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| Photo of the upper side of a female silverspot butterfly with distinctive crème spots. Credit: Robb Hannawacker. |
Mesa County Commissioners approved a letter to the United States Fish and Wildlife Service (USFWS) regarding the proposed listing of a subspecies of the Silverspot Butterfly.
USFWS proposes to list a subspecies of butterfly (Speyeria Nokomis Nokomis ), a silverspot butterfly from Colorado, New Mexico, and Utah, as a threatened species under the Endangered Species Act of 1973, as amended (Act), with a rule issued under section 4(d) of the Endangered Species Act.
The letter states:
“Mesa County is not in support of listing the Silverspot Butterfly under the Endangered Species Act (“ESA”), particularly when it appears that there are management practices that may benefit the species yet to be implemented. Further, timely, comprehensive studies verifying current populations, reasons for decline, and what a recovered species looks like, appear to be lacking.
According to the Federal Register Notice, published on May 4, 20221 and the Species Status Assessment Report for Speyeria nokomis Nokomis (February, 2010, Version 1.0) (“SSA”) 2, of the twelve reasons identified as “Factors Influencing Species Viability”, several are not considered a “detectable factor in reduction of species viability” or are unknown to be the cause of species or habitat decline. Additionally, two of the factors, prescribed burning or wildfire and grazing, are identified as being potentially beneficial to the Silverspot Butterfly under certain management conditions. Without a thorough understating of what is causing a presumed decline of the species, it will be nearly impossible to develop a viable recovery plan.
While one extant population is identified in Mesa County, the species range shown in Figure 14 in the SSA, uses a broad-brush stroke covering a large portion of western Colorado.3 Mesa County requests that additional species surveys be conducted to better define the habit within Mesa County to ensure that, in the event habitat is proposed in the future, property owners and public land managers are not subject to unnecessary regulatory burden in areas not suitable for the species.
Before moving forward with an ESA listing, implementation of a proactive conservation and education program, in close cooperation with private landowners, federal land managers, and lessees may result in greater habitat savings and a more timely recovery of current populations. We would appreciate this approach prior to any final determination is issued.
Thank you for the opportunity to comment on the Proposed Rule for the listing of the Silverspot Butterfly. We reserve the opportunity to comment further, should additional information or habitat mapping become available.”
