Cloudcroft checkerspot listing

[Kondla, Norbert FOR:EX]

I recently read the Federal Register finding which was kindly posted on this
discussion group. Here are my observations:
- it is unclear what this has to do with the taxon proposed for listing but
the document alleges general overcollection of butterflies in the general
area. Q. Does anyone have any data to support this allegation ? Of course
some people would argue that any collection is overcollection but I am
curious about the data supporting the allegation and also what level of
collecting is used to distinguish between overcollecting and other
collecting in that part of the world. I note with curiosity that a closure
order on collecting was implemented due to "the threat of overcollection" Q.
So what has been going on here, was there overcollection or merely a
perceived threat.
-the document references possible effects of road reconstruction; I am not
familiar with the ecology of the Penstemon species used by cloudcrofti but I
am aware of two cases in western Canada where disturbance by road
construction has actually caused massive increase in the local Penstemon
species and likely corresponding increase in both E. anicia helvia and E.
chalcedona paradoxa as a result ( I note that I do not have predisturbance
data for comparison but when butterflies are swarming around larval food
plants that are unnaturally abundant, one can suspect a cause and effect
relationship)
-the document points out that specimens of other subspecies of E. anicia (a
common and widespread taxon in western North America) have been offered for
sale. Q. So what and what does this have to do with the status of
cloudcrofti; is there any data to suggest that cloudcrofti is threatened by
commercial collecting ??
-the document speculates about likely high interest in the taxon and
apparent low numbers. Q. where is the data for this speculation; have any
population estimates been made during the normal natural population
fluctuations that occur over time ??
-the document drones on about high prices for prized species, Q. So what,
has anyone actually ever bought or sold even a single cloudcrofti specimen
for a 'high price'
-has anyone done any surveys to find out what the actual distribution of
cloudcrofti actually is ? or will a listing decision be made on the skimpy
information in the said document with its very curious commentary about
collecting and collectors. I honestly hope that a decision will be made on
much better data and less biased verbiage than what appears in the federal
register. Flame away if you disagree- but if this were brought to me for
either signature or statutory decision; I would laugh the authors out of the
room and suggest they come back with an objective assessment based on data..
~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~
Norbert Kondla  P.Biol., RPBio.
Forest Ecosystem Specialist, Ministry of Environment
845 Columbia Avenue, Castlegar, British Columbia V1N 1H3
Phone 250-365-8610
Mailto:Norbert.Kondla at gems3.gov.bc.ca
http://www.env.gov.bc.ca