Comment on FR Doc # 2012-23747

Document ID: FWS-R8-ES-2012-0069-0007
Document Type: Public Submission
Agency: Fish And Wildlife Service
Received Date: October 05 2012, at 12:00 AM Eastern Daylight Time
Date Posted: October 5 2012, at 12:00 AM Eastern Standard Time
Comment Start Date: September 27 2012, at 12:00 AM Eastern Standard Time
Comment Due Date: November 26 2012, at 11:59 PM Eastern Standard Time
Tracking Number: 1jw-8187-et20
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The erroneous assumption regarding collectors made by the Spring Mts. USFS was that there is a huge trade in selling rare and endangered species and that P. shasta charlestonensis might bring in large amounts of money by someone collecting these butterflies. My guess would be maybe $5 to $15 for a good quality specimen,not $26,000 but the truth is few collectors collect for sale or are in the business. Few collectors buy what others catch. In reality, few collectors live in Nevada and about the only two locations in Nevada any current collectors visit to collect would be the Spring Mts. and the Lake Tahoe area. Out of state collectors would NOT know any conservation issues are going on in the Spring Mts. And since Austin's work (Austin, 1980, Journal of Research on the Lepidoptera...the Butterflies of Clark County, Nevada well defined the fauna in that Mountain Range, few would do research there and casual collecting for ones own collection does not require a permit...so collectors might understandably collect P. shasta charlestonensis if they ran into one if they are not informed of its current status and legalities. The writer of the proposal cites much literature claiming that collectors are threats to butterfly populations and cites several authors who make such assertions and claims. While there are a few poachers out there and collecting may hurt some localized sensitivel ow numbered populations, such occurrences have been very few and are rare. Negative views of collecting often come from publications which advocate watching over collecting and are then cited by other authors- see (Butterflies through Binoculars The West by Jeffrey Glassberg (2001). Such assertions are the views of that author and not the views of the scientific community. Collecting guidelines for the Lepidopterists' Society for the scientific community and collectors clearly prohibit collecting endangered or threatened species. Collecting is still required for research

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