registered captive breeding operations.

There are no captive-breeding facilities in Belize or Guatemala that are providing specimens or skins for trade, either domestically or internationally under the CITES captive-breeding exception (CITES 2010c). In Belize, Morelet's crocodiles are officially protected from commercial harvest. Platt and Thorbjarnarson (2000b) found no evidence of commercial poaching of Morelet's crocodiles for skins or meat in Belize (Platt and Thorbjarnarson 2000b, p. 27). Reportedly, the species is not subject to commercial activities in Guatemala given that Guatemala's Comisión Nacional de Áreas Protegidas (CONAP; National Commission on Protected Areas, also known as the Guatemalan National Park Service) prohibits the export and trade in wild specimens of endangered species (CITES 2010a, p. 7).

Illegal Trade

According to the 2010 CITES proposal to transfer the Morelet's crocodile to Appendix II, the UNEP-WCMC CITES Trade Database showed few illegal movements of parts and derivatives of the Morelet's crocodile between 1975 and 2007 from Mexico, Guatemala, and Belize, with the United States as the only destination. This suggests that there is a very low level of illegal trade and that it is only with the United States; however, enforcement actions are not a required field for CITES Annual Reports. Unlike the United States, most countries do not specify the

Considering the same caveats pertaining to WCMC data, there were eight records illegal trade occurring from Guatemala (between 1989 and 1997), mainly involving pairs of shoes (27), and one case in Belize, which involved the export of 31 eggs in 1995. Regarding Guatemala, Castañeda-Moya (1998) stated that illegal capture of the species continued in the Petén region in that year

do not specify the

Recent data available on illegal trade in the Morelet's crocodile between 1975 and 2007 showed that the United States reported illegal imports (UNEP-WCMC CITES Trade Database 2010a). The data on illegal imports are based on the numbers of items that were seized and confiscated by law enforcement personnel in both the United States and in other countries. This information is not included in CITES annual reports for each country; the United States is the exception. The majority of the illegal Morelet's crocodile parts and derivatives confiscated upon arrival into the United States between 1975 and 2007 came from Mexico (20 skins, 28 handbags, 243 leather items, 419 pairs of shoes, 3 watch straps, 9 bodies, 10 garments, 2 live animals, and 65 small leather products). Again, these items could have come from legal operations in Mexico, but were a violation at the time under the Act due to the Morelet's crocodile's endangered status. A significantly smaller number of illegal items originated from Guatemala (1 skin, 2 handbags, 1 leather item, 27 pairs of shoes, and 1 body) and Belize (31 eggs). The majority of the illegal trade reportedly began in 1985, but began to decline steadily starting in 2000. Between 2005 and 2007, there were only several reported illegal imports of Morelet's crocodile into the United States, and these were small leather products from Mexico (UNEP-WCMC CITES Trade Database 2010b)

in, 2 handbags, 1 leather item, 27 pairs of shoes, and 1 body) and Belize (31 eggs). The majority of the illegal trade reportedly began in 1985, but began to decline steadily starting in 2000. Between 2005 and 2007, there were only several reported illegal imports of Morelet's crocodile into the United States, and these were small leather products from Mexico (UNEP-WCMC CITES Trade Database 2010b).

The Government of Mexico's Federal Prosecutor for Environmental Protection (PROFEPA) has investigated illegal trade in live animals, presumably for the pet trade. A potential illegal market in live animals is under analysis, and would be expected to involve the Mexican cities of Guadalajara, Monterrey, and Mexico City (Mexico 2006, p. 41). Illegal harvest or killing of individuals perceived as threats to humans or livestock cannot be completely precluded, but enforcement of controls on domestic and international trade severely limit any commercial incentives. PROFEPA performs inspections to prevent laundering of wild Morelet's crocodile specimens and other illegal activities. There was a declining trend in seizures of illegal specimens and products during 1998-2007. According to Mexico (Mexico 2006, pp. 39-42), 85 specimens were confiscated in 2003, two in 2004, 80 in 2005, and 14 in 2006 (partial results). In addition and according to Paola Mosig, Program officer for the TRAFFIC World Wildlife Fund in Mexico, 20 seizures with a total of 48 live specimens, as well as 25 belts and two wallets were confiscated in 2007 (Mosig 2008, pers. comm.) According to TRAFFIC, the Wildlife Trade Monitoring Network, these seizures are indicative of a strong enforcement program that deters illegal trade (Mosig 2008, pers. comm.).

Current Trade

In accordance with Article II, paragraph 2(a) of CITES, and CITES Resolution Conf

es with a total of 48 live specimens, as well as 25 belts and two wallets were confiscated in 2007 (Mosig 2008, pers. comm.) According to TRAFFIC, the Wildlife Trade Monitoring Network, these seizures are indicative of a strong enforcement program that deters illegal trade (Mosig 2008, pers. comm.).

Current Trade

In accordance with Article II, paragraph 2(a) of CITES, and CITES Resolution Conf. 9.24 (Rev CoP14) Annex 1, the Government of Mexico submitted a proposal (CoP15 Prop.8) to the CoP15 to transfer the Morelet's crocodile throughout its range to Appendix II of CITES with an annotation requiring a zero quota for wild specimens that was further amended by adding the phrase, “for commercial purposes” (CITES 2010a, p. 1). The Government of Guatemala opposed Mexico's CITES proposal as it pertains to the species in Guatemala, based on the limited knowledge of the population and population trends in Guatemala; the threats to the species from deforestation and pollution in Guatemala; and the possibilities of illegal, cross-border trade taking place from Guatemala to Mexico. As a result, the parties to CITES agreed that Morelet's crocodiles in Mexico and Belize should be transferred to CITES Appendix II but that Morelet's crocodiles in Guatemala remain in CITES Appendix I. (CITES 2010b, p. 2). The change in CITES status for Morelet's crocodiles in Mexico and Belize became effective on June 23, 2010. Because of the zero quota annotation, transferring the Morelet's crocodile to CITES Appendix II precludes the trade of wild specimens for commercial purposes and therefore should not create additional pressure on wild populations in any of the range states, as long as enforcement remains effective. As such, international commercial trade in Morelet's crocodiles under CITES is currently limited to individuals from captive-breeding operations only

g the Morelet's crocodile to CITES Appendix II precludes the trade of wild specimens for commercial purposes and therefore should not create additional pressure on wild populations in any of the range states, as long as enforcement remains effective. As such, international commercial trade in Morelet's crocodiles under CITES is currently limited to individuals from captive-breeding operations only. However, once the Appendix-II status went into effect for Morelet's crocodiles in Mexico and Belize, international trade of Morelet's crocodiles in Mexico and Belize under CITES was no longer limited to facilities that are registered with the CITES Secretariat pursuant to the resolution on registration of operations that breed Appendix-I animal species for commercial purposes (Resolution Conf. 12.10 (Rev. CoP15)).

According to the Government of Mexico's 2010 CITES proposal, the current level of international trade in the Morelet's crocodile is around 8,600 individuals in 10 years (an average of 860 individuals per year). The Morelet's crocodile represents only a small fraction of the global trade in crocodilians, far behind the market leaders: brown spectacled caiman ( Caiman crocodilus fuscus ), American alligator ( Alligator mississippiensis ), and Nile crocodile ( Crocodilus niloticus ). Current trends in international trade do not indicate a threat to the Morelet's crocodile in the wild (CITES 2010a, p. 8). In addition, the Government of Mexico's proposal to move the Morelet's crocodile to CITES Appendix II allows only individuals from sources other than wild populations to be exported and this provision remains in effect with the zero quota for wild specimens traded for commercial purposes. The risk of laundering of wild specimens through farms is very low, because the quality of skins produced in captivity is much higher than wild-caught skins, and demand in international trade focuses on high quality skins (CITES 2010a, pp. 8, 23)

es other than wild populations to be exported and this provision remains in effect with the zero quota for wild specimens traded for commercial purposes. The risk of laundering of wild specimens through farms is very low, because the quality of skins produced in captivity is much higher than wild-caught skins, and demand in international trade focuses on high quality skins (CITES 2010a, pp. 8, 23). It should be noted that there are a number of CITES-recognized production methods that are not “wild” and not “bred in captivity.” Mexico or any other country is free to propose a change to the annotation at the next CoP removing this limitation. However, there is no indication at this time that a change is imminent.

To see if our results would be comparable to Mexico's assessment, we queried the UNEP-WCMC CITES Trade Database for the number of Morelet's crocodile skins legally exported between 1998 and 2008 and found

Besides CITES and the Act, no other international measures control the cross-border movement of the Morelet's crocodile (CITES 2010a, p. 10). If this proposed rule is finalized and the prohibitions of the Act are removed, then Morelet's crocodile parts and products could be imported into the United States for commercial purposes, provided they do not originate in Guatemala. However, cross-border movement of the Morelet's crocodile throughout its range would still be regulated through CITES (Appendix II for Mexico and Belize; Appendix I in Guatemala).

Subsistence Harvest

The overharvest for commercial purposes, rather than subsistence harvest, was the primary reason for the Morelet's crocodile listing under the Act and under CITES. Although subsistence harvest has historically had an impact on some local populations of Morelet's crocodiles, these impacts have diminished over time and do not currently have a significant impact on the species as a whole

ce Harvest

Indigenous cultures in Mexico, Belize, and Guatemala have a long history of using the Morelet's crocodile for subsistence and cultural purposes (Maimone Celorio et al. 2006, pp. 40-43; Zamudio 2006, pp. 5-8; Méndez-Cabrera and Montiel 2007, p. 132). Historically, the Maya Indians in Mexico consumed small quantities of the eggs and meat of the Morelet's crocodile (Maimone Celorio et al. 2006, pp. 40-43; Zamudio 2006, pp. 5-8; Méndez-Cabrera and Montiel 2007, p. 132). Hunting and harvest techniques were based on traditional knowledge by these people of the behavior and ecology of the Morelet's crocodile (Cedeño-Vázquez and Zamudio Acedo 2005, pp. 8-9). More recently (1965-1980), and in response to a demand by outside buyers/businessmen, Maya hunters harvested large quantities of hides for commercial purposes, but that activity now has largely been discontinued (Zamudio et al. 2004, p. 344).

Indigenous and nonindigenous people in Belize, generally poor farmers, also engaged in large-scale, commercial harvest of hides during the previous century, but that practice was primarily based on economic instead of cultural reasons (Hope and Abercrombie 1986, p. 146). Abercrombie et al. (1982, p. 19) made a distinction between master hunters in Belize, generally older men who made extensive forays into the forest in search of specific game species, and part-time hunters, generally younger men who made short-term, opportunistic outings and often harvested Morelet's crocodiles. Among other uses, the Morelet's crocodile also has important roles in indigenous art, medicine, and religion (Stocker and Armsey, 1980, p

between master hunters in Belize, generally older men who made extensive forays into the forest in search of specific game species, and part-time hunters, generally younger men who made short-term, opportunistic outings and often harvested Morelet's crocodiles. Among other uses, the Morelet's crocodile also has important roles in indigenous art, medicine, and religion (Stocker and Armsey, 1980, p. 740; Cupul-Magaña 2003, pp. 45-48), and is used locally for handicrafts, jewelry, decorations, and curios (BERDS 2005a, p. 1).

Meerman et al. (2003a, p. 49) noted a relative scarcity of fish and fish predators such as crocodiles in the Sarstoon Temash National Park in Belize. They suspected that fish populations are depressed, and that over-fishing by humans must play a role. People engaged in fishing along the Upper Temash River also annually collect Morelet's crocodile eggs from nests located along water channels for human consumption. In some years, one or more nests escape discovery so the eggs are not collected. As a result, baby crocodiles are subsequently seen that year. Heavy fishing also reduces the potential prey base for the Morelet's crocodile. The heavy predation on eggs together with the depletion of the Morelet's crocodile's prey base may be responsible for the low crocodile count along the river (Meerman et al. 2003a, pp. 42, 45).

Castañeda Moya (1998a, p. 521; 1998b, p. 13) listed illegal hunting as a threat to Morelet's crocodile in the Petén region of Guatemala, but did not provide a numerical estimate of the take. ARCAS, an animal welfare group in Guatemala, reported the rescue or recovery of 49 live individuals (about 8 per year), most likely from pet dealers or private individuals, during the period 2002-2007 (ARCAS 2002, p. 3; 2003, p. 2; 2004, p. 2; 2005, p. 2; 2006, p. 3; 2007, p. 3). We do not have any information describing the effect of these threats on the status of wild populations in Guatemala

e. ARCAS, an animal welfare group in Guatemala, reported the rescue or recovery of 49 live individuals (about 8 per year), most likely from pet dealers or private individuals, during the period 2002-2007 (ARCAS 2002, p. 3; 2003, p. 2; 2004, p. 2; 2005, p. 2; 2006, p. 3; 2007, p. 3). We do not have any information describing the effect of these threats on the status of wild populations in Guatemala.

Although subsistence harvest continues to affect negatively some local populations of the Morelet's crocodile, the impacts appear to be very small. We have no evidence that subsistence harvest is currently or anticipated to affect significantly the Morelet's crocodile throughout its range. The current range-wide distribution of the Morelet's crocodile closely mirrors the historical range-wide distribution, with a total population size of approximately 19,400 adults in the three range countries.

Scientific Research

Scientific research in and of itself also constitutes a use of the Morelet's crocodile. Research in the three range countries has mainly focused on field surveys for the occurrence of the species, relative to abundance and habitat quality, which do not require removal of specimens. Research protocols followed so far have been those accepted worldwide and do not involve significant alteration of habitat or behavior (CITES 2010a, p. 7). Several scientific research projects on the Morelet's crocodile have focused on field surveys that involve capture, handling, or invasive techniques to identify, for example, the species, sex, or size class of the specimen, as well as to collect biological specimens or to attach an identification tag. If conducted according to standard protocols, these physical activities pose little risk of injury or disturbance to the subject crocodiles. Several studies have also entailed, for example, night surveys using bright spotlights (Castañeda Moya et al. 2000, p. 62), stomach flushing (Platt et al. 2006, p. 282), collection of small blood samples (Dever et al. 2002, p

to attach an identification tag. If conducted according to standard protocols, these physical activities pose little risk of injury or disturbance to the subject crocodiles. Several studies have also entailed, for example, night surveys using bright spotlights (Castañeda Moya et al. 2000, p. 62), stomach flushing (Platt et al. 2006, p. 282), collection of small blood samples (Dever et al. 2002, p. 1079), or the gathering of nonviable eggs from nests for contaminants analyses (Rainwater et al. 2002a, p. 320). None of these studies has cited any negative effects due to handling or observation on the Morelet's crocodile populations.

All three range countries regulate scientific research and collection. According to the UNEP-WCMC CITES Trade Database, 3,124 specimens were exported for scientific purposes from Mexico to the United States. From an administrative standpoint, a permit at the state or Federal level regulates the collection of biological samples for scientific purposes in Mexico. In Mexico, the Mexican Endangered

With the Appendix-II designation for Morelet's crocodiles in Mexico and Belize, individuals or institutions wishing to import scientific samples originating from those countries will no longer be required to obtain a CITES import permit. However, the CITES import permit requirement would still be in effect for Guatemala and CITES export permits or re-export certificates, regardless of the country of origin, would be required. The elimination of import permits, while continuing the CITES requirement for export permits and re-export certificates, may result in additional scientific collecting and research to benefit the species while ensuring that adequate protections for the species remain in place (see the Factor D section, Inadequacy of Existing Regulatory Mechanisms, below)

f the country of origin, would be required. The elimination of import permits, while continuing the CITES requirement for export permits and re-export certificates, may result in additional scientific collecting and research to benefit the species while ensuring that adequate protections for the species remain in place (see the Factor D section, Inadequacy of Existing Regulatory Mechanisms, below).

In conclusion, we are not aware of any evidence that utilization of the Morelet's crocodile for scientific research purposes poses anything more than a low risk to the subject individuals; furthermore, risks at the population level are probably negligible. To the contrary, these studies (surveys and sampling) provide useful information essential to monitoring the status and continued health of individuals as well as populations. These studies also allow ecotourists in these countries to work with the scientific community in the collection of Morelet's crocodile data (Volunteers for International Partnership 2009, pp. 1-4.) This provides ecotourists with an opportunity to observe the Morelet's crocodile in its native habitat and to gain firsthand knowledge about the conservation threats that the species is facing.

Ranching

Although the Belize-Guatemala-Mexico Tri-national Strategy for the Conservation and Sustainable Use of Morelet's Crocodile (see the Post-Delisting Monitoring section, below) includes long-term plans for ranching, none of the range countries have given any indication they plan to ranch Morelet's crocodiles within the foreseeable future.

Summary of Factor B

Thus, while uncontrolled commercial harvests nearly extirpated the Morelet's crocodile, the species has largely recovered because of being protected under CITES and the Act in the early 1970s, as well as the implementation of CITES trade controls by all three range countries. All of the range countries currently continue to prohibit harvest of wild Morelet's crocodiles

ure.

Summary of Factor B

Illegal international and domestic trade still occurs, but levels remain low. Any incidence of illegal killing that may have occurred has not prevented the observed population increase of the species. The potential remains for illegal cross-border trade, as well as the laundering of wild specimens through existing captive-breeding operations in Mexico, but enforcement in Mexico is relatively strict. Given the increased effectiveness of law enforcement personnel with regard to the implementation of CITES, the increased supply of captive-bred Morelet's crocodiles in Mexico that are now available for commercial trade as a result of the Morelet's crocodile's transfer to CITES Appendix II, and the increasing awareness of these regulations by the public, we anticipate that illegal trade in wild Morelet's crocodiles will decrease in the majority of the species' range in the foreseeable future.

The Government of Mexico's Federal Prosecutor for Environmental Protection (PROFEPA) performs inspections to prevent laundering of wild Morelet's crocodile specimens and other illegal activities. In Belize, the importation and exportation of wildlife requires a permit and is subject to strict protocols and provisions of the Wildlife Protection Act, Hunting of Scheduled species for scientific or educational purposes in Belize also requires a permit. There was a declining trend in seizures of illegal specimens and products from 1998-2007. According to TRAFFIC, these seizures are indicative of a strong enforcement program that deters illegal trade (Mosig 2008, pers. comm.)

bject to strict protocols and provisions of the Wildlife Protection Act, Hunting of Scheduled species for scientific or educational purposes in Belize also requires a permit. There was a declining trend in seizures of illegal specimens and products from 1998-2007. According to TRAFFIC, these seizures are indicative of a strong enforcement program that deters illegal trade (Mosig 2008, pers. comm.).

Other uses such as scientific research are either benign or involve relatively small numbers of Morelet's crocodiles. In addition and given the steps that the Government of Mexico is taking internally to promote the sustainable commercial use of Morelet's crocodiles, we anticipate that commercial uses will increase in the foreseeable future, especially in Mexico, but that captive-bred specimens will be used instead of wild individuals.

In conclusion, we find that the overutilization for commercial, recreational, scientific, or educational purposes is not a significant factor affecting the Morelet's crocodile throughout its range, both now and for the foreseeable future.

Factor C. Disease or Predation

Inter-specific interactions, namely disease and predation, can have significant impacts on the conservation status of a species. At the time the petition was submitted, disease was not considered a significant conservation threat to the Morelet's crocodile. However, the West Nile Virus (WNV) has been detected in several Mexican populations of the Morelet's crocodile. According to Farfán-Ale et al. (2006, pp. 910-911), six specimens tested negative to the WNV at the Mérida Zoo, Yucatan State, Mexico, during 2003-2004, while six of seven specimens tested positive to the WNV at Ciudad del Carmen, Campeche State, Mexico, in 2004. All crocodiles, including those not sampled, showed no signs of illness at the time of the testing or during the 3 months that followed (Farfán-Ale et al. (2006, p. 911).

In a separate survey conducted during May-October 2005, Hidalgo-Martínez et al. (2008, p

, Mexico, during 2003-2004, while six of seven specimens tested positive to the WNV at Ciudad del Carmen, Campeche State, Mexico, in 2004. All crocodiles, including those not sampled, showed no signs of illness at the time of the testing or during the 3 months that followed (Farfán-Ale et al. (2006, p. 911).

In a separate survey conducted during May-October 2005, Hidalgo-Martínez et al. (2008, p. 80) detected the WNV in six of seven Morelet's crocodiles at Zoológico La Venta, Villahermosa, Tabasco State, Mexico. All animals were healthy at the time of serum collection, and none had a history of WNV-like illness. The presence of WNV antibodies in animals from those zoos demonstrated the presence of WNV in those regions and indicated a potential risk of infection in animals. The magnitude of that potential risk, however, has not been determined. West Nile Virus was responsible for a significant number of deaths of farmed American alligators in the U.S. State of Georgia during separate outbreaks in 2001 and 2002 (Farfán-Ale et al. 2006, p. 908). However, we do not have any information to indicate that WNV causes illness in the Morelet's crocodile. The sample sizes in the above studies on Morelet's crocodile were small, so much larger studies are needed. However, the best available information does not suggest that WNV is a threat or likely to become a threat.

Predation on Morelet's crocodile eggs and juveniles is a common natural phenomenon, posing no risk to healthy populations. They are preyed upon more frequently at the juvenile stage by many birds and medium-sized mammals (CITES 2010a, p. 4). Larger juveniles and subadults are less susceptible than small juveniles are to predation, and only large carnivores such as jaguars ( Panthera onca )

s and subadults are less susceptible than small juveniles are to predation, and only large carnivores such as jaguars ( Panthera onca )

Other interspecific interactions can also affect the conservation status of a species. The Morelet's crocodile and the American crocodile co-occur and may compete with each other for resources along the freshwater-saltwater interface in coastal Mexico and Belize. Platt and Thorbjarnarson (2000a, p. 16; 2000b, pp. 24-26) reported relatively higher frequency of encounter rates for the Morelet's crocodile at alluvial and nonalluvial lagoons, mangrove forest, and rivers and creeks, collectively characterized as inland sites, while the American crocodile was relatively more abundant in offshore cays and the Turneffe Atoll. These differences were attributed to the smaller body size of the Morelet's crocodile, as well as past exploitation patterns by hunters and subsequent niche expansion by this species (Platt and Thorbjarnarson 2000b, p. 26). There was no indication, however, that interspecific competition between the Morelet's and the American crocodiles was a serious conservation problem.

Parasites have been also reported for the Morelet's crocodile, but have not been identified as a conservation threat. In Mexico, trematodes (parasitic flatworms commonly called flukes) and nematodes (unsegmented worms commonly called roundworms) have been reported (Moravec and Vargas-Vázquez 1998, p. 499; Moravec 2001, p. 47) from the Yucatan Peninsula, but health problems with the crocodile hosts were not noted. Rainwater et al. (2001a, p. 836) reported ticks ( Amblyomma dissimile and Amblyomma sp.), but noted that parasitism by ticks on the Morelet's crocodile was rare in Belize and elsewhere.

p. 836) reported ticks ( Amblyomma dissimile and Amblyomma sp.), but noted that parasitism by ticks on the Morelet's crocodile was rare in Belize and elsewhere.

Padilla Paz (2008, p. vi) characterized hematology, body index, and external injuries for 103 Morelet's crocodiles from the northern wetlands of Campeche State, Mexico. These variables were used to characterize the health of the animals. Captive Morelet's crocodiles evaluated for that study presented significantly more injuries than did wild individuals. Parasitism with nematodes ( Paratrichosoma recurvum ) was greater in wild crocodiles than in captive individuals. No serious health issues were identified in individuals in either group (Padilla Paz 2008, pp. 67-68).

Individual Morelet's crocodiles can also have physical issues that can affect their well-being. Rainwater et al. (2001b, pp. 125-127) reported two individuals among 642 Morelet's crocodiles captured in Belize with a missing forelimb. Known in the technical literature as ectromelia, this condition was probably the result of congenital defects and not due to an injury. Both individuals otherwise appeared to be in good condition.

Summary of Factor C

While the full impact of the WNV on the Morelet's crocodile has yet to be determined, there is no indication at present that WNV poses a threat to the species, and other interspecific interactions do not appear to be adversely affecting the Morelet's crocodile. In conclusion, we find that disease or predation is not a significant factor affecting the Morelet's crocodile throughout its range, both now and for the foreseeable future.

Factor D

t's crocodile has yet to be determined, there is no indication at present that WNV poses a threat to the species, and other interspecific interactions do not appear to be adversely affecting the Morelet's crocodile. In conclusion, we find that disease or predation is not a significant factor affecting the Morelet's crocodile throughout its range, both now and for the foreseeable future.

Factor D. Inadequacy of Existing Regulatory Mechanisms

Convention on International Trade in Endangered Species of Wild Fauna and Flora

The Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES, the Convention, or Treaty) is an international agreement between member governments to ensure that the international trade in plants and wildlife does not threaten the species' survival. It provides varying degrees of protection to more than 30,000 species of animals and plants, whether they are traded as live specimens, parts or products. Countries that have agreed to be bound by the Convention (that have “joined” CITES) are known as Parties. Although CITES is legally binding on the Parties, it does not take the place of national laws. Rather, it provides a framework to be respected by each Party, which has to adopt its own domestic legislation to ensure that CITES is implemented at the national level. For many years, CITES has been among the international conservation agreements with the largest membership, with now 175 Parties ( http://www.CITES.org ).

CITES works by subjecting international trade in specimens of selected species to certain controls. Trade includes any movement into or out of a country and is not limited to commercial movement. All import, export, re-export, and “introduction from the sea” of species covered by the Convention have to be authorized through a permitting system. The species covered by CITES are listed in three Appendices, according to the degree of protection they need (CITES 2009c)

d species to certain controls. Trade includes any movement into or out of a country and is not limited to commercial movement. All import, export, re-export, and “introduction from the sea” of species covered by the Convention have to be authorized through a permitting system. The species covered by CITES are listed in three Appendices, according to the degree of protection they need (CITES 2009c).

Appendix I include species threatened with extinction that are or may be affected by trade. Trade in specimens of these species is permitted only in exceptional circumstances. Appendix II includes species not necessarily threatened with extinction, but in which trade must be controlled in order to avoid utilization incompatible with their survival. Appendix III includes species that have been unilaterally listed by a Party to assist in the implementation of the listing Party's national legislation to conserve and monitor trade in the listed species. The Conference of the Parties (CoP), which is the decision-making body of the Convention and comprises all its member countries, has agreed on a set of biological and trade criteria to help determine whether a species should be included in Appendices I or II (Since Appendix-III listings are a unilateral decision, Parties do not need to abide by the same biological and trade criteria adopted by the Parties.). At each regular meeting of the CoP, Parties submit proposals based on those criteria to amend these two Appendices to add, remove, or reclassify species (such as the Government of Mexico's 2010 proposal to transfer the Morelet's crocodile from Appendix I to Appendix II). Parties discuss these amendment proposals during the CoP, and then they are submitted for adoption by the Parties ( http://www.cites.org ).

A specimen of a CITES-listed species may be imported into or exported (or re-exported) from a Party only if the appropriate permit or certificate has been obtained prior to the international trade and presented for clearance at the port of entry or exit

II). Parties discuss these amendment proposals during the CoP, and then they are submitted for adoption by the Parties ( http://www.cites.org ).

Regulation of Trade in Appendix-I Specimens

Both an export permit or re-export certificate must be issued by the country of export and an import permit from the country of import must be obtained prior to international trade for Appendix-I species. An export permit

Issuance of import permits for Appendix-I species will also need a determination from the country of import that the import will not be for purposes that are detrimental to the survival of the species, the proposed recipient of live animals or plants is suitably equipped to house and care for them, and the purpose of the import is not for primarily commercial purposes. Thus, with few exceptions, Appendix-I species cannot be traded for commercial purposes.

Regulation of Trade in Appendix-II Specimens

In contrast to the trade requirements for an Appendix-I species, CITES does not require an import permit from the destination country as a condition for the export and re-export of an Appendix-II species, unless it is required by the destination country's national law. However, an export permit or re-export certificate is required from the exporting country prior to the international trade taking place. An export permit may only be issued for Appendix-II species if the country of export determines that: (1) The export will not be detrimental to the survival of the species; (2) the specimen was legally obtained according to the animal and plant protection laws in the country of export; and (3) live animals or plants are prepared and shipped for export to minimize any risk of injury, damage to health, or cruel treatment

nly be issued for Appendix-II species if the country of export determines that: (1) The export will not be detrimental to the survival of the species; (2) the specimen was legally obtained according to the animal and plant protection laws in the country of export; and (3) live animals or plants are prepared and shipped for export to minimize any risk of injury, damage to health, or cruel treatment.

A re-export certificate may only be issued for Appendix-II species if the country of re-export determines that: (1) The specimen was imported into their country in accordance with CITES and (2) live animals or plants are prepared and shipped for re-export to minimize any risk of injury, damage to health, or cruel treatment.

Parties to CITES are required to monitor both the export permits granted and the actual exports for Appendix II species. If a Party determines that the export of an Appendix-II species should be limited in order to maintain that species throughout its range at a level consistent with its role in the ecosystems in which it occurs and well above the level at which the species might become eligible for inclusion as an Appendix-I species, then that Party must take suitable measures to limit the number of export permits granted for that species (CITES article IV, paragraph 3).

CITES Registered Captive-Breeding Operations

Prior to the Morelet's crocodile in Mexico and Belize being downlisted to Appendix II, it could be treated as an Appendix II species and internationally traded commercially only if the specimen originated from a captive-breeding operation registered with the CITES Secretariat in accordance with CITES Resolution Conf. 12.10 (Rev. CoP15) “Guidelines for a procedure to register and monitor operations that breed Appendix-I animal species for commercial purposes.” These captive-breeding operations may only be registered if specimens produced by that operation qualify as `bred in captivity' according to the provisions of Resolution Conf. 10.16 (Rev.)

th the CITES Secretariat in accordance with CITES Resolution Conf. 12.10 (Rev. CoP15) “Guidelines for a procedure to register and monitor operations that breed Appendix-I animal species for commercial purposes.” These captive-breeding operations may only be registered if specimens produced by that operation qualify as `bred in captivity' according to the provisions of Resolution Conf. 10.16 (Rev.). To qualify as bred in captivity, specimens must be born in a controlled environment where the parents mated. In addition, breeding stock must be established in accordance with the provisions of CITES and relevant national laws and in a manner not detrimental to the survival of the species in the wild. Breeding stock must also be maintained without the introduction of specimens from the wild, except for the occasional addition of animals, eggs or gametes meeting certain requirements. The breeding stock must have produced offspring of second generation (F2) in a controlled environment or be able to demonstrate that it is capable of reliably producing second-generation offspring in a controlled environment. Resolution Conf. 12.10 (Rev. CoP15) defines the term “bred in captivity for commercial purposes” as “any specimen of an animal bred to obtain economic benefit, including profit, whether in cash or kind where the purpose is directed toward sale, exchange, or provision of a service or any other form of economic use or benefit”. Countries operating CITES-registered operations must ensure that the operation “will make a continuing meaningful contribution according to the conservation needs of the species” (CITES 2007b, pp. 1-2). Under the exception in the Treaty and Resolution Conf. 12.10 (Rev. CoP15), specimens of Appendix-I species originating from CITES-registered captive-breeding operations can be traded for commercial purposes, and shipments only need to be accompanied by an export permit issued by the exporting country

eaningful contribution according to the conservation needs of the species” (CITES 2007b, pp. 1-2). Under the exception in the Treaty and Resolution Conf. 12.10 (Rev. CoP15), specimens of Appendix-I species originating from CITES-registered captive-breeding operations can be traded for commercial purposes, and shipments only need to be accompanied by an export permit issued by the exporting country. The importer is not required to obtain an import permit because these specimens are treated as CITES Appendix II. Countries that are Parties to CITES should restrict their imports of Appendix-I captive-bred specimens to those coming only from CITES-registered operations. Additional information on CITES-registered operations can be found on the CITES Web site at http://www.cites.org/eng/resources/registers.shtml.

Prior to the downlisting of the species in Mexico and Belize, three CITES-registered operations for Morelet's crocodiles were located in Mexico. These facilities, while no longer registered with the CITES Secretariat, are still in operation (CITES 2010a, p. 24, Annex 3). The names of these operations are:

(1) Cocodrilos Mexicanos (established in 1989; (former) registration number A-MX-501) in Culiacan, Sinaloa State. In 2008, this operation contained 28,673 captive Morelet's crocodiles for commercial production (CITES 2010a, p. 24, Annex 3).

(2) Industrias Moreletii (established in 1993; (former) registration number A-MX-502) in Villahermosa, Tabasco State. In 2008, this operation contained 1,237 captive Morelet's crocodiles for commercial production (CITES 2010a, p. 24, Annex 3).

n Culiacan, Sinaloa State. In 2008, this operation contained 28,673 captive Morelet's crocodiles for commercial production (CITES 2010a, p. 24, Annex 3).

(3) Cocodrilos de Chiapas (established in 1989; (former) registration number A-MX-503) in Tapachula, Chiapas State. In 2008, this operation contained six captive Morelet's crocodiles for exhibition purposes (CITES 2010a, p. 24, Annex 3).

When the CITES Appendix-II designation became effective on June 23, 2010, for Morelet's crocodiles in Mexico and Belize, commercial international trade in captive Morelet's crocodiles was no longer limited to crocodiles originating from the three operations that were registered with the CITES Secretariat. However, with the annotated listing, no export of wild-caught specimens for commercial purposes is allowed. Thus, any commercial export will continue to come from sources other than wild populations. There are currently 19 closed-cycle captive-breeding operations registered with the Government of Mexico as UMAs for the

Since the Morelet's crocodile in Guatemala is listed as an Appendix-I species under CITES, the only way that Morelet's crocodiles and their parts and products from Guatemala could legally be traded commercially in international trade is if a captive-breeding operation were to be registered with the CITES Secretariat. However, since Guatemala does not currently have any captive breeding operations that are registered with the CITES Secretariat, the commercial international trade in Morelet's crocodile products from Guatemala remains restricted

d products from Guatemala could legally be traded commercially in international trade is if a captive-breeding operation were to be registered with the CITES Secretariat. However, since Guatemala does not currently have any captive breeding operations that are registered with the CITES Secretariat, the commercial international trade in Morelet's crocodile products from Guatemala remains restricted.

However, under the current listing of the species under the Act, it remains illegal to import Morelet's crocodiles or their parts or products into the United States, regardless of the source, unless the purpose of the import is for scientific research or enhancement of propagation or survival of the species. If this proposed rule is finalized and the prohibitions of the Act are removed, Morelet's crocodile parts and products originating from sources other than wild populations from Mexico and Belize could be imported into the United States for commercial purposes, as long as the required CITES export permit or re-export certificate has been granted. As discussed earlier, however, an export permit will not be granted unless the exporting country finds that the export will not be detrimental to the species and the specimen was lawfully acquired.

Mexico's Proposal To Transfer the Morelet's Crocodile to CITES Appendix II

At the 2008 CITES Animals Committee meeting, the Government of Mexico submitted for comment and review a draft proposal to transfer Mexico's population of Morelet's crocodile from Appendix I to Appendix II based on Mexico's belief that the Morelet's crocodile no longer met the criteria for inclusion in Appendix I (CITES 2008a, pp. 1-28; CITES 2008a, p. 32). Committee members were generally favorable of the proposal, but had several technical questions and suggestions. The Government of Mexico subsequently revised their 2008 proposal and formally submitted a 2010 CITES proposal for consideration at CoP15, held in March 2010 in Doha, Qatar (Government of Mexico 2010)

the criteria for inclusion in Appendix I (CITES 2008a, pp. 1-28; CITES 2008a, p. 32). Committee members were generally favorable of the proposal, but had several technical questions and suggestions. The Government of Mexico subsequently revised their 2008 proposal and formally submitted a 2010 CITES proposal for consideration at CoP15, held in March 2010 in Doha, Qatar (Government of Mexico 2010). The 2010 proposal was to transfer the Morelet's crocodile throughout its range to Appendix II (CoP15 Prop. 8). The CITES Secretariat reviewed the proposal and agreed that the Morelet's crocodile no longer met the biological criteria for an Appendix-I species and recommended that the proposal be adopted.

The Government of Mexico's 2010 CITES proposal recommended transferring the Morelet's crocodile from Appendix I to Appendix II because the species no longer met the criteria for inclusion in Appendix I. Under the 2010 proposal, the transfer to Appendix II applied to all three range countries. The 2010 proposal included an annotation establishing a zero quota for wild specimens. The zero quota would prohibit any international trade in wild specimens within the context of CITES, thereby limiting the trade to Morelet's crocodile and its products to those originating from sources other than wild specimens. Although the Belize-Guatemala-Mexico Tri-national Strategy for the Conservation and Sustainable Use of Morelet's Crocodile (see the Post-Delisting Monitoring section, below) includes long-term plans for ranching, none of the range countries have indicated they plan to ranch Morelet's crocodiles within the foreseeable future.

ludes long-term plans for ranching, none of the range countries have indicated they plan to ranch Morelet's crocodiles within the foreseeable future.

The Government of Mexico consulted with the Governments of Belize and Guatemala on their 2010 CITES proposal. The Government of Belize supported the proposal, but did not provide documents to the CITES Secretariat to indicate their official support. According to the Government of Mexico's 2010 CITES proposal, the Government of Guatemala supported the proposal in part, but recommended transferring only the Mexican population of Morelet's crocodile in captive-breeding operations to Appendix II, with a zero quota for wild specimens traded for commercial purposes. In a letter from Guatemala's Consejo Nacional de Areas Protegidas to the Ambassador of Mexico dated 5 June 2009 (CITES 2010a, Annex 4, p. 25), the Government of Guatemala indicated that it did not support the Government of Mexico's 2010 CITES proposal as written. They recommended verifying that moving captive Morelet's crocodiles in Mexico to Appendix II would not put wild Morelet's crocodiles in Mexico at risk. They supported Mexico's transfer of captive-bred populations of Morelet's crocodiles from Appendix I to Appendix II provided the parties ensure the following:

• They verify that wild populations of Morelet's crocodiles in Mexico will not be at risk as they are moved from Appendix I to II;

• If Mexico's proposal at CoP15 is approved, then measures should be put in place for strict monitoring and enforcement on the Mexico-Guatemala border;

• That the marking of live animals be done by methods that cannot be falsified and that skins be tagged in accordance with CITES to maintain chain of custody;

• That the tagging methods for Mexican populations of Morelet's crocodile be widely circulated to range countries and those countries importing parts and products as well as live specimens

and enforcement on the Mexico-Guatemala border;

• That the marking of live animals be done by methods that cannot be falsified and that skins be tagged in accordance with CITES to maintain chain of custody;

• That the tagging methods for Mexican populations of Morelet's crocodile be widely circulated to range countries and those countries importing parts and products as well as live specimens.

Under Guatemala's recommended scenario, Morelet's crocodiles in Mexico, and Belize would be in Appendix II, with a zero quota for wild specimens traded for commercial purposes and all Morelet's crocodiles in Guatemala would remain on Appendix I (CITES 2010a, pp. 12, 25-26). The Appendix-II designation became effective on June 23, 2010. As a result, Morelet's crocodiles and their products from Mexico and Belize from sources other than wild populations are now allowed to enter international trade for commercial purposes under CITES. They are, however, not currently able to enter the United States market because the Act's prohibitions remain in effect. The international commercial trade in all wild Morelet's crocodiles remains restricted.

At this time, the Government of Mexico intends to export products derived from Morelet's crocodiles raised in its captive-breeding operations that are registered with the Government of Mexico as UMAs, and that have a proven track record of producing

record of producing

Now that the Morelet's crocodile in Mexico and Belize is transferred to CITES Appendix II with an annotation providing a zero quota for wild specimens traded for commercial purposes, if this proposed delisting rule under the Act is finalized, then products originating from any captive-breeding operations in Mexico (and Belize, if any) could be imported into the United States. In addition, if this proposed delisting rule under the Act is finalized, then Morelet's crocodile products manufactured in other countries could also be re-exported into the United States if those skins originated in Mexico or Belize and were not derived from wild populations. Live Morelet's crocodiles and parts or products originating from Guatemala will remain in CITES Appendix I, with its associated trade restrictions remaining in place.

Through Resolution Conf. 8.4 (Rev. CoP15) the Parties to CITES have adopted a process, the National Legislation Project, to evaluate whether Parties have adequate domestic legislation to successfully implement the Treaty. In reviewing a country's national legislation, the Secretariat considers whether a Party's domestic laws designate the responsible Scientific and Management authorities, prohibit trade in violation of the Convention, have penalty provisions in place for illegal trade, and provide for seizure of specimens that were illegally traded or possessed.

While both Guatemala and Mexico's legislation have been determined to be sufficient to properly implement the Treaty, Belize's national legislation was considered lacking. As part of the National Legislative Project, Belize has submitted a plan to revise their legislation to the Secretariat in March 2010, but as of this proposed rule, have not officially enacted any revised legislation (CITES 2010e)

ile both Guatemala and Mexico's legislation have been determined to be sufficient to properly implement the Treaty, Belize's national legislation was considered lacking. As part of the National Legislative Project, Belize has submitted a plan to revise their legislation to the Secretariat in March 2010, but as of this proposed rule, have not officially enacted any revised legislation (CITES 2010e). Although a trade suspension was put in place for Belize for one orchid species, Myrmecophila tibicinis, the suspension was in relation to the Review of Significant Trade in Specimens of Appendix II species (CITES 2010d) and not due to Belize's current legislation implementing CITES. If this proposed rule is finalized, CITES will continue to protect the Morelet's crocodile throughout its range by regulating international trade. However, as part of this proposed rule, we are requesting any information on Belize's efforts to enact national legislation and/or their efforts to ensure their compliance with CITES. We will continue to monitor Belize's progress between the proposed and final rules.

All three countries also have protected-species and protected-areas legislation under the jurisdiction of specific ministries or departments. The three range countries have an extensive regulatory framework to control activities with respect to the Morelet's crocodile and its habitat. Mexico is unique among the three range countries in that the Government of Mexico also has legislation regulating captive-breeding operations.

Mexico

The Government of Mexico has a strict and comprehensive legal framework to regulate the conservation and sustainable use of the Morelet's crocodile in Mexico:

amework to control activities with respect to the Morelet's crocodile and its habitat. Mexico is unique among the three range countries in that the Government of Mexico also has legislation regulating captive-breeding operations.

Mexico

The Government of Mexico has a strict and comprehensive legal framework to regulate the conservation and sustainable use of the Morelet's crocodile in Mexico:

(1) Ley General de Equilibrio Ecológico y Protección al Ambiente (LGEEPA; General Ecological Equilibrium and Environmental Protection Law) —This is the primary Mexican law for environmental matters and is the principal legal instrument that regulates the Morelet's crocodile in Mexico (CONABIO 2005, Annex 3, p. 1). Passed in 1988, this law applies to and integrates the three levels of government within the context of natural resources: Federal, state, and municipal. With regard to trade in wildlife species, including the Morelet's crocodile, the LGEEPA contains the basis to regulate all activities, including importation, exportation, seizures, sustainable use, violations, fines, animal welfare, and legal possession. While forty-five articles within the Mexican LGEEPA deal with environmental contamination (CONABIO 2005, Annex 3, p. 1), we are not aware of any specific provisions and their relevance to Morelet's crocodile.

(2) Ley General de Vida Silvestre (LGVS: General Wildlife Law) —Passed in 2000, this law regulates the use, conservation, and management of domestic wild fauna and flora and their habitat (CONABIO 2005, Annex 3, pp. 1-2). This law is based on the principle of sustainable use. Any activity with regard to wild fauna and flora must comply with certain requirements: The activity must be supported by an approved management plan; the quantity to be harvested must be less than natural recruitment (replacement); and the harvest must not have negative impacts on the wild populations, their habitat, or biological activities

This law is based on the principle of sustainable use. Any activity with regard to wild fauna and flora must comply with certain requirements: The activity must be supported by an approved management plan; the quantity to be harvested must be less than natural recruitment (replacement); and the harvest must not have negative impacts on the wild populations, their habitat, or biological activities. With regard to the Morelet's crocodile, harvest of wild populations is not permitted, and harvest under this law would only be permitted for specimens obtained through closed-cycle, captive-breeding operations which have programs that contribute to the development of wild populations (CITES 2010a, p. 9).

According to the LGVS, alien specimens or populations are those occurring outside their natural range (such as the Morelet's crocodiles found on the Pacific coast of Mexico), including hybrids. Such specimens or populations can only be managed in captivity, and with prior approval. A management plan must be in place with established security and contingency measures to avoid any negative effects on the conservation of wild native specimens and populations or their habitat. LGVS establishes management, control, and remediation measures for individuals or populations considered harmful. Measures may consist of capture/collection for the development of recovery, restocking and reintroduction projects; for research or environmental education activities; for relocation of specimens (subject to prior evaluation of the destination habitat and condition of the individuals); for elimination or eradication of individuals/populations; or of actions or devices to keep the individuals away, disperse them, make access difficult or reduce the damage they cause (CITES 2010a, p. 9).

reintroduction projects; for research or environmental education activities; for relocation of specimens (subject to prior evaluation of the destination habitat and condition of the individuals); for elimination or eradication of individuals/populations; or of actions or devices to keep the individuals away, disperse them, make access difficult or reduce the damage they cause (CITES 2010a, p. 9).

(3) Programa de Conservación de la Vida Silvestre y Diversificación Productiva en el Sector Rural (Program for Wildlife Conservation and Productive Diversification of the Rural Sector) —Launched in 2000, this program defines the conceptual, strategic, legal and administrative framework that governs any initiative for the conservation and use of wild species (CITES 2010a, p. 8). The goal of this program is to establish incentives for private and public initiatives that favor natural resources conservation, as well as provide economic opportunities for private entities for the sustainable use of these resources (CONABIO 2005, Annex 3, pp. 2-3). Based on a biological evaluation of the species, this program promotes the use and conservation of priority species of plants and animals, including the establishment of wildlife production units and technical advisory committees such as the COMACROM (Subcomité Técnico Consultivo para la Conservación, Manejo y Aprovechamiento Sustentable de los Crocodylia en México; Technical Advisory Subcommittee for the Conservation, Management and Sustainable Use of the Crocodilians in Mexico) in the case of the Morelet's crocodile. Created by the Government of Mexico in 1999, COMACROM includes scientists, technicians, NGOs, producers, authorities and other

Subcomité Técnico Consultivo para la Conservación, Manejo y Aprovechamiento Sustentable de los Crocodylia en México; Technical Advisory Subcommittee for the Conservation, Management and Sustainable Use of the Crocodilians in Mexico) in the case of the Morelet's crocodile. Created by the Government of Mexico in 1999, COMACROM includes scientists, technicians, NGOs, producers, authorities and other

(4) Norma Oficial Mexicana NOM-059-SEMARNAT-2001 —Passed in 2001, this regulation provides legal protection to domestic endangered species of fauna and flora and provides a mechanism to evaluate extinction risks (CONABIO 2005, Annex 3, p. 3). The Método de Evaluación de Riesgo de Extinción de Especies Silvestres de México (MER; Method to Evaluate Wildlife Extinction Risks in Mexico), one of the parts of this regulation, has four categories of risk: Probably extinct in the wild, in peril, threatened, and subject to special protection. The Morelet's crocodile is included in the category “subject to special protection.” This regulation defines the category “subject to special protection” as “those species or populations that might find themselves threatened by factors that adversely affect their viability, thus determining the need to promote conservation or recovery and the recovery and conservation of associated species populations. (This category may include lower risk categories of the IUCN classification).”

Although the Government of Mexico no longer classifies the Morelet's crocodile as “Endangered” or “Threatened,” classification as “subject to special protection” under Mexican Official Law NOM-059-SEMARNAT-2001 allows legal protection at the national level (CITES 2010a, p. 9). Including the Morelet's crocodile in this category allows the Government of Mexico to make sure it still meets the conservation needs of important species from both a biologically and socio-economic standpoint before the species can be considered as threatened or endangered

otection” under Mexican Official Law NOM-059-SEMARNAT-2001 allows legal protection at the national level (CITES 2010a, p. 9). Including the Morelet's crocodile in this category allows the Government of Mexico to make sure it still meets the conservation needs of important species from both a biologically and socio-economic standpoint before the species can be considered as threatened or endangered. The petitioners recommended keeping the Morelet's crocodile in this category of “subject to special protection” to maintain existing measures of conservation, technical supervision, monitoring and enforcement in order to avoid the species' having a higher risk category in the future (CONABIO 2005, p. 4 and Annex 2, p. 5).

(5) Norma Oficial Mexicana NOM-126-SEMARNAT-2000 —Passed in 2000, this regulation oversees scientific research and collection by individual domestic and foreign researchers, as well as by institutions (CONABIO 2005, Annex 3, p. 3). If a species is also regulated under CITES, the appropriate permit or certificate must be obtained under this regulation. Scientific research or collections involving the Morelet's crocodile are regulated under these provisions.

(6) Sistema de Unidades de Manejo para la Conservación de la Vida Silvestre (SUMA; Wildlife Conservation Management and Administration Unit System) —In 1997, the Government of Mexico established a system for registering, supervising, and enforcing UMAs (Unidad de Manejo y Administración; Conservation Management and Administrative Units) for intensive reproduction of economically valuable natural resources, including captive farming of Morelet's crocodiles (CONABIO 2005, Annex 3, pp. 3-5). The goal of this regulation was to ensure that biodiversity conservation be considered within the context of the production and socioeconomic needs of the country. This system combined a broad range of entities or facilities (“units”) under a single administrative program, including zoological and botanical gardens, greenhouses, and animal breeding centers

codiles (CONABIO 2005, Annex 3, pp. 3-5). The goal of this regulation was to ensure that biodiversity conservation be considered within the context of the production and socioeconomic needs of the country. This system combined a broad range of entities or facilities (“units”) under a single administrative program, including zoological and botanical gardens, greenhouses, and animal breeding centers. Through these units, the Government of Mexico promotes natural resources uses that are responsible and planned. Extensive and intensive captive-breeding units for the Morelet's crocodile are covered under this system. In exchange for the right to harvest the Morelet's crocodile under controlled conditions, closed-cycle captive-breeding unit operators are required to develop and implement an approved management plan for the site, as well as to conserve the species' habitat and other species that use that habitat. Strict animal husbandry practices and welfare considerations are required under these plans.

Legal registration of approved UMAs requires proof of captive production beyond the F2 generation (CITES 2010a, p. 9). For intensive UMAs, such as captive-breeding operations in Mexico, the Government of Mexico requires the UMAs to submit regular reports that must include information on births and deaths, number and identification of traded specimens, and management activities (CITES 2010a, p. 10).

The Government of Mexico uses three methods to mark live Morelet's crocodiles registered with the Wildlife Division through the corresponding inventories of UMAs. The first method is interdigital staples on the feet. The second method is the traditional method of cutting notches in the tail scales and is only used by some operations (CITES 2010a, p. 10). These marks are registered with the Government of Mexico. The third method is the Universal Tagging System required by CITES for the export of skins (Resolution Conf. 11.12 (Rev

ponding inventories of UMAs. The first method is interdigital staples on the feet. The second method is the traditional method o

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