NABA Turns Fish and Wildlife into Brainless Zombies

Fresh off the presses, the Miami Blue Butterfly (MBB) is now listed as federally endangered by act of an emergency provision.  Huzzah!  (right?)

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Miami Blue Butterfly from Butterflies of America

My first thought was “wait, wasn’t this already endangered?”.  Yes, turns out the MBB has been state-endangered since 2002 after a previous emergency petition filed by the North American Butterfly Association (NABA).  This measure seemed comprehensive enough since this butterfly occurs nowhere else in the USA.  But that’s not an important detail and I don’t see any real harm in federally listing another butterfly.  The Florida Keys sure need every ounce of help they can get when it comes to protecting the environment.

As an endangered species the Miami Blue (Cyclargus thomasi bethunebakeri) is a northern range extension of a species that commonly occurs throughout the Caribbean.  Whether or not the US immigrant is truly distinctive enough to warrant a subspecies of its own is not something I can really address since I’m not a butterfly guy in the least.  I do greatly shy away from the entire idea of a subspecies, but hey, I guess these butterfly guys need something to do!  It also seems logical to me that influxes of emigrating blues would naturally change in abundance over the southern coast of Florida.  In the early 1950’s these insects used to be abundant up and down beaches nearly all over the state.  The last 60 odd years have been cruel to Florida – development and mosquito abatement has ravaged what used to be pristine habitat.  All of the butterflies are suffering.

Then I realized there was something very odd about this announcement: the emergency provision is also listing all similar blues that share habitat with the MBB as threatened and therefore protected!  Why?  Because they look like the MBB.  These blues include the Cassius blue (Leptotes cassius), Ceraunus blue (Hemiargus ceraunus), and the Nickerbean blue (Cyclargus ammon).  Let’s get one thing straight – both the Cassius and Ceraunus blues are not in any way actually threatened nor even rare.  They can both be – incredibly abundant species with a range that spans all of the Carribbean, the gulf coast west to California and inland strays to the midwest!

So I ask, how could this have passed?

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Gary Larson, The Far Side

Oh that’s right – fear mongering brought to you by the radically anti-collecting North America Butterfly Association.  NABA perceives collecting as one of the gravest dangers to butterfly populations despite the incredible lack of evidence.  Yes, every collector out there is sporting an evil black cape and making it their life’s work to extinguish beauty from the world.  Somehow this organization has managed to convince the USFWS they have a point.  I can’t do this provision justice, so here is the exact quote.

In addition, the Service is issuing a 4(d) special rule on these species to establish prohibitions on collection and commercial trade within the United States. This action also prohibits the import into, and export from, the United States of the three similar butterflies. Otherwise lawful activities that may impact these similar butterflies—such as legal use of pesticides, mowing, and vehicle use—are not prohibited. Extending the prohibitions of collection, possession, and trade to the three similar butterflies will provide greater protection to the Miami blue.


I’m honestly speechless.  Well, maybe I can manage a few more words.

Go ahead and mow down your patch of habitat and then spray herbicide on it.  But you better not dare to collect a single blue… the USFWS is watching.

They also turn out to be rather paranoid.  Sure, poaching does happen every once in a while no matter what species you protect.  Whether it be for profit or food, a few odd animals will be picked off.  But is there any real evidence to support this level of craziness?  The majority of citations in the registrar are from cases, not peer-reviewed journals.

the Service has determined that designation of critical habitat for the Miami blue butterfly is not prudent because publishing maps and descriptions of critical habitat areas would widely announce the exact location of the butterfly to poachers, collectors, and vandals and may further facilitate disturbance and destruction of the butterfly’s habitat.

Oh I do love quotes: (source)

but also indicates that there is no evidence or information on current or past collection pressure on the Miami blue (FWC 2010, p. 13)… Although we do not have evidence of illegal collection of the Miami blue, we do have evidence of illegal collection of other butterflies from Federal lands in south Florida …

…The same Web site offers specimens of two other butterflies similar in appearance to the Miami blue; the ceraunus blue currently sells for €4.00 ($5.57), and the cassius blue is available for €2.50-10.00 ($3.48-$13.93).

… Therefore, it is quite possible that collectors authorized to collect similar species may inadvertently (or purposefully) collect the Miami blue butterfly thinking it was, or planning to claim they thought it was, the cassius blue, nickerbean blue, or ceraunus blue


Don’t get me wrong – additional funding and protection for a rare species might be helpful as long as the habitat is safeguarded.  It seems however that the vast majority of funds tend to go into captive breeding programs which doubtfully do much good.  If the butterfly is vanishing from the islands then releasing clouds of them will only make for pretty photographs and not a saved species.

I will be submitting a solicited comment and I suggest you do the same. Comment here before October 11, 2011: Federal eRulemaking Portal: Follow the instructions for submitting comments to Docket No. [FWS–R4–ES–2011–0043].  Or write to: U.S. mail or hand-delivery: Public Comments Processing, Attn: Docket No. [FWS–R4–ES–2011–0043]; Division of Policy and Directives Management; U.S. Fish and Wildlife Service; 4401 N. Fairfax Drive, MS 2042–PDM; Arlington, VA 22203..

9 comments to NABA Turns Fish and Wildlife into Brainless Zombies

  • Dear Mr. Grinter,

    As a scientist, I’m sure that you normally look for supporting data before making statements. You state that the North American Butterfly Association is radically anti-collecting. This statement is untrue. If you look at the 20 years of NABA publications, you will see almost no mention of collecting at all! NABA, and everyone in a leadership position with NABA, has absolutely no problem with collecting butterflies for a scientific purpose.  I was a professional scientist (as were a number of the other people in leadership positions at NABA), working at Stanford University Medical School and at Rockefeller University.  I am certainly all for scientific inquiry!  In addition NABA’s Scientific Advisory Board, consisting of Nat Holland (Rice University), Naomi Pierce (Harvard University), Robert Robbins (U.S. National Museum), Ron Rutowski (Arizona State University), John Shuey (The Nature Conservancy) and Ernest Williams (Hamilton College), includes some of the foremost scientists in the United States who work with butterflies.

    What NABA does do, in addition to encouraging scientific research some of which is published in American Butterflies,) is to encourage people who are not scientists (which is almost everybody) to approach butterflies with binoculars and cameras.  This emphasis on binoculars and cameras has resulted in a tremendous increase in the number of people who are seriously interested in butterflies and this has resulted in an increase of our knowledge of butterflies and, most importantly, in an increase in our ability to conserve butterflies.

    Regarding Miami Blues, it was not NABA who asked the USFWS to also list Ceraunus and Cassius Blues. And neither I, nor anyone at NABA, have said, nor believe, that the largest threats to butterfly populations is collectors.


    Jeffrey Glassberg, Ph.D.
    President: NABA

    • Dr. Glassberg – Thank you for taking the time to reply to my comment and provide some tempering to my opinion. While I did not directly state that NABA had asked the USFWS to list the Ceraunus and Cassius blues, I can understand how that point might be misconstrued. How they arrived on the register is a mystery to me, and I am doubly perplexed by the decision to protect these common and wide ranging species even when FWS themselves state “there is no evidence”.

      In regards to NABA I do believe you are technically correct. The organization has never officially printed or demanded any anti-collecting sentiment. Anecdotally I can say that I have occasionally come across NABA watchers who have vehemently chased me from habitat from which I was legally collecting butterflies. Naturally I know many more collecting-friendly watchers than hostile watchers, but it is just a brief anecdote that has aroused my suspicions.

      Since you are the president of the association and have printed books endorsed by NABA and yourself as the president of NABA I will take your opinion as the official stance of NABA. Going directly to your Butterflies through Binoculars the East you state: “Even when collection pressure doesn’t result outright in the demise of a rare colonial butterfly, each individual killed results in the depletion of the gene pool, and this loss of genetic diversity becomes more important as the colony becomes smaller.” Aside from being factually misleading, this statement is preceded by reports of collectors wiping out the Mitchell’s Satyr (which is still not extinct). I see this as a very anti-science and anti-collecting agenda. The book continues on with vast generalizations regarding taxonomy and the Linnaean nomenclature system, none of which help support your “raison d’être” of conversation.

      I know I grew up collecting butterflies and it helped me grow into a naturalist and scientist. While watching is a great activity, I do not see evidence for the support of science by NABA.

      The most convincing evidence however might be especially relevant and poignant here. Your 2001 editorial in American Butterflies (a NABA publication) brags about your leverage of sensitive habitat localities of the Miami Blue over FWS in an attempt to force their hand in protection

      “Last summer, NABA petitioned the U.S. Fish and Wildlife Service to list Miami Blues as federally endangered on an emergency basis. We decided to keep the location of the colony secret until listing could provide some protection. While I understand that the petition was favorably received, the Department of Interior subsequently issued a moratorium on all listings and it is unclear when, if ever, this species will be protected. So, I have decided to make the location of the colony public. I hope that Secretary of the Interior Norton acts to list this species and that Florida legislators enact laws that provide real protection, before it too late, but I am not optimistic. So, my advice to you is to see these butterflies, at the northern end of Bahia Honda State Park, along Silver Palms Nature Trail, while you still can. But please don’t tell anyone else.”

  • Chris, I’ve read through this a couple times now and I’m still not sure why you’re so up in arms about the federal listing. I see it as a legal maneuver to go after the poachers, especially on an international level. I have visions of comparisons to how mob bosses are nabbed for tax evasion rather than murders of which there is no evidence. Did you see the prices some butterflies fetch? The irony is that listing will probably increase the black market value of the butterflies and those won’t be shown on websites. I may be mistaken, but if collecting is for scientific purposes, permits can still be issued for endangered species.

    As for NABA, I always thought their main goal was promoting awareness and conservation of butterflies; there are other organizations that focus on the scientific aspects, like the Lepidopterists’ Society. To that end, Jeffrey and his BtB books, particularly his 1993 first edition, have done a good job at making butterflies more accessible to the general public. Before Peterson came out with his bird guide, enthusiasts shot and stuffed birds just to identify them. That’s unthinkable today and look how popular (and lucrative) birding has become. Collecting will always have a place in the scientific world, but I’d like to believe there’s a growing culture of naturalists who don’t have to kill or collect in order to appreciate and be well-informed.

    Too bad about your experience with NABA members. There are always freaks associated with any organization. I refuse to associate myself with my town’s monarch group, because a few vocal individuals, while good-intentioned, often get emotionally accusatory based on misinformation they’ve picked up. You know there’s a $1000 fine if you’re caught molesting a monarch here? I’ve joked that the city could make a lot of money when tagging is done every year.

    • The topic bothers me because there simply isn’t a real poaching problem and collectors are being vilified for no reason whatsoever. The FWS say themselves there is no evidence to support the idea that poaching is a problem for the Miami Blue. It has been state endangered since 2002 and not one poacher has been seen. Anecdotally I have never even heard of someone catching or wanting to catch a Miami Blue. I am also a tiny bit bothered by your comparison of butterfly collectors to mob bosses. 99% of the fear of butterfly collectors is fear mongering with zero evidence to support it. The fact is, there has never been an instance of a collector making a butterfly extinct. If you drive a car – you will kill orders magnitude more butterflies every year than you could possibly dream of catching with a net.

      Of course there is a sizable trade in butterflies, Papilio and Ornithoptera in particular fetch these obscene prices and I’ve even blogged about it before. But those prices do not reflect the rarity of a species, but often only of a specimen – they are usually natural hybrids, gynandromorphs or color aberrations that are nothing that can nor should be protected. There are still butterflies that fetch hundreds or even a few thousand dollars, but this is due to the difficult to catch in the wild (either on a mountain top or in a war-zone). You also have to understand that there is no real trade in the Lycaenidae (blues). There is no international pressure to poach these blues out of existence – this is why no collector has ever been caught trying to do so. The Scahus’s Swallowtail however would have an international market – but even FWS can only come up with one example of poaching.

      There are always one or two bad apples and I have no qualms against making a species endangered and collecting illegal. But protecting “similar” species that honestly look nothing like the MBB to save it from collecting is absurd. A poacher “claiming” to catch a common blue that has a Miami blue in their net could have been prosecuted before this similarity law. It’s very easy to tell these species apart in the field. The butterfly collecting community is small in the first place, and the number of the people who are breaking the laws to collect is a tiny fraction of this community. There may be 10 people in the US who poach butterflies – do we really need to legislate against them?

      The most important thing here is that insects are not birds – the population dynamics are so vastly different that laws governing them in the same manner are absurd. Insects have vastly larger populations, lay orders of magnitude more eggs, and live for only a few weeks of the year. When you net a male butterfly in the field 9 times out of 10 he has already mated with one or more females. A female butterfly has deposited most of her eggs by time she is caught on the wing. I often catch females hoping for eggs and only get a handful if any of the many dozens she has already laid in nature.

      Collecting plays an important role in butterfly education and identification beyond the scientific realm. For many species you can not accurately identify them without collecting a series of specimens of both sexes. I see no point in butterfly lists that watchers generate since many of their identifications are likely to be inaccurate and there is no method for fact checking (if you’re a birder you know the problems with false ID’s). Even a good photograph can only be identified with 100% accuracy 3/4 of the time.

      I never want to be part of a state in which school children are not allowed to collect butterflies – and now kids in Florida can’t catch the abundant blues that are on every flower in their back yard. The vast majority of insect collections in museums are not made by research scientists, but by hobbyists. I grew up collecting butterflies because it was fun, not because I was a 10 year old researcher. My hobby developed into a passion, a career and into science. I don’t have a problem with watching, I think it’s great, and I think NABA has managed to raise “awareness”. However I fail to see how conservation can be achieved when it is not based in science. People are being mislead into thinking non-scientific collecting (and all collecting) is evil and it is doing the entire scientific community a disservice.

  • Now, that is a better argument than your post, Chris. Haha, I’m sorry I mentioned mob bosses. My point was that there are crimes that are near impossible to find evidence, but that doesn’t mean it doesn’t happen. What prosecutors have done is go after something that can be caught, like tax evasion or in this case obvious commercial trade of similarly looking butterflies. At the very least they’re now armed with a law that can allow them to collect evidence. I think there’s more to the story of why USFWS (not NABA) enacted the emergency listing that’s not obvious. And I’m certain it’s not to vilify collectors like you or school children.

    I had a collection as a kid and it consisted of mostly cabbage whites and grasshoppers. I ended up publishing a study that collected half a million moth specimens over the course of 10 years and curated a museum collection that consisted mostly of private donations. I also know a couple people who have turned entire bedrooms or utility rooms in their homes to house their collections. I hope they will eventually leave their collections at institutions that will preserve their efforts. There is tremendous value in collecting, if properly documented and cared for.

    With that said, the majority of people out there do not get into collecting or science. They simply don’t have the patience or interest. Here’s where I think NABA has played an important role in increasing awareness of an animal that many people simply never notice. Not everyone is like you, Chris. I see public interest and education as the main point of butterfly counts, not necessarily accurate identifications. Although, many species can be statistically evaluated over the long-term from these annual counts. Get the public interested in the diversity of pretty butterflies, then they’re more inclined to see the value in protecting habitats, not to mention donating money to institutions that support jobs like the one you have and I have had. Here, too, is value in simply watching butterflies. Be careful of biting the hand that feeds you.

    • I still fail to see how this is like going for tax evasion or how it helps to gather more evidence – either a miami blue is poached or not (and I’m not arguing against the possibility of this happening). I see this more like changing the law to make impersonating Marlon Brando equal to murder just so you can go after the mob bosses. They can’t find anyone poaching therefore they make collecting a common and abundant species illegal – shazam – now you can find more evidence because you just created it. Go figure.

      NABA didn’t and couldn’t enact any laws of course, but they did petition for the listing of the Miami Blue, both in 2000 and 2010 (their petition resulted in this declaration). Nowhere in the records have I found the request to include the other species, but there is no denying that NABA is an anti-collecting organization that has direct ties to this new law… perhaps they just planted the seed.

      I’m all about public education but just not at the expense of science. I know almost no one has the time nor will ever care enough to become a citizen-scientist. But NABA is on one hand generating public awareness and participation which is great – but on the other hand making it much harder for scientists to actually do their job (getting chased out of habitat). Just think about grad students/PI’s working with blues in Florida now have to go through the ESA which is a true nightmare – a bureaucratic road block that even NABA had a really hard time fighting through (or heck anyone working on ANY insect in florida could now face the ESA because their project might impact the habitat of this ABUNDANT and widespread species that literally occurs everywhere).

      I would be a full supporter of NABA if they didn’t foster an anti-collecting environment – heck I have even participated in NABA butterfly counts (with a net though).

      A program that I do fully support is the Lepidopterists’ Society “Outernet Project” – with the goal of putting nets in kids hands.

  • The real endangered species here is the butterfly collector. I do not have a problem with people taking photographs of butterflies. NABA and the Lepidopterist Society both share a common interest and appreciation of the subject with perhaps different objectives. Habitat distruction, wide spread use of pesticides, herbicides and the whole sale plantings of vineyards here in California and habitat loss due to urbanization in Florida have played a far greater role in the demise of all butterfly populations then a billion butterfly poachers could have. I myself was embroiled in a famous case entitled Crimes of Passion and was labled a butterfly poacher by the United States Fish and Wildlife Service. For the record, most Ornithoptera or birdwing butterflies are rather common but have had blanket protection due to the U.S.F.W.S. lack of expertise seperating common species from rare or endangered ones which would also apply to the three species of blues in Florida. Another case is the Apollo butterfly which has as wide a range of distribution from Norway to Mongolia south to Spain and Turkey being included in C.I.T.E.S. Another flaw with the endangered species act while well intended is actually missapplied to sub species. American museums are poorer institutions because exchanging butterflies is considered a comerical venture as something of value is received for something sent or offered. While you ponder why you see fewer butterflies each year or the fact that tropical rain forest decrease by the year, please enjoy your wine !

  • PFC Joseph Eguizabal

    I feel that we as lep collectors seem to take the blame for bugs going extinct, yet the law enforcement groups don’t go after developers that want to change good habitat into strip malls or parking lots. But a guy waving a net is the enemy? Right. I was in Afghanistan and I have seen some very good places to collect Parnassius and other leps. Hell, I’ve been on patrol in them and have seen some nice stuff flying around. I could of caught a couple if I wanted to, but there are ambushes, mines, and IED’s waiting in many areas there. Now, if there is someone who really wants an A1 Parnassius chaltonius or meutingi, and isn’t scared to get killed, captured, tortured, or blown up, then they can go there and collect these “rare” bugs. At the same time, now I’m home and have plans to go enjoy my hobby and have a couple of projects to do, and the last thing I want to deal with is some people trying to stop me from catching bugs. I had this happen before deployment in a park in central tennessee, where there was a couple that decided that I was a poacher for collecting zebra swallowtails, Tiger swallowtails, and some common nymphalids, went to the ranger and tried to get me kicked out of the park. Luckily the ranger knew that I was collecting, and that I have a permit that year to collect in state parks. I just hope I don’t have people try to stop me this year.

  • You state that no butterfly has ever been collected to extinction. However, there is a well known example from the UK where it was a day-flying moth. The New Forest Burnet moth had an unique subsepeies in the New Forest which created as a “New” hunting forest by King William I who came to the throne in 1066. The moth had its exctinction predicted by the collectors of the day in the 1920s . There was heavy commercial collecting with collectors patrolling the sites looking for newly emerged adults. It duly became extinct.

    Furthermore, it is basic science that predation affects populations. So it is therefroe reasonable that we should prevent predation of endangered species. We do know from the research that it is possible to collect most of the specimens of a butterfly from small colonies easily.
    Here is one of several examples from the literature

    The following is an excerpt from a published paper. The Ecology and Conservation of the Heath Fritillary Butterfly, Mellicta athalia. II. Adult
    Population Structure and Mobility by M. S. Warren Journal of Applied Ecology, Vol. 24, No. 2 (Aug., 1987), pp. 483-498

    “The possible impact of collectors on M. athalia populations

    Several authors (e.g. Frohawk 1934) have suggested that over-collecting may have led to the decline of M. athalia in some areas, but they produce little evidence to support this. The possible impact of collectors can be examined by calculating the proportion of the adult population caught in one day of intensive catching (i.e. the maximum collectable proportion) during the mark-recapture experiments. The results, plotted on Fig. 8, show that the proportion caught was closely related to the population size itself and ranged from 4 to 94%”

    If you can collect 94% of the butterflies in a colony you can certainly drive it to extinction.