BEFORE THE SECRETARY OF THE INTERIOR Petition to List the Preble’s Meadow Jumping Mouse (Zapus hudsonius preblei) as a Distinct Population Segment under the Endangered Species Act November 9, 2017 Petitioners: Center for Biological Diversity Rocky Mountain Wild Acknowledgment: Conservation Intern Shane O’Neal substantially contributed to drafting of this petition. November 9, 2017 Mr. Ryan Zinke CC: Ms. Noreen Walsh Secretary of the Interior Mountain-Prairie Regional Director Department of the Interior U.S. Fish and Wildlife Service 18th and C Street, N.W. 134 Union Boulevard, Suite 650 Washington, D.C. 20240 Lakewood, CO 80228
[email protected] Dear Mr. Zinke, Pursuant to Section 4(b) of the Endangered Species Act (“ESA”), 16 U.S.C. §1533(b), Section 553(3) of the Administrative Procedures Act, 5 U.S.C. § 553(e), and 50 C.F.R. §424.14(a), the Center for Biological Diversity and Rocky Mountain Wild hereby formally petitions the Secretary of the Interior, through the United States Fish and Wildlife Service (“FWS”, “the Service”) to list the Preble’s meadow jumping mouse (Zapus hudsonius preblei) as a distinct population segment. Although the Preble’s meadow jumping mouse is already currently listed as a subspecies, this petition is necessary because of a petition seeking to de-list the Preble’s meadow jumping mouse (“jumping mouse”, “Preble’s”), filed by the Pacific Legal Foundation on behalf of their clients (PLF 2017), arguing that the jumping mouse no longer qualifies as a subspecies. Should FWS find this petition warrants further consideration (e.g. a positive 90-day finding), we are submitting this petition to ensure that the agency simultaneously considers listing the Preble’s as a distinct population segment of the meadow jumping mouse.