The “butterfly metaphor” describes the need for people and organizations to change their ways, thinking differently about the way things have always been. It is fitting in the halls of government, where the status quo is paramount, and pundits joke about the seven words bureaucrats shouldn’t say: “We’ve never done it that way before.”
The butterfly represents the ultimate transformation, with its mysterious metamorphosis from ugly caterpillar, to what Robert Heinlein described as “self-propelled flowers.” Some people are said to be caterpillars, pleased with the status quo. Others are in a cocoon, sheltered and afraid to fly away. When it comes to the Endangered Species Act, federal officials can be both.
The metaphor seems apt, in light of a proposal by the U.S. Fish and Wildlife Service (USFWS) to add one of nature’s most beautiful butterflies to the endangered species list. Known as the Silverspot butterfly, its scientific name is Speyeria nokomis. It only lives at high elevations, from about 5,200 to 8,300 feet, but to be careful the USFWS assumes the butterfly’s elevational range between 5,000 and 8,500 feet – adding thousands of square miles of potential designated habitat.
Still, that should not distress most western cities and towns that bare at lower elevations, except for one thing – the posted map of the butterfly’s range includes a gigantic swath from southeast of Santa Fe, north to Meeker and west to Thompson Springs, Utah – including lower elevation cities like Grand Junction and Montrose. It covers the Santa Fe, Carson, San Juan, Rio Grande, Uncompahgre, Gunnison, Grand Mesa, White River, and Manti-La Salle National Forests, including thousands of square miles where no Silverspots live.
This listing proposal stems from several lawsuits filed by the Center for Biological Diversity, demanding the agency make decisions on nearly 800 species that groups had petitioned the government to list, and/or designate critical habitat. Although the federal process is sluggish (the largest lawsuit was settled in 2011), the decision to list more species was never really in doubt.
Sadly, that’s how the endangered species process has always worked. Although groups filing such lawsuits see new listings as a victory, they are actually a defeat. We should look at every new addition to the endangered list as a failure. Listing is an acknowledgment that a species is in danger of extinction, and actually slows their recovery. In the 45-year history of the federal list, fewer than three percent of the 2,369 listed species have ever been recovered and delisted.
In practice, the process for listing a species is fairly simple. Groups file petitions seeking to add species, and in due course, USFWS almost routinely adds them. If it fails to do so, petitioning groups often file lawsuits, whereupon federal judges frequently order the listing anyway. The agency has simply found it easier to list a species than not to do so. Somewhat oversimplified, this is how the process has evolved. Court orders now dictate such a high percentage of USFWS’s activities that it has very little discretion over its own budget and priorities. The agency loses many cases because of missing legal deadlines, a habit officials routinely blame on chronic underfunding.
Unlike many listed species, we actually know a great deal about Silverspot butterflies, thanks to dozens of excellent researchers and lepidopterists. The new listing proposal is based largely on a “Species status assessment report for Speyeria nokomis Nokomis,” written by the Grand Junction field office of USFWS. It’s a well-written and carefully documented 80-page paper for anyone who wants to learn more.
The report identifies reasons for the Silverspot butterfly’s decline, mostly human activity: residential and agricultural development, habitat fragmentation, grazing, fires, pesticides and (predictably) climate change. It does not identify genetic mixing between subspecies, though that is well-documented in this species. Ironically, grazing and fire are also possibly helpful to Silverspot habitat, so the agency may decide later exactly what to regulate – probably after critical habitat is already designated and the time for public comment expired.
That’s unfortunate, because every new species listing is an opportunity for a different approach, a chance to eschew regulation and pursue an incentive-based program to recover the species, in cooperation with landowners and local governments. But, as any USFWS employee could answer, “we’ve never done it that way before.” That would require giving up command-and-control, the only approach the endangered species process has ever known.
In “Hope for the Flowers,” Trina Paulus wrote of a caterpillar who asks, “How does one become a butterfly?” Another answers, “You must want to fly so much that you are willing to give up being a caterpillar.”
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