John Shuey jshuey at TNC.ORG
Thu Jan 31 08:39:01 EST 2002

> Bob, Anne, Neil et al.
> It is really amazing to see how you folks have put together a dedicated
> group to work with Miami Blues, and done it so quickly.  I wish you great
> success.  Do you have anyone in an advisory position with your group who
> has previously worked on the restoration of a federally endangered species
> of Lepidoptera in the U.S.?  I don't ask this to minimize the talents of
> your group but to alert you to some of the restrictions your project will
> face if you ARE successful at getting the species listed as federally
> endangered and proceed with your recovery plan.  And no I'm not available;
> I have my pro bono hands full attempting to deal with state listed leps in
> a single, northern state.
> I suggest you contact the Toledo Zoo and talk to them about what
> it took to
> get the federally endangered Karner Blue butterfly successfully
> reintroduced into Ohio.  I recently saw an excellent presentation on this
> project by zoo personnel at the Winter meeting of the Ohio Lepidopterists
> society.  A scientific group which, by the way, welcomes everyone with an
> interest in moths and butterflies be they collector, photographer
> or watcher.

To add a little to this - the worry I have is you guys are way out in front
of the process.  The Miami Blue is probably going to be listed as federally
endangered.  Then the FEDERAL RECOVERY TEAM - (not you guys although you
might have members on the team) will decide what is required to recover this
species.  Then, once a prioritized list of recovery activities is in place,
things start to get approved (for Federal permits and potential Section 6
funding).  The fastest I've personally seen this happen is about two years
from listing to draft recovery plan development. The Karner Blue plan is at
least 7 years in the making.

That is not to say things can't happen without a recovery plan - look at the
Karner Blue.  Captive rearing in three states, re-introductions, habitat
restoration, etc...  But things happen a lot easier if there is a "trusted
consensus" for the US-FWS to buy into that drives these activities.  (and
for the Karner, most of the ongoing activity has long been part of the early
drafts of the recovery plan).

Permits can be pretty easy to obtain if you have institutional backing and
support that understands the process - and a point person who has the
credibility to hold the actual permit.  In my mind this translates to an
institution with a proven track record relative to imperiled species
conservation, the legal wherewithal to meet the permit obligations, and a
lead "scientist" who is a recognized expert at handling the species in
question or a similar species. The easiest way to "build" the science expert
is to try and get the best candidate you have on the Federal Recovery Team -
so that every one can get comfortable with them (remember this can back-fire
if your expert is not that swift).  (And again, this takes some time).  If
you don't have these elements in place - then permits are pretty much
impossible to obtain.

And if the butterfly is state listed (and if Florida DNR actually has legal
authority) then there is an entire parallel set of hoops to jump though -
and they may or may not issue a permit even if the Feds do!  (these issues
help define my attitude that "you should never piss anyone off too much - or
a least if you have to do it, do it for a good cause" - you never know who
is going to hold your future -  things like funding, permits, access to work
on state land .... - in their hands )

Despite all this doom and gloom - I really wish you good luck.  You'll do
better if you have your eyes fully open.


John A. Shuey
Director of Conservation Science
Indiana Office of The Nature Conservancy
1505 N Delaware Street, Indianapolis, IN 46202

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