Ram Realty’s “Technical and Legal Submittal” and “Supplemental Response” to the Miami Tiger Beetle Emergency Listing Petition

In response to a December 11, 2014 emergency listing petition to protect the Miami tiger beetle (Cicindela floridana) filed by the Center for Biological Diversity, advocacy groups, and several individuals (myself included), Ram Realty retained the law firm Gunster, “Florida’s Law Firm for Business,” to craft their reply to the U.S. Fish and Wildlife Service (USFWS).

Luna E. Phillips is a “Florida Bar board certified Gunster shareholder who practices in the area of environmental, administrative and governmental law [and] leads the firm’s Environmental practice” (from Gunster’s website) wrote and submitted two responses to USFWS totaling some 7,500 words! However, in both of these documents there are serious systematic errors and fatal misunderstandings or, even worse, flagrant misrepresentation of the science. Below I’ve reproduced both of Ram’s filings in red and my comments in black.

Technical and Legal Submittal regarding the December 11, 2014 Emergency Listing Petition Filed by the Center for Biological Diversity, et al:

January 14, 2015

Dear Ms. Blackford:

As you know, this firm represents Coral Reef Retail LLC and Coral Reef Resi Ph I LLC, the owners of the Coral Reef Commons property (Coral Reef Owners). Enclosed is a Technical and Legal Submittal regarding the December 11, 2014 Emergency Listing Petition filed by the Center for Biological Diversity, et al. This Technical and Legal Submittal identifies the flaws in the emergency petition, and the Coral Reef Owners urge the US. Fish and Wildlife Service to carefully review before making a determination on the emergency petition.

The Coral Reef Owners respectfully request that this Technical and Legal Submittal be added to the administrative record for the Miami tiger beetle potential listing, and should the Service make any determinations on the emergency petition, Coral Reef Owners request to be notified. Please do not hesitate to contact me at or via email if you have any questions regarding the content of this letter.

Sincerely,

[Signed]

Luna E. Phillips

cc: Vicki Mott, US. Department of the Interior

Client [Ram Realty]

Rafe Petersen, Holland & Knight

Church Roberts, Johnson Engineering, Inc.

INTRODUCTION

On December 11, 2014, the United States Fish and Wildlife Service (USFWS) received an emergency petition under Section 4 of the Endangered Species Act (ESA) to list the Miami Tiger Beetle (MTB) as threatened or endangered (hereinafter, the Petition). The Petition was filed by several environmental advocacy groups and individuals that oppose development projects in the south Florida pine rocklands. The Petition alleges that the MTB should be listed on an emergency basis under the unsupported theory that the MTB is imminently threatened by destruction from the construction and operation of a mixed-use shopping mall” and potential development of a theme park. Based on this theory, the Petition requests that USFWS immediately list the MTB as endangered and designate critical habitat for the species. The Petition should be rejected as a thinly-veiled attempt to coerce USFWS into shutting down development in South Miami-Dade. The limited purpose of the emergency listing provision of the ESA is to prevent species from becoming extinct by affording them immediate protection while the normal rulemaking procedures are undertaken. The Petition fails to meet the necessary minimum criteria required under the ESA to warrant the extraordinary action of an emergency listing, There is no significant, immediate threat to the MTB — neither project cited in the Petition is imminent and the MTB is not on the brink of extinction. Furthermore, the MTB does not meet the criteria of a

[Footnote 1] The Petition refers to the Miami tiger beetle (Cicindela floridana). As outlined in this Technical and Legal Submittal, these are invalid names. However, for ease of reference, this submittal will refer to the beetle as the Miami tiger beetle (MTB). (Ram’s assertion that the MTB = an invalid species is woefully incorrect; please see my extensive reply below)

“species” and the Petition is based on faulty science and unsupported conclusions. We address the serious and extensive flaws contained in the Petition in this comment letter, We respectfully request that USFWS add this comment letter to the administrative record associated with the Petition; thoroughly address the issues raised in this comment letter before making any decision; and reject the Emergency Petition request for its failure to provide a sufficient basis for an emergency listing.

I’ll touch on Ram’s claims further into this post but I feel it is important to recognize one fact at the outset: Ram is pushing to develop a site which includes significant areas (almost 50% of the property) of pine rocklands, a habitat which once covered an estimated 127,000 acres in Florida. Due to extensive habitat destruction only 2,273 acres (1.8%) of pine rockalnds exist today outside the Everglades National Park. This remaining acreage is severely fragmented  into parcels of drastically varying size “…from 0.25 acres to 800 acres, with a mean size of 15.6 acres and a median size of 4.3 acres” (URS Corporation et al. 2007). Pine rocklands are now critically endangered and of the many species which dwell in this habitat face extinction.

EXECUTIVE SUMMARY OF CONCERNS AND FLAWS WITH THE EMERGENCY PETITION

The Petition fails to provide sufficient information to warrant the extraordinary relief of an emergency listing. The best available Science and information demonstrates that there is no significant risk to the species and that the MTB would not qualify for listing as threatened or endangered under Section 4 of the ESA. The routine listing process is sufficient for purposes of considering the status of the MTB.

1. The USFWS may bypass the normal listing procedures only where there is a significant risk to the well-being of a species. Very little science has been developed or is known regarding population, habitat, or species identification to support a conclusion that the MTB is imperiled to the point of jeopardy or extinction.

The Miami tiger beetle was rediscovered in 2007 and described as a full species in 2011. Consequently, while we do not have decades of research on the MTB, the best available science provides sufficient information for the pressing concerns outlined in our petition.

Ram’s lawyer is clearly unaware of the present state of the science. The USFWS has commissioned numerous population surveys since 2008 (Knisley 2011, Knisley and Wirth 2013), which document significant fluctuation in the number of adult and larval MTBs. The Miami tiger beetle has only been found in pine rocklands habitats; both today and the original collection site. Frighteningly, the area of pine rocklands outside the Everglades National Park (ENP) have declined by >98%. Again Ram’s assertion that the MTB species identification is in question is false; please see my extensive reply below.

2. The two projects cited in the Petition, Coral Reef Commons (CRC.) and Miami Wilds, do not pose an immediate threat to the MTB. The CRC projects local approvals have been suspended by Miami-Dade County pending the owners receipt of approval of a Habitat Conservation Plan under Section 10 of the ESA. That project will result in a net gain in pine rocklands habitat function. The Miami Wilds project is several years from breaking ground, and will also need some level of USFWS approval. In any event, the County approval process includes sufficient protection of pine rocklands habitat and the preservation and restoration that will result from approval of those two projects will result in a net gain of habitat function for all species that live in pine rocklands habitat.

The Coral Reef Commons site is minimally developed (12%) and Ram’s plan calls for significant development of the remaining areas (88%). The extensive development of the CRC site would hinder the prescribed burning of the directly adjacent MTB habitat, allowing vegetation to overrun the beetles’ habitat. Additionally, Ram’s plans for the CRC “preserves” are two widely separated parcels of habitat bordered by development; this design renders these “preserves” minimally accessible to species entering or moving between the nearby habitat. Given the proximity of Ram’s proposed development any potential for controlled burning is severely limited and the potential for vegetation encroachment is very high. Consequently, the claim of “net gain in … habitat function” within these preserves is doubtful.

Construction of hospitals, schools, apartments, and hotels around [pine rocklands] sites should be discouraged because of conflicts with smoke generation during prescribed fires. (URS Corporation et al. 2007)

Miami Wilds, in its present incarnation, would destroy a portion of occupied MTB habitat and threaten the remaining adjacent MTB habitat with vegetation encroachment and degradation from fire suppression. Ram’s claim that this project is no immediate threat is ludicrous. Most alarmingly Ram’s assertion that “… the County approval process includes sufficient protection…” for this endangered habitat ignores the facts. Miami-Dade County Commissioner Dennis Moss has pushed to declare a redevelopment district (this included the Richmond Heights pine rocklands) around Zoo Miami which would strip most of these standing environmental protections. Moss only recently backed off of this proposal due to the public outcry to preserve the pine rocklands.

3. There is insufficient information on the biological status and threats to the MTB that would warrant proposing it for listing as threatened or endangered. The MTB is not even a candidate species identified by the USFWS. Any terminology created by the Petitioners to describe it as “potential candidate” or “highly imperiled candidate” have no meaning within the context of the ESA and cannot support listing. The Service should consider the Petition in the normal process of the ESA.

The biological status of the MTB is firm; please see my extensive reply below. Ram’s “not a candidate species” claims fall flat; we petitioners clearly reference both the USFWS and state concern status. See this excerpt directly from the Petition (with links substituted for the footnotes):

The Service regards the Miami tiger beetle as a species of concern, and the Florida Fish and Wildlife Conservation Commission regards it as a species of greatest conservation need.

Reenforcing the need for protection, in 2014 Knisley, Kippenhan, and Brzoska (experts not involved in the Petitionrecognized the MTB as “in danger of extinction” and recommended the MTB for federal listing

We assigned seven taxa a 1+ grade, our highest level of rarity and/or threats; of these there is presently sufficient information available to consider two of them –  [the Miami tiger beetle] and Cicindela tranquebarica joaquinensis Knisley and Haines – as the U. S. forms most in danger of extinction.Consequently, we recommend these two taxa should be immediately considered for listing by the USFWS. (Knisley et al. 2014)

4. The scientific and factual bases of the Petition are fundamentally flawed. The Petition contains numerous conclusory statements, with little and questionable scientific authorities cited. In order to undertake an emergency listing, the Service must have facts showing the presence of an emergency situation posing significant risk to the species as a whole. Simply stating that the MTB is an imperiled species does not make it so.

Throughout the Petition we thoroughly cite the appropriate research and expert analysis of the matter. Any claims to the contrary simply ignore the actual content of the Petition. See my comments above on points 1 through 3 for the risks facing the MTB.

5. The Petition fails to demonstrate that the MTB is a species” or “subspecies” within the meaning of the ESA. The taxonomy does not support the MTB as biologically distinct from other beetles. Petitioners accept the MTB as a separate species based on several unsupported scientific assumptions that fail when tested.

False – Ram’s lawyer is clearly unaware of scientific practice and convention or is attempting to cast false doubt and delay the listing process. See my extensive reply below for a complete treatment of this claim.

6. There are significant gaps in the data necessary for a listing decision, and the Petition fails to present substantial information indicating that listing may be warranted. The Petition fails to detail the manner, location or extent of any surveying completed to date, relying instead on blanket statements that the MTB is imperiled. The ESA defines the term endangered species” as any species which is in danger of extinction throughout all or a significant portion of its range.” Not all pine rocklands in the County have been surveyed for the MTB. Therefore, the Petition uses an incomplete data set of surveys to infer that the MTB is imperiled. This is highly improper. Without comprehensive surveys for the MTB, any determination that the MTB is on the brink of extinction is merely speculative. More surveying data is needed in order to determine the level of risk facing the MTB and whether it warrants an emergency listing.

Again Ram’s claims are not consistent with the facts:

Extensive surveys were conducted in both scrub habitats and most of the pine rockland sites in Miami-Dade, Ft. Lauderdale and Palm Beach Counties (Knisley, 2008). Most were unsuitable probably because they were too densely vegetated or the substrates were mostly oolitic limestone rock with few or no sand patches (Knisley et al. 2014).

As we cite in the Petition researchers have conducted extensive surveys, from 2008 to 2014, at virtually all accessible pine rockland sites (Knisley 2011, 2014; Knisley and Wirth 2013). While the locations and extent of the surveys are enumerated in these reports, I’ve put together a chart of all rocklands outside the Everglades National Park:

Surveyed areas

Over two-thirds (almost 70%) of the pine rocklands outside the ENP have been surveyed and the Miami tiger beetle has been found only in the Richmond Heights pine rocklands, an area comprising, at most, 18% of the extant pine rocklands.

The largest unsurveyed portion of pine rocklands are approximately 109 parcels (23%) of rockland in private ownership. There is a very low probability for access to these sites and the Institute for Regional Conservation (IRC) notes that “[the] majority of these private parcels are in very poor condition, due to lack of proper management.”

PowerPoint Presentation

Contrary to Ram’s claims, the surveys of any potential habitats have been extensive and, with the exception of the Richmond Heights pine rocklands, have not yielded any MTBs. This is a severely limited range which alone is a significant risk to a species; coupled with the lack of habitat management and pending development the MTB is in danger of extinction.

7. In addition to more surveying data, there is no approved methodology to survey for MTB. This further calls into question any listing conclusion based on the limited surveys discussed above.

Incorrect; tiger beetle activity is predictable and well described in the literature. The methods used in the MTB surveys are described therein and are consistent with protocols employed in other endangered/threatened tiger beetle species surveys (Knisley 2011).

8. The Petition states that the MTB is only found in open patches of sandy soils. The Petition expands this statement and alleges that the MTB is only found in the Richmond Pine Rockland area. There is no scientific authority for this leap of logic. Other research indicates that beetles can be found in numerous locations in south Florida containing open sandy soils, not just the Richmond Pine Rockland in Dade County.

The original collection site was pine rocklands and no other specimens are present in any major collections despite extensive surveys and collection in the region. On the other hand, a common species, the scabrous tiger beetle (Cicindela scabrosa), has been found in the greater Miami-Dade region, particularly to the north, and many preserved specimens can be found in the major U.S. museums. As the original collection site and only occupied habitat are pine rocklands, specifically within open sandy patches, there is no doubt about the Miami tiger beetle’s habitat requirements (Brozska et al. 2011).

Ram’s assertion that the MTB “can be found in numerous locations in south Florida containing open sandy soils” is absolutely false. As I note below the MTB is full, distinct species with taxonomic support as great as its sister species and any attempt to conflate the MTB and C. scabrosa are invalid.

9. The Petition states that the CRC property is “occupied” by the MTB. This statement is completely and wholly unsubstantiated. As the USFWS told RAM on December 18, 2014, no beetle surveys have been conducted on the CRC property. Furthermore, the majority of the CRC property contains no open sandy patches of sand given that the property is currently degraded, with a dense and overgrown understory and canopies, due to lack of maintenance. A third of the CRC property has previously been developed and is occupied by abandoned buildings formerly used by the University of Miami for medical research purposes. Because of this degraded state, current conditions do not provide habitat for the MTB. When restored, the site will provide more open areas that could provide habitat for the MTB, along with other species that use pine rocklands for habitat.

Our claim is that the CRC site is a possible habitat for the MTB and if present that “[b]oth developments would directly destroy occupied habitat and impact adjacent occupied habitat by limiting burns and other flora management efforts.” Further to this point, we even provide a map of MTB sites (Note the lack of any known MTB sites  in the CRC site):

MTB Locations

There have been no comprehensive, independent surveys of the CRC site. Yes, the site may be degraded, but it is still able to be restored if Ram does not pave over the site. The foundation of pine rocklands is the oolitic limestone substrate and this appears to be intact on a majority of the property. Contrary to Ram’s claim that a “third of the … has previously been developed” only 12% of the CRC is significantly impacted.

Ram Site pie chart web

10. The Petitions focus on CRC reveals the Petitioners true intent — to use the ESA to advance their own biased agenda to stop the development of the CRC, Miami Wilds and any development of land within pine rocklands. The Service should reject Petitioners attempt to misuse the USFWS emergency listing Petition process (at the expense of limited USFWS resources) [emphasis added] in their single-minded quest to leverage the ESA as the ultimate land use tool.

Any development within or impinging upon pine rocklands further reduces the 1.8% remaining in Florida (outside the ENP) and impacts any neighboring rocklands through (often extensive) fire suppression and the subsequent vegetation encroachment. There are surely other sites in the county where Ram can build Coral Reef Commons without destroying and degrading endangered habitats.

Throughout these documents Ram’s lawyer consistently advocates for further, redundant, research on the MTB. Ram’s characterization of the Petition as an “attempt to misuse the USFWS emergency listing Petition process” is ridiculous; the emergency listing process exists exactly for this type of situation and the statement that the Petition comes “at the expense of limited USFWS resources” is a brazenly hypocritical claim. Ram spends significant portions of these letters pushing for research which would absolutely come at the expense of USFWS’s limited resources.

11. It is not proper to designate critical habitat concurrently with an emergency listing.

I’ll defer to a legal expert here; however, a critical habitat designation is absolutely necessary for any listed species and, should the MTB receive federal or state protection, a critical habitat designation must follow.

12. If listing of the MTB is ultimately deemed warranted by the USFWS, the normal listing process should be undertaken so that adequate science and data can be developed regarding species status and the public can be given an opportunity for adequate and meaningful comment. The MTB Petition should not be prioritized over other current listing work.

There is adequate science and data to support the MTB’s species status (see below) and we believe that the best available data merits emergency listing. Even under the normal listing process there is no excuse to delay MTB petition given the serious threats to the species’s survival.

DETAILED COMMENTS REGARDING EMERGENCY PETITION

1. The Emergency Petition Is Flawed And Does Not Support The Legal Standard For Emergency Listing.

Section 4 of the ESA sets forth an emergency listing procedure that allows the USFWS to bypass the normal listing procedures only where there is a significant risk to the well-being of a species.” There are two key tasks associated with conducting an ESA status review. The first is to determine whether the petitioned entity qualifies as one or more species under the ESA. If the petitioned entity qualifies as a species, the second task is to conduct an extinction risk assessment to determine whether the species is threatened or endangered. Listing decisions must be based on substantial scientific or commercial information indicating that the petitioned action may be warranted or should be rejected on that basis, 16 U.S.C. §1533b)3)A), For the purposes of this Section, substantial information’ is that amount of information that would lead a reasonable person to believe that the measure proposed in the petition may be warranted. 50 C… § 424.14b)1) (emphasis added). The Petition lacks the necessary substantial information to support an emergency listing and fails to demonstrate that listing may be warranted.

As I’ve noted above (and as we cite in the Petition) there is compelling data for our claims and, as explained below, the full MTB species status is not in question.

The considerations the Service must make in assessing the Petition are listed in 50 C…§ 424.14b)2). These include: 1) a requirement that the petition clearly indicate the administrative measure recommended and give the scientific and any common name of the species involved; 2) the petition must contain detailed narrative justification for the recommended measure, describing, based on available information, past and present numbers and distribution of the species involved and any threats faced by the species; and 3) provide information regarding the status of the species over all or a significant portion of its range; and 4) be accompanied by appropriate supporting documentation in the form of bibliographic references, reprints of pertinent publications, copies of reports or letters from authorities, and map. 50 C… § 424.14b)2). While Petitioners appear to have attempted to meet these obligations, on closer examination it is clear that the Petition is insufficient to trigger the extraordinary action of an emergency listing. Moreover, in light of flaws with the biological assumptions, surveying methodology, data gaps and underlying scientific rationale, it is clear that listing is not warranted.

[Footnote 2] 16 U.S.C.§1533(b)(7), ELR STAT. ESA §4(b)(7).

Contrary to Ram’s claims there are no significant or unwarranted biological assumptions and the surveys have been both extensive and methodologically sound. Consequently, the asserted data gaps and lack of scientific rationale are simply assertions, not fact, and do not represent the state of the science.

2. Significant Risk To The Miami Tiger Beetle Does Not Exist And Therefore Emergency Listing Is Not Proper

An emergency listing is appropriate only where there is a significant risk to the well being of a species on the population as a whole.” USFWSs Listing Handbook states the following: “Species should be considered for emergency listing when the immediacy of the threat is so great to a significant proportion of the total population that the routine listing process is not sufficient to prevent large losses that may result in extinction.” As discussed below, such circumstances are not present here.

“The purpose of the emergency rule provision of the Act is to prevent species from becoming extinct by affording them immediate protection while the normal rulemaking procedures are being followed.” Thus, in order to meet this standard, the Service must be presented with sufficient facts showing the presence of an emergency situation posing significant risk to the species as a whole. While the emergency listing process allows the temporary listing with somewhat less rigor than required in the normal listing process, the ESA still requires a level of substantial science to support an emergency listing. See Bennett v. Spear, 520 U.S. 154,176, 1997) (The obvious purpose of the requirement that each agency use the best scientific and commercial evidence available is to ensure that the ESA not be implemented haphazardly, on the basis of speculation or surmise.”).

[Footnote 3] 16 U.S.C.§1533(b)(7), ELR STAT. ESA §4(b)(7).

[Footnote 4] USFWS, Endangered Species Listing Handbook (1994) at 109 (emphasis added).

[Footnote 5] Listing Handbook at 109.

The Petition fails to demonstrate that expected losses during the normal listing process would risk the continued existence of the MTB as species. As noted in the Listing Handbook, one factor to consider in determining the immediacy of the threat to the MTB is the relative immediacy of any project deadlines, Here, neither of the two projects that Petitioners selectively target in their Petition is sufficiently immediate to pose a threat to the MTB (even assuming it is present at those locations). As the USFWS and Petitioners are aware, the CRC project is currently being reviewed by the USFWS as part of the Section 10 Habitat Conservation Plan process. In the interim, the County has suspended the necessary approvals for the project and the property owner, Ram has agreed to refrain from commencing all earth disturbing activities. Far more speculative, the Miami Wilds project has no approvals and does not even control the land required for implementation of the preliminary plan. Thus, it cannot be credibly argued that Miami Wilds poses any immediate threat of imperiling MTB. Petitioners admit this in their Petition, at 21-23, thereby acknowledging that there is no immediate threat. For these reasons alone, USFWS should reject the emergency petition.

With over >98% potential historic habitat gone, drastically fluctuating population, and a constant progression of vegetation encroachment the MTB is not only extraordinarily limited in range and numbers but is under continual stress (Knisley 2011, Knisley et al. 2014). Developmental encroachment in the form of Coral Reef Commons and Miami Wilds poses a significant and immediate threat. County commissioner Dennis Moss has pushed for the creation of a special redevelopment zone to facilitate the construction of a theme park in the Richmond Heights pine rocklands for years and any planned development (especially as it involves the removal of legal protections for endangered lands) is an immediate threat to the rocklands and their inhabitants.

Moreover, as discussed below, the data on the presence and extent of the MTB is weak with significant data gaps. In order to emergency list a species, the Service must have facts showing the presence of an emergency situation posing significant risk to the species as a whole. The existing surveying is incomplete and unscientific, and the taxonomy on the MTB does not support the argument that it is a species” or “subspecies” under the ESA. There is no substantial information indicating that listing of the MTB is warranted, much less that the threat is so grave as to risk extinction.

Ram’s claim that “the data on the presence and extent of the MTB is weak with significant data gaps” is false. The USFWS has commissioned extensive surveys (Knisley 2011, Knisley and Wirth 2013) and these surveys have failed to find the MTB at any sites outside the Richmond Heights pine rocklands. These rocklands are at significant risk of development and degradation, both from lack of management and developmental encroachment. The MTB’s status as a full species is settled.

3. Petition Lacks Adequate Science To Support An Emergency Listing

A. There is no data or science to support that the MTB is a separate species or distinct subspecies that can be listed

The Petition contains no data or support for the supposition that the MTB is a species or distinct subspecies that merits listing. The ESA defines the term “species” to include any subspecies of fish or wildlife or plants, and any distinct population segment of any species of vertebrate fish or wildlife that interbreeds when mature.” 16 U.S.C. §153216). Here, the designation of the MTB is an artificial distinction that does not withstand scientific scrutiny.

We petitioners clearly and consistently cite the appropriate research on the species status of the MTB. In Brzoska et al. (2011) numerous non-artificial differences in morphology, habitat, and seasonal activity are laid out to demonstrate that the MTB is a full separate species. It is important to note that the authors of Brzoska et al. (2011) were not involved in the Petition.

Furthermore other independent scientists and publications have recognized the status of the Miami tiger beetle; chiefly author, Yves Bousquet, and the reviewers of the authoritative Catalogue of Geadephaga (Coleoptera, Adephaga) of America, north of Mexico. This peer-reviewed publication recognizes the Miami tiger beetle as a full species in the genus Cicindela (within the subgenus Cicindelidia) Cicindela floridana Cartwright, 1939.

Indeed, it is clear that the MTB is simply a scabrous tiger beetle (Cicindela scabrosa Schaupp), which are prevalent throughout Florida. Given that there are no differences among these beetles, the MTB cannot be listed as endangered. See National Assn of Homebuilders v. Norton, 340 F.3d 835 (9th Cir. 2003) (rejecting listing of Cactus ferruginous pygmy owl). [emphasis and species name added]

No, entirely wrong. Ram’s claim of a single species is simply a forceful attempt to misrepresent the species status of the MTB. No current scientific authority or scholarly work recognizes the MTB (Cicindela floridana Cartwright) as a synonym of Cicindela scabrosa Schaupp. There are significant difference in morphology, habitat, and seasonality (Brzoska et al. 2011). Even in general appearance the two species are immediately (and consistently) distinguishable (MTB on the left):
MTB vs scab

Upon review, it is clear that existing and accepted science on identifying species indicates a more rigorous identification process must occur before the MTB can receive separate species status. The self-serving publication of a single article is insufficient for demonstrating that the MTB is a distinct species.

A significant percentage of species (not just beetles or even insects) are described in a single paper or monograph. This claim is either a fundamental misunderstanding of the whole species description process or deliberate attempt to misconstrue the validity of the MTB species status. Ram’s accusation of “a self-serving … single article” is both a smear on the authors of the Brzoska et al. (2011) paper, who are not involved in the Petition, and on the nature of the scientific process.

In 1984, Choate published a paper that identified a new species known as the highlands tiger beetle, Cicindela highlandensis and elevated C. abdominalis scabrosa to species level thereby changing the name to C. scabrosaChoate also identified a variety of C. scabrosa as C. s. floridana, which is now referred to as the MTB.

Half-correct; it was O.L. Cartwright who first described the MTB as a subspecies of C. abdominalis in 1939 from Frank Young’s 1934 specimens. Choate’s treatment of the group (as summarized in Brozoska et al. 2011) dealt only passingly with the MTB:

Choate (1984) reviewed the abdominalis group, describing a new species, Cicindela highlandensis Choate, and elevating Cicindela scabrosa Schaupp to species level. In that paper he created “C. s. floridana”, with no mention of types and no other discussion of “floridana” except for his section on variation in C. scabrosa that “some specimens are quite greenish (i.e. floridana)” which he considered to be a possible sign of recent adult emergence. Apparently Choate considered var. floridana as a subspecies of C. scabrosa because both had similar sculpturing on the elytra and dense flattened setae on the pronotum.

Choate 1984-6

Brzoska et al. (2011), a paper cited in the Petition, takes liberties with Choates variety (var.) of C. s. (var.) floridana (Choate 1984), inferring that it was intended to be a distinct subspecies without supporting evidence, Brzoska et al, attempt to assert subspecies status by using a field guide and identification manual for Florida and US. tiger beetles (Pearson et al. 2006), which, not coincidentally, was coauthored by one of the same coauthors in the Brzoska paper, C. Knisley. Field guides are not the generally accepted manner in which to identify a new species, much less support an emergency listing. Knisley takes similar liberties and relies on the same unsupported inferences taken from the Choate (1984) paper to support that the MTB as a separate species.

The authors of Brzoska et al. (2011) make two points: 1) Choate’s 1984 treatment of the MTB was brief (“… no mention of types and no other discussion…”) and 2) Choate recognized the MTB as very closely related to C. scabrosa. On the same note Brzoska et al. note that Pearson et al. (2006) mention the MTB (“… considered a separate subspecies by some experts.”) within their treatment of C. scabrosa. Why the inclusion of this material? Nothing more than background information; the passages referencing Choate (1984) and Pearson et al. (2006) appear only in the paper’s introduction! There is no “attempt to assert subspecies status” as Ram insists, only references to the few scholarly works which have mentioned the MTB.

In the scientific description of the Miami tiger beetle Brzoska et al. (2011) utilize differences in morphology, habitat, and seasonality to distinguish the MTB, not a previous species/subspecies status. You can cut out all “assertions” of subspecies status and the MTB’s status as a full species is fully intact; Ram’s claims are again not consistent with the science.

It is important to note that Knisley admits on his website biography that his mission is to use listing of species (tiger beetles) to stop development, further calling into question his conclusions that the MTB is a separate species and exposing the motive for the Petition. “About 1985, I became more interested in tiger beetle conservation with an overall goal of using rare tiger beetles as a vehicle for the protection of unique natural areas in the U.S. The results of this work have led to the listing of 4 species on the Endangered Species list and coincidental protection of some key habitats where they occur.” C. Barry Knisley, Research Randolph-Macon College Faculty Page (Jan. 12, 2015, 9:21 AM), 

Ram Realty or their lawyer appears to be under the impression that C.B. Knisley is somehow responsible for the Petition; this is nonsense. Knisley’s only “role” in the Petition is as a source; we cite his reports to the USFWS and other scientific publications. I did independently contact Dr. Knisley to clarify two points of his MTB work; these are reproduced and cited in the Petition:

Extensive surveys of most of the pine rockland sites in Miami-Dade County failed to find any additional sites for the Miami tiger beetle.These three sites should be considered a single population given tiger beetle movement and their close proximity being within dispersal range.

These two clarifications are not in any way “responsibility” for the MTB petition. The authors cited in the Petition (chiefly Brzoska, Knisley, and Slotten) were not involved in the planning, writing, or submittal of the Petition.

Ram’s assertion that the “motive for the Petition” is to “stop development” is a misrepresentation of the facts. We petitioners are concerned about the continued survival of the Miami tiger beetle. Pine rocklands are the only known habitat for the MTB (and numerous other endemic species) and Ram’s Coral Reef Commons development will directly destroy pine rocklands (possible MTB habitat) and impact adjacent pine rocklands through the suppression of controlled burns.

The fact that Ram Realty chose a known biologically unique natural area (and key habitat to so many species) for their development is shameful. Calling any opposition to the destruction of this rare and unique habitat a blanket attempt to “stop development” is simply lying about the facts in this case.

More recently, Choate produced two taxonomic keys that do not even mention the variety described as var. floridana. In Choates (2001) Manual for the Identification of Ground Beetles (Coleoptera: Carabidae) of Florida (which includes tiger beetles), he does not include nor even mention his previously described C. scabrosa var, floridana. Similarly in Choates (2003) Illustrated Key to Florida Species of Tiger Beetles, he included C. highlandensis, C. abdominalis, and C. scabrosa as distinct identifiable species using the taxonomic key.

The late P.M. Choate published these keys six and four years, respectively, before the MTB was rediscovered. We can assume from his 1984 treatment of the abdominalis group that Choate regarded the MTB as examples of recently emerged C. scabrosa hence the exclusion of “floridana” (MTB) from his 2001 manual and 2003 taxonomic key. To this point Choate does not mention even examining Frank Young’s 1934 MTB specimens and wrote all of these papers before any other specimens were available. This mischaracterization of the distinctive green tones of the MTB is likely not purposeful; because when beetles (generally speaking) first emerge as adults their protective exoskeleton is still hardening. Due to changing absorption and reflection of light during this hardening progression the color of some beetles can vary from the time of emergence to fully mature adult form.

However, this is not the case in the MTB. I personally have worked with these beetle throughout their life cycle and I’ve seen no changes in adult coloration and Brzoska et al. (2011) do note this in their paper as a key character separating the MTB from its nearby species. Ultimately, Choate is not at fault for this misassumption and exclusion of the MTB. But Ram dishonestly uses Choate’s mistakes in their attempt to cast doubt onto the status of the MTB despite a clear refutation in Brzoska et al. (2011) .

Importantly, it does not include C. scabrosa var. floridana (the MTB) or mention the possible extinct status of this variety. If the MTB was truly a separate species, as Petitioners infer from Choate 1984, why would Choate in 2003 not include his own described variety of C. scabrosa as a separate and identifiable subspecies in a document intended to identify Florida species of tiger beetles?

Many, if not most, taxonomic keys will list species thought to be extinct, extirpated, or in nearby geographic regions to ensure proper identification in case these species are collected again or expand their known ranges, Range extensions and the return of extirpated species is not uncommon, especially in South Florida where Everglades Restoration activities, exotic plant removal programs, and land management activities are ongoing (Mosley 2009). It is highly unlikely that C. scabrosa var. floridana was excluded from the key because it was thought to be an extinct subspecies or species.

The MTB is absent from these works because Choate regarded the MTBs as examples of a recently emerged C. scabrosa hence the exclusion of “floridana” (MTB) from his 2001 manual and 2003 taxonomic key.

Just a minor point but we petitioners do not use Choate (1984) to support MTB as a separate species; this is conclusively resolved in Brzoska et al. (2011) and recognized in independent publications (ex Bousquet 2012).

Adding to the debate about whether the MTB is a separate species is The Florida State Collection of Arthropods (FSCA 2015). It has a checklist of Cicindelidae that does not recognize species level status for the MTB but rather lists it as a synonymous (=) variety of Cicindela scabrosa shown in the following taken directly from FSCA:

(Excerpted from FSCA Species list for Florida)

  • C. (Cicindelidia) scabrosa Schaupp, FL endemic (ALA, BRE, BRO, DAD, HIG, IND, LEV, ORA, POL, PUT, SJO, TAY, VOL); rare 
    C. abdominalis var. floridana Cartwright 
    C. abdominalis var. scabrosa Schaupp 
    C. extenuata Casey

This checklist does not add to any debate. Just read the note at the top of the “FSCA” list: “reviewed and corrected by R.W. Lundgren, June 1995; G.E. Ball, September 1995.” Ram’s lawyer is citing 19 year old information here! This is simply an obsolete list and Ram’s omission of the date and misattribution of this list typifies their dishonest approach to the whole matter of the MTB.

The Interagency Taxonomic Information System (ITIS 2014) also does not recognize the name proposed by Brzoska et al. 2011 for the MTB Cicindelidia floridana. The newly developed name of MTB created from suppositions and assumptions is simply not valid.

[Footnote 6] ITIS 2014 contains the following disclaimer, ITIS taxonomy is based on the latest scientific consensus available, and is provided as a general reference source for interested parties. However, it is not a legal authority for statutory or regulatory purposes. While every effort has been made to provide the most reliable and up-to-date information available, ultimate legal requirements with respect to species are contained in provisions of treaties to which the United States is a party, wildlife statutes, regulations, and any applicable notices that have been published in the Federal Register. For further information on US. legal requirements with respect to protected taxa, please contact the US. Fish and Wildlife Service.”

This discrepancy reflects a scholarly debate about the placement of some tiger beetle subgenera and not the validity of the MTB’s species status. From Ted MacRae’s 2009 review of A Treatise on the Western Hemisphere Caraboidea (Coleoptera). Their classification, distributions, and ways of life. Volume II (Carabidae-Nebriiformes 2-Cicindelitae):

Likewise with subgenera, Erwin and Pearson break ranks with the preponderance of recent North American literature (including Pearson’s own 2006 book) and accord full generic rank to most of the former subgenera of the genus Cicindela, including such familiar North American taxa as Cylindera, Dromochorus, Ellipsoptera, Eunota, and Habroscelimorpha (Tribonia, on the other hand, is synonymized under Cicindela, leaving Cicindelidia as the only non-nominate subgenus of Cicindela). (MacRae 2009)

Consequently the status of several subgenera, particularly Cicindelidia, is still in flux. This is the case in Brzoska et al. (2011): “We follow the classification of Rivalier (1954) and Wiesner (1992) and place this species in the genus Cicindelidia Rivalier.” Thus the question of the genus name used in Brzoska is only an academic quibble and, as before, has no bearing on the validity of the MTB species status.

Under the present classification (Bousquet 2012) of North American tiger beetle genera the MTB sits in the genus Cicindela within the subgenus Cicindelidia. Thus Cicindela floridana Cartwright 1939 is the full name for this species and is both the combination we use in the Petition and that ITIS recognizes.

According to ITIS, the valid Genus name remains Cicindela with species names; C. highlandensis, C. abdominalis, and C. scabrosa as valid. The C. abdominalis floridana (MTB) subspecies name is listed as invalid.

The name C. abdominalis floridana (MTB) was synonymized (into C. scabrosa) by Choate (1984) and is rightly not valid. Ram’s selective exclusion of the valid ITIS MTB name from this list is again appallingly dishonest.

In the scientific field of identifying beetles, many species of Floridas aquatic and semi aquatic beetles have male forms with specialized aedeagus for transfer of sperm which is often used to separate species that look very similar and cannot be taken to species level otherwise (Epler 2010, Epler 1996). The same is true for tiger beetles where the reproductive parts, including male aedeagus and female ovipositors are specialized and unique to species and used for identification (Pearson and Vogler 2001). Such descriptions are wholly lacking in the Brzoska et al. (2011) taxonomic key, and there was no genetic evidence presented to elevate it to species level. Elevation to species level for the MTB appears to be premature and is not consistent with previous accepted taxonomic practices (Epler 2010, Epler 1996, ITIS 2014) or at Floridas recognized museum arthropod collection (FSCA 2015). There are often variations in size, form, and color patterns in Floridas aquatic, semiaquatic, and terrestrial beetles depending on sex (Epler 2010, Epler 1996) and habitat conditions that do not rise to a separate species level or subspecies. The elevation of Cicindelidia (Cicindela) floridana to species level or distinct subspecies level is not supported through recognized taxonomic standards at this time. There is no genetic difference among these variations of C. scabrosa.

This is an entirely misleading claim as neither Cartwright (1939), Choate (1984), or Brzoska et al. (2011) utilize differences in the male aedeagus to differentiate the species! The MTB is not even an “aquatic and semi aquatic [beetle]” which are often very difficult to differentiate, hence the need for internal characters. Choate did examine the aedeagus of C. abdominalis, C. highlandensis, and C. scabrosa but does not even use these traits in his key:

Choate 1984-8

There has been a preliminary genetic analysis conducted which concludes: “[t]his molecular study provides strong evidence that Cicindela floridana [MTB], C. scabrosa and C. highlandensis are all closely related and recently diverged sister species” (Knisley 2011). Even without genetic evidence the MTB is so different in terms of morphology, habitat, and seasonality it stands as a full species (Brzoska et al. 2011).

Finally, Cicindelidia floridana (combined name proposed by Brzoska et al. 2011) is not valid according to Cartwright (1939), Choate (1984, 2001, 2003) FSCA (2014) or ITIS (2014) who use Cicindela. It appears that they just made this name up by combining two previous authors names.

As I illustrate above the name “Cicindelidia floridana” is the result of an academic debate over tiger beetle subgeneric classification, not the validity of the MTB’s status.

B. Population Size, Range Distribution, And Critical Habitat Unknown Which Calls into Questions Whether The MTB Actually Faces A Significant Risk Which Merits An Emergency Listing

The ESA defines the term endangered species” as any species which is in danger of extinction throughout all or a significant portion of its range.” 16 U.S.C. § 15326). With regard to the MTB, population and distribution status is completely unknown at this time, and no survey methodology has been published or even proposed for detection of presence/absence of the MTB. Entomologists and ecologists employ numerous techniques for the sampling of insect communities, but standardized detection methods for tiger beetle have not been proposed for screening of presence/absence to identify population distribution. Many of the sampling techniques, including, Malaise traps, light traps, and Berlese funnels, can be destructive (kill traps). Other methods for collecting tiger beetles include sweep nets and live pitfall traps with limited success. Because adult tiger beetles run very fast in short bursts and are agile fliers with sensitive vision, they can be difficult to collect. Adults are known to react promptly to abrupt movements of approaching collectors from great distances” (Taboada et al. 2012) and are difficult to trace.

Shameless misrepresentation of the science. MTB population (likely <100) and distribution (only Richmond Heights pine rocklands) are well known (Knisley 2008, 2011; Brzoska et al. 2011) and survey methodology has been established (Knisley 2011).

Survey methodologies are also lacking for establishing population sizes of tiger beetle species when they are known to be present, survey time frames, temperature minimums and maximums, weather conditions, and a minimum or optimum level of effort are needed to standardize any survey protocols. Larvae spend many months underground, possibly a year or more. Requiring surveys with no guidance on these issues is unjustified based on what is currently known. Visual walking transect surveys for population estimates requires training, experience and repeated site visits. Taboada et al. (2012) tested the effectiveness of live pitfall traps for collecting flying tiger beetles with adaptive modifications to improve catchability.

Additional research is needed to improve on pitfall traps and visual walking transect surveys to develop a population estimate methodology that is both adequate and defensible, Pitfall traps may be difficult to construct in the pine and hammock rocklands of the Richmond Tract due to the limestone substrate.

False; tiger beetle activity is well described in the literature and predictable (summarized in Knisley and Shultz 1997, Pearson et al. 2006). There already exist adequate and defensible tiger beetle population estimate methodologies (Knisley and Gowan 2008). Even with such methodologies, visual walking transect surveys prove to be the most effective (due to extensive vegetation and uneven limestone substrate) in identifying MTBs in the field and obtaining sufficient population estimates (Knisley 2008, 2011; Knisley and Wirth 2013). Ram’s claim that “[v]isual walking transect surveys for population estimates requires … repeated site visits” ignores the content of Knisley’s reports; numerous site visits were conducted and are clearly noted in the report (Knisley 2008, 2011; Knisley and Wirth 2013).

The statement that”[l]arvae spend many months underground, possibly a year or more” is not accurate; tiger beetle larvae are ambush predators which construct vertical burrows into the sandy substrate. The larvae wait at the burrow opening at ground level for prey, likely ants or springtails, lunging at and dragging prey down into the burrows. These burrows are characteristic in size and shape thus providing a reliable way of surveying larval MTBs.

The 1934 collection site for holotypes of the Cicindela abdominalis var. floridana by Cartwright (1939) were made by Frank Young, reportedly while searching for rare tree snails in sandy hammocks in North Miami. The exact location and habitat type for these collections is not known, but in the area of Barry University (Brzoska et al. 2011). Sandy hammocks are not pine rocklands, and there are no sandy hammocks within the CRC project

Actually, I pinpointed the exact area and habitat of the MTB type locality last year; see my post here. The habitat type was certainly pine rocklands, which Frank Young noted bordered his collecting sites:

The distribution of the hammocks around Arch Creek shows the same general pattern as those around New River to the north or Little River to the south. That is, the hammocks occur along the margins of the stream or its estuary, across the rocklands of the East Coast ridge, and fan out along the edges of the transverse glade. This pattern is apparently maintained by the nature of the soils and the periodic fires which sweep the bordering rocky pinelands [emphasis added] and encroach upon the edges of the hammocks.

Here is an aerial image of the MTB type locality from 1940:

Bingo

Additionally in photographs of Barry University you can see the remnants of pine rocklands in the background, further confirming the existence of this habitat at the MTB type locality.

The collection of new specimens collected in 2007 (Brzoska et al. 2011) reportedly came from Richmond Heights area pine rocklands but no detailed description of habitats nor locations were provided out of concern of the “extreme rarity of this beetle” (Brzoska et al. 2011 page 5 under Distribution. In spite of this concern about the extreme rarity, 40-43 specimens were collected from three unknown sites and “pinned” for distribution to museums and private collections.

The number of beetles collected by all three authors combined for all morphological, dissection, and genetic studies comes to fewer than 10 specimens per year (from 2007 to 2011)! This scientific collection of specimens is both necessary and accepted practice.

There exists an increasing market for tiger beetle specimens on the internet (Knisley et al. 2014) and Brzoska et al. (2011) are exceedingly cautious with the first MTB rediscovery site for good reason. In a similar case a rare Namibian tiger beetle, Mantica horni Kolbe, was known from only two type specimens from 1896 and “a very few individuals” until 2003 when a large series (24 males and 21 females) was collected by Franzen and Heinz (2005). After this rediscovery and publication of the collection locale I’ve seen M. horni selling for $995 to ~$1,400 per specimen! At similar prices those 43 MTBs could be worth anywhere from $42,785 to $60,200!

Further detailed description of habitats and MTB locations were provided in the Petition and in numerous reports to USFWS, a fact which Ram again choses to ignore.

Without detailed habitat descriptions, including, vegetation species, community structure, canopy cover, soil types, micro-climate conditions, and location data, it is impossible to identify any critical habitat requirements for this tiger beetle. There was also no mention of larval beetles or critical habitat for reproduction and survival as larvae.

Detailed habitat descriptions of pine rockland are reported in the literature (see URS Corporation et al. 2007) and soil types, micro-climate conditions, and location data for the MTB are reported in Knisley (2011). The larvae of the MTB are mentioned in numerous reports to USFWS and have been preliminarily described, including microhabitat and development (Knisley 2011, Knisley and Wirth 2013). Ram’s exclusion of this information and deliberate claims to the contrary is another forced misrepresentation of the science.

This tiger beetle (C. scabrosa var. floridana) may only require sandy soils with abundant prey, which could occur at many sites including airports, cleared fields, transmission line right of ways, military sites with vast open areas, and other non-pine rockland habitats in the Miami Dade region.

No. Ram’s assertions that the MTB = C. scabrosa (rebutted above) and MTB “can be found in numerous locations in south Florida containing open sandy soils” are both false.

4. Petition Makes Wholly Unsubstantiated And Misleading Statements That The CRC Property Is “Occupied” By The MTB

The Petition claims that the CRC property is occupied by the MTB. These statements are wholly unsupported and scientifically unsubstantiated. The fact that Petitioners would allege that MTB is present without any factual support whatsoever clearly demonstrates the Petitioners’ thinly veiled attempt to use the Emergency Petition process to stop the development of the CRC.

Our contention is that the CRC site is a possible habitat for the MTB which, if present, means that the CRC development “would directly destroy occupied habitat” and, even if the MTB is not currently present on the CRC site, that this development would “impact adjacent occupied habitat by limiting burns and other flora management efforts.” We even include a map of known MTB sites which clearly illustrates that no MTBs have been found on CRC site (however there have been no comprehensive surveys of the area) :

MTB Locations

The filing of the Petition with suspect and weak science in support cannot be condoned or allowed as means to advance their agenda to stop the CRC project.

Dishonest, plain and simple. As I have gone over above the Petition is based on sound science conducted by independent researchers. Any claim to the contrary is ignoring the facts.

As is known by the USFWS, no surveys have been conducted for MTB on the CRC property. Moreover, the Petitioners, by their own admission, state that the MTB can be found on open sandy soils. The majority of the CRC development does not have open Sandy patches of soils, Rather, it is infested with exotics, and coupled with lack of prescribed burning, is a densely canopied hardwood community, The CRC landowner has conducted numerous intensive site inspections and assessments on CRC. Petitioners have not.

CRC does not have any of the characteristics that the Petition alleges are necessary to support a population of MTB. Again, the fact that the Petition alleges that the MTB is present at the CRC site despite the fact that it has never been surveyed, is not subject to periodic fire, and lacks the constituent elements that Petitioners believe are a necessity for the species, demonstrates their underlying agenda of coercing USFWS into listing species to affect specific projects.

Yes, the CRC site may be degraded (largely due to mismanagement by the University of Miami), but it is still able to be restored if Ram does not pave over the site. The foundation of pine rocklands is the oolitic limestone substrate and this appears to be intact on a majority of the property. These pine rocklands have survived comparatively unscathed since the since early logging and military developments in the 1940s and these Richmond Heights rocklands represent a quarter of the 1.8% of this habitat left outside the Everglades National Park. Any further development seriously jeopardizes the rocklands and their inhabitants, principally by further fragmenting the remaining rocklands and suppressing fires, a necessity for the maintenance of the habitat.

5. Onsite Restoration Efforts Will Benefit The MTB

Current conditions on CRC do not consist of open sandy soils needed by MTB. Brzoska et al. (2011) asserts species level status and states that Cicindelidia floridana is found in small sandy pockets of pine rockland habitat (Fig.4), and This habitat is maintained by periodic fire.” Figure 4 of Brzoska et al. (2011) is a photograph of native pine rockland habitat with no canopy closure and what appears to be graminoid prairie with scattered small slash pine in the background.

The CRC property has neither. In its current condition, the CRC property is degraded, infested with exotic vegetation and many areas are covered with dense vegetation and suffer from lack of prescribed burns. The CRC property has been invaded by invasive exotic Burma reed and is converting to hardwood community due to lack of fire. It was previously developed as the Richmond Naval Air station, subsequently used by the University of Miami for medical research purposes, and has been largely unmanaged for decades.

The property has never been extensively developed; only 12% is presently developed. Below on the left is an aerial photograph from 1938 before any development of the CRC site (outlined in red); notice intact pine rockland habitat. In the center is an image from 1952, after the peak of Richmond Naval Air Station. And on the right is a 2014 satellite image (from Google Earth). Notice how little of the CRC site has been significantly altered.

RAM site 1938 1952 and 2014

While Petitioners seek to use the ESA to stop the CRC project, it is unquestionable that after onsite mitigation, the pine rockland habitat will improve to support a better biodiversity with open Space that will be a benefit to all species, possibly the MTB. Under a Habitat Conservation Plan, the pine rockland habitat on the CRC property will be preserved and managed for long-term benefits to the species, Restoration and management of preserves through exotic plant control, prescribed fire, thinning of pine and hardwoods will restore pine rockland habitat. Additional details regarding pine rockland habitat preserve restoration and management, including a proposed prescribed burn plan were submitted to USFWS in the Technical Submittal dated October 9, 2014.

This is simply not true. Ram can paint a rosy picture of gentle development but their plans are to develop over two-thirds of the property. This simply does not preserve a significant portion of the critically endangered habitat. Another solution is not to develop over two-thirds of the property and its pine rocklands. Under one-eighth of the Coral Reef Commons site has been developed. Perhaps there is a more appropriate use for this critically endangered habitat than yet more development. Let’s restore and preserve the seven-eighths of the property that is undeveloped and constructively use or mitigate the fraction of the property that is already developed. Pine rocklands are a irreplaceable part of Florida’s natural history and should be protected.

Conclusion

The Petitioners have failed to provide sufficient information to necessitate an emergency listing. There is no immediate threat to the MTB from the projects set forth in the Petition.

Nothing in the Petition (aside from pure conjecture and speculation) has indicated that there is an “emergency” for the beetle. In turn, the Service lacks sufficient information on species status, range, threats and the other factors identified in Section a)1) of the ESA, We request that the Service take the necessary time to fully review species status and research the beetle prior to making any decisions. Such a rulemaking should be done as part of the normal ESA workplan and existing priorities and court deadlines. If listing is warranted, the normal listing process would allow more development of data and opportunity for public comment. We also note that we have a pending Freedom of Information Act (FOIA) request on all information pertaining to the MTB that will not be processed until February 2015. In light of the fact that this Petition seems to target the CRC project directly, we believe out of fundamental fairness no action should be taken on this species until we are able to evaluate the Petition thoroughly. Ironically, the project going forward would create habitat for the beetle that does not currently exist on the CRC site.

Ram’s claim that “[USFWS] lacks sufficient information on species status, range, threats…” is superlatively false; the claim ignores the existing science and the fact that the Service itself commissioned research into the biology, range, habitat, and threats to the Miami tiger beetle.

Throughout this letter Ram has continually misrepresented the state of the science, selectively excluded research, and omitted context, all in support their development goals. This is simply shameful conduct.

Supplemental Response to Emergency Listing Petition regarding the Miami Tiger Beetle Filed by the Center for Biological Diversity, et al:

February 27, 2015

Dear Ms. Blackford:

As you know, this firm represents Coral Reef Retail LLC and Coral Reef Resi Ph I LLC, the owners of the Coral Reef Commons property (Coral Reef Owners). Enclosed is a Supplemental Response to the Emergency Listing Petition regarding the Miami tiger beetle. We also submitted our initial Technical and Legal Submittal regarding the December 11, 2014 Emergency Listing Petition filed by the Center for Biological Diversity, et al. on February 13, 2015. This Supplemental Response to the Technical and Legal Submittal further identifies the flaws in the emergency petition, and the Coral Reef Owners urge the US. Fish and Wildlife Service to carefully review our response and to deny the petition as failing to meet the necessary standards.

The Coral Reef Owners respectfully request that this Supplemental Response to the Technical and Legal Submittal be added to the administrative record for the Miami tiger beetle potential listing, and should the Service make any determinations on the emergency petition, Coral Reef Owners request to be notified. Please do not hesitate to contact me at or via email – if you have any questions regarding the content of this letter.

Sincerely,

[Signed]

Luna E. Phillips

cc: Client [Ram Realty]

Holland & Knight, Rafe Petersen, Esq.

US. Fish and Wildlife Service, Mr. Leopoldo “Leo” Miranda

Florida Fish and Wildlife Conservation Commission, Mr. Ernie Marks

Florida Fish and Wildlife Conservation Commission, Ms. Marissa Krueger

US. Department of the Interior, Ms. Vicki Mott

Johnson Engineering, Inc., Mr. Church Roberts

On January 14, 2015, Coral Reef Retail LLC and Coral Reef Resi Ph I LLC, the owners of the Coral Reef Commons Property (Coral Reef Owners) submitted to the USFWS a response to the above referenced emergency petition requesting listing for the Miami Tiger Beetle (MTB). The same response was filed with the Florida Fish and Wildlife Conservation Commission (FWCC). Subsequent to filing these responses, Coral Reef Owners received numerous documents from the USFWS pursuant to a Freedom of Information Act (FOIA) request. These documents underscore the lack of data and unsettled questions regarding the taxonomy and endangered status of the MTB. The documents also confirm that no MTB exist on Coral Reef Owners proposed development, Coral Reef Commons (CRC.), contrary to statements in the emergency petition. Moreover, the USFWS’s own expert declared that after surveying the CRC property he found no beetles and that the CRC is not “suitable habitat” for the MTB.

Correct; as we note in the Petition no MTBs have yet been found on the CRC site. Knisley’s single survey focused on the area immediately west of the Zoo Miami entrance road and did not cover a significant portion of the property (at most only 12% to 18%); there have been no comprehensive surveys of this area. This is not sufficient survey data to conclude the MTB is absent and Ram’s extrapolation that the whole site is unsuitable is scientifically unfounded (Knisley: “This area seems to have marginal or unsuitable habitat”). Researchers, including Dr. Knisley and myself, attempted to gain access to the site but the University of Miami blocked any further access to this site for “security concerns.”

A review of the FOIA documents makes clear that the emergency petition is nothing more than a poorly cobbled together attempt by petitioners to rush a listing in furtherance of their own biased agenda to stop the CRC development. The documents confirm that there is no immediate threat to the MTB and demonstrate a concerted effort to distort the science to have this species listed in order to stop development of pine rocklands. Indeed, the best available science does not even support species status for the MTB.

In actually it is Ram and their lawyer who are distorting the science as I show in my reply to their initial letter. Particularly, the MTB species status is settled and recognized by numerous independent scientists. The Petition was submitted out of concern for the survival of the Miami tiger beetle, not as some directed attack on the CRC development. Ram Realty chose a known biologically unique natural area (pine rocklands are critically endangered) directly adjacent to occupied MTB habitat which deeply concerns us due to scale of the planned development and its probable impact upon existing habitat (chiefly the suppression of controlled burning).

Because the emergency petition makes unsubstantiated statements about CRC and questionable statements regarding the status of the MTB, we file this Supplemental Response to highlight the critical issues to be addressed by the USFWS before listing (either emergency or normal) proceeds. We recommend that the USFWS engage a peer review panel to review the existing science on the MTB. This will ensure that any listing decision is based in sound science and grounded in the requirements of the ESA. Opening up the listing process to an unbiased peer review panel is prudent and the scientific community involved in assessing the status of the MTB should welcome such review. Moreover, given the substantial questions concerning MTB status, it is not appropriate for MTB to be given an elevated priority on the candidate list.

The species status of the MTB is not in dispute; unbiased scientists have recognized the full species status of the Miami tiger beetle. An independent peer review panel would also find the same. Ram’s push for such a review is clearly an attempt to delay the MTB listing evaluation and is unacceptable.

It is the USFWS and Florida FWCC who give the MTB such priority; see this excerpt directly from the petition (with links substituted for footnotes):

The Service regards the Miami tiger beetle as a species of concern, and the Florida Fish and Wildlife Conservation Commission regards it as a species of greatest conservation need.

Below, in Summary fashion, are three supplemental points regarding the MTB:

1. The taxonomy of Cicindela scabrosa (syn. C. scabrosa var. floridana) remains unsettled because of differences in opinion of tiger beetle experts. More research, including surveys of sand-pinescrub along the margins of pine flatwoods” in South Florida (Choate 1984, 2003) is needed, along with additional DNA work and examinations of male aedaeagus for any differences. Therefore, emergency listing is not appropriate at this time.

[Footnote 1] USFWS Interagency Policy for Peer Review in ESA Activities, 59 Fed. Reg. 34270 (July 1, 1994) (stating the policy of the Services incorporate peer review by appropriate and independent specialists in listing decisions)

This is an entirely spurious claim; the species status of the MTB is not in dispute. Contrary to Ram’s claims there have been extensive surveys of both pine rocklands and scrub habitats in Miami-Dade, Ft. Lauderdale and Palm Beach Counties (Knisley 2008, 2011; Knisley and Wirth 2013). Neither Cartwright (1939), Choate (1984), or Brzoska et al. (2011) utilize differences in the male aedeagus to differentiate species; Choate did examine the aedeagus of C. abdominalis, C. highlandensis, and C. scabrosa to confirm the subgeneric relationship of the species but did not use these traits in his key. Even without further genetic analysis the MTB is so different in terms of morphology, habitat, and seasonality it stands as a full species (Brzoska et al. 2011).

Choate (1984) evaluated the taxonomic status of Cicindela species in Florida and elevated a new species known as the highlands tiger beetle, Cicindela highlandensis) and elevated C. abdominalis scabrosa to species level, thereby changing the name to C. scabrosa. Choate (1984) also combined two other names under the name C. scabrosa; Cicindela extenuata and C. abdominalis floridana, Carwright 1939 (see below section from Choate 1984). By combining these three names under the new species Cicindela scabrosa and developing a detailed taxonomic key, he essentially eliminated the separate variety previously known as C. abdominalis var. floridana, described by Cartwright. Choates taxonomic key is attached as Exhibit A.

The International Commission on Zoological Nomenclature (ICZN) is considered an authority on the naming of species and has rules related to the naming of species and subspecies, followed by scientists. The ICZN has the nomenclature rule, 45.6.4.1., that states as follows, a name that is infrasubspecific under Article 45.6.4 is nevertheless deemed to be subspecific from its original publication if, before 1985, it was either adopted as the valid name of a species or subspecies or was treated as a senior homonym.” The renaming of the species in the Cicindela genus (Choate 1984) was done before 1985 and therefore falls under this rule. Since Choate (1984) renamed several species and combined var. floridana into C. scabrosa prior to 1985, it could be assumed that subspecific status was no longer recognized. Choates key in 1984 did not recognize var. floridana as distinct subspecies or even a variety. In describing the newly elevated C. scabrosa, Choate states This species exhibits little variation. Some specimens are quite greenish (i.e., floridana), but this is interpreted to be a sign of recent emergence. Older specimens appear to have lost the greenish tint. Maculation (Fig. 3) is quite constant.” (Choate 1984 page 77). Importantly, none of the scientific literature cited to in the emergency petition discuss this renaming of the species by Choate, the above statement, or that his key fails to include var. floridana. Instead, the emergency petition cites to one published article in an online journal, Brzoska et al. (2011), which glosses over this aspect of Choates work, while cherry picking other aspects of his work. This fundamental issue on whether the MTB is a valid species or not merits additional careful review by the USFWS.

In subsequent taxonomic keys (2003) used at the University of Florida for identification of tiger beetles of Florida, Choate continued to use Cicindela highlandensis, C. abdominalis and C. scabrosa as distinct species but made no mention again of a var. floridana as a distinct subgroup, variety or subspecies. See Choate (2003) attached as Exhibit B. The emergency petition also fails to address this point.

In his 1984 treatment of the abdominalis group we see that Choate regarded the MTB as examples of recently emerged C. scabrosa hence the exclusion of “floridana” (MTB) from his 2001 manual and 2003 taxonomic key. To this point Choate does not mention even examining Frank Young’s 1934 MTB specimens and wrote all of these papers before any other specimens were available. Choate’s brief coverage of the MTB was not the basis of any significant MTB work and as such we do not cite his work on the matter in the Petition, instead referring to the proper species description paper (Brzoska et al. 2011).

Note: Paul M. Choate was a lecturer in the Entomology and Nematology Department, Cooperative Extension Service, Institute of Food and Agricultural Sciences, University of Florida, Gainesville, FL 32611. Choate was considered the Florida expert on tiger beetle taxonomy.

Choate was an expert on tiger beetles but all of his publications on the subject predate the rediscovery of the MTB.

Barry Knisley, a researcher at Randolph Macom College in Ashland, Virginia, relies on Choates (and Cartwrights) work for his publication and has also been retained by the USFWS to conduct surveys of MTB in Miami-Dade County.

Knisley and his coauthors (Brzoska et al 2011) cite Choate and Cartwright as introductory material only. Brzoska et al (2011) use numerous non-artificial traits to distinguish the Miami tiger beetle as a full species, not a Choate or Cartwright’s previous subspecies status.

The Florida Museum of Entomology, Florida State Collection of Arthropods (FSCA) acknowledges Choate as the definitive expert at the University of Florida and supports Choate (1984, 1990 and 2003) by combining C. extenuata, C. abdominalis var. floridana, and C. abdominalis var. scabrosa into a the new species name of C. (Cicindelidia) scabrosa Schaupp, FL endemic with the range of Florida Counties to include ALA, BRE, BRO, DAD, HIG, IND, LEV, ORA, POL, PUT, SJO, TAY, VOL rare.” (FSCA 2015). If Cicindelidia floridana (Brzoska et al. 2011) was an accepted taxa as a species or subspecies by the entomology community in Florida and Coleoptera experts at the FSCA. The USFWS must consider why it is not listed as such today. Clearly, there are questions remaining about the species status for Cicindelidia floridana (Brzoska et al. 2011). See Excerpts from FSCA (2015) attached as Exhibit C.

Clearly Ram’s lawyer did not read the list; look at the authorship note at the top of the FSCA list: “reviewed and corrected by R.W. Lundgren, June 1995; G.E. Ball, September 1995”  Ram is attempting to use obsolete 19 year old information from an outdated list. The misuse and misattribution of this list is blatantly dishonest.

Florida Natural Areas Inventory (FNAI) has developed a tracking system for the status of rare plants and animals and has two recent names listed for the so-called MTB. FNAI (2009) lists Cicindela scabrosa floridana Miami Tiger Beetle S1 (with no Federal listing status). This appears to combine Choate’s renaming of the species to C. scabrosa but retains the var. floridana name. The reasons for this combination are not clear and require additional review.

Wrong. This reason is perfectly clear; this FNAI list was written before Brzoska et al. was published in 2011! I believe that FNAI workers were aware of the MTB rediscovery early on and this list represents the available information in 2009.

FNAI (2014) lists Cicindelidia floridana Miami Tiger Beetle G1 S1 (with no Federal listing status). FNAI has adopted Brzoska et al. (2011) elevation of the new genus name of Cicindelidia and new species name of floridana for their tracking list. These tracking lists prepared by FNAI are not externally peer-reviewed and do not represent the current status of the science. For the same reasons, these lists should be reviewed by the USFWS.

The FNAI lists follows Brzoska et al. (2011) in the use of Cicindelidia; these differences reflect a minor debate about tiger beetle generic classification and have no impact on the species status of the MTB.

The International Taxonomic Information System (ITIS 2014) lists Cicindela floridana as a valid species name, but it is not clear where this name came from, since it was not published in that form. It appears to represent elevation of species name floridana but not the genus name of Cicindelidia proposed by Brzoska et al. (2011). The ITIS is not a legal authority and makes the following disclaimer. Disclaimer: ITIS taxonomy is based on the latest scientific consensus available, and is provided as a general reference source for interested parties. However, it is not a legal authority for statutory or regulatory purposes. While every effort has been made to provide the most reliable and up-to-date information available, ultimate legal requirements with respect to species are contained in provisions of treaties to which the United States is a party, wildlife statutes, regulations, and any applicable notices that have been published in the Federal Register. For further information on US. legal requirements with respect to protected taxa, please contact the US. Fish and Wildlife Service.”

A case before the ICZN could be filed by the USFWS to clarify the taxonomic status of this variety, subspecies or species that has come to be known as the Miami tiger beetle. It is recommended that this be addressed by USFWS, before listing.

The ITIS list reflects the current correct classification of the MTB from the authoritative Catalogue of Geadephaga (Coleoptera, Adephaga) of America, north of Mexico (which ITIS cites as their source). This peer-reviewed publication recognizes the Miami tiger beetle as a full species in the genus Cicindela (within the subgenus Cicindelidia) Cicindela floridana Cartwright, 1939. This difference from Brzoska (2011) is due to a scholarly debate over the status of several subgenera, particularly Cicindelidia, and not the validity of the species therein (including the MTB). There is no need for ICZN clarification; the naming of the MTB follows accepted practice.

Brzoska (2011) relies on Choates work, but fails to address Choates lack of naming the MTB as a separate species. This merits closer scrutiny before the USFWS accepts the taxonomy of this species as a separate species in reliance of Brzoskas work. Not coincidentally, the Brzoska (2011) article was coauthored by Dr. Knisley. If the Brzoska 2011 article is to be the scientific basis of any listing decision, it should be peer reviewed by another journals editorial committee or the ICZN to determine if its conclusions are robust and use the best available science.

Brozoska et al. (2011) address this specific point in their introduction:

Choate (1984) reviewed the abdominalis group, describing a new species, Cicindela highlandensis Choate, and elevating Cicindela scabrosa Schaupp to species level. In that paper he created “C. s. floridana”, with no mention of types and no other discussion of “floridana” except for his section on variation in C. scabrosa that “some specimens are quite greenish (i.e. floridana)” which he considered to be a possible sign of recent adult emergence. Apparently Choate considered var. floridana as a subspecies of C. scabrosa because both had similar sculpturing on the elytra and dense flattened setae on the pronotum.

The authors of Brzoska et al. (2011) were not involved in the Petition and Ram’s conflation of the respective authors is purposely deceitful.

2. Population Size, Range Distribution, and Critical Habitat are Unknown, making Emergency Listing not Appropriate.

Even assuming arguendo, that the MTB is a distinct species, the surveying to support its status as endangered is incomplete. It is clear based on the FOIA documents that more surveying is needed to determine the status of the MTB, its habitat, its range and distribution. Until such detailed surveying is completed by USFWS, any listing will not be based on sound science and, thus, inappropriate.

The tiger beetle, C. scabrosa (or C. scabrosa var. floridana) may only require sandy soils with abundant prey (ants) which could occur at many sites including airports, cleared fields, transmission line right of ways, military sites with vast open areas, and other non-pine rockland habitats in the Miami-Dade Broward, Palm Beach, and Collier Counties that have sand-pinescrub along the margins of pine flatwoods” in South Florida (Choate 1984) where C. scabrosa is known to inhabit. Areas that fit these descriptions should be surveyed to understand the extent of the population. The Service should not condone listing the MTB as a pretext for pine rocklands protection. MTB species status is an artificial distinction not supported by Science.

Contrary to Ram’s claims there have been rigorous surveys (commissioned by and submitted to the USFWS):

Extensive surveys were conducted in both scrub habitats and most of the pine rockland sites in Miami-Dade, Ft. Lauderdale and Palm Beach Counties (Knisley, 2008). Most were unsuitable probably because they were too densely vegetated or the substrates were mostly oolitic limestone rock with few or no sand patches (Knisley et al. 2014).

Ram’s lawyer has either not read the existing research on the Miami tiger beetle or is purposefully omitting the relevant data to further their own goals. Again, the MTB’s status as a full species is settled.

Pine rocklands need no pretext for protection; this habitat is critically endangered with only 1.8% of the historic habitat remaining outside of the ENP. A whole variety of endemic species live in this habitat and are found nowhere else, including the Miami tiger beetle.

USFWS own expert admits that surveying is incomplete but then implies that more surveying could yield data demonstrating the species is not rare. (See Email dated March 14, 2014 Subject: RE: Request for information on the Miami tiger beetle” attached as Exhibit D, stating, Also, pretty certain that finding it MTB in a few other locales would change its extreme rarity.) Not only does this demonstrate that the USFWS may not have sufficient information to declare the MTB as endangered, it hints at manipulation of the existing data to favor a decision towards listing. Both are concerning and require USFWS review. As the USFWS is aware, a species shall be listed only when it is demonstrated that it is in danger of extinction in all or a significant of portion of its range.” The documents suggest that the proponents of the listing are deliberately defining species range narrowly in order to justify listing. The reality is that tiger beetles may have a much wider range and may be prevalent across Southern Florida.

Dr. Knisley’s comments represent an abundance of caution and optimism as the context of this email shows; however, for all of the optimism in this message he concludes otherwise in Knisley et al. 2014:

Both C. tranquebarica joaquinensis and Ci. floridana [MTB] have been extensively surveyed to confirm their very limited distribution, small populations and currently existing threats to their survival. Consequently, we recommend these two taxa should be immediately considered for listing by the USFWS.

Entomologists and ecologists have employed numerous techniques for the sampling of insect communities but standardized detection methods for tiger beetle have not been proposed for screening of presence/absence to identify population distribution. Survey methodologies are also lacking for establishing population sizes of tiger beetle species when they are known to be present. Survey time frames, temperature min/max, weather conditions, and a minimum or optimum level of effort is also needed to standardize any Survey protocols. Survey methodologies should developed prior to any listing decision.

False; tiger beetle activity is predictable and well described in the literature (summarized in Knisley and Shultz 1997, Pearson et al. 2006). The methods used in the MTB surveys are described and consistent with protocols employed in other endangered/threatened tiger beetle species surveys (Knisley 2011; Knisley et al 2014).

3. Coral Reef Commons Site is Not Suitable Habitat for MTB and No Beetles Exist on

The emergency petition for listing states that the CRC is used by MTB. There was no citation or reference to any studies or information on how petitioners scientifically Supported such statement. We now know that no science exists to support these statements. In fact, the opposite is true.

Our claim is that the site, which is almost 50% pine rocklands, is a possible habitat for the MTB and if present that “[b]oth [the CRC and Miami Wilds] developments would directly destroy occupied habitat and impact adjacent occupied habitat by limiting burns and other flora management efforts.”We even include a map of known MTB sites which clearly illustrates that MTBs have yet to be found on CRC site (however there have been no comprehensive surveys of the area) :

MTB Locations

The USFWS has commissioned Dr. Knisley to conduct surveying in the Richmond pine rockland area. Those surveys included the CRC property. Knisley documented his findings in a report dated April 10, 2013. That report was submitted to the USFWS on April 13, 2013. See Exhibits E and F attaching Knisleys 2013 report and the email conveying same to USFWS staff).

The report concludes that no MTB was found on the CRC property and that CRC is not suitable habitat for the MTB because overgrowth of vegetation. Petitioners disregard this information and instead chose to make unsupported statements in their emergency petition. Their collective disregard for this information calls into question the credibility of any of the scientific positions they make in the petition.

As we note in the Petition no MTBs have yet been found on the CRC site. There have been no comprehensive surveys of this area. Knisley’s single survey focused on the area immediately west of the Zoo Miami entrance road and did not cover a significant portion of the property (at most only 12% to 18%). This is not sufficient survey data to conclude the MTB is absent and Ram’s extrapolation that the whole site is unsuitable is scientifically unfounded.

The above summary depicts serious concerns regarding the listing the MTB and petitioners’ manipulation of the science to force an emergency listing when no emergency exists. Certainly, the science on the MTB is unsettled and merits more review. The attempt to couch the CRC property as the last vestiges of MTB habitat is simply false. The FOIA documents reveal petitioners true intent to stop the CRC development and a willingness to overlook scientific data gaps to declare the MTB as endangered.

For all of these reasons, Coral Reef Owners respectfully request that the USFWS deny the emergency listing and hold species status pending further analysis and peer review.

A single deeply concerning point stands out in the Ram’s first and second letters: a systemic misrepresentation of the science, both by spurious references and by omission of fact. This conduct is not acceptable.

Ram’s protestations of inadequate science are an obvious attempt to delay the listing evaluation of the Miami tiger beetle. I trust USFWS will look at the available science and extend a significant level of protection to the MTB.As for the Coral Reef Commons site; the solution is not to develop over two-thirds of the area and its pine rocklands. Under one-eighth of the Coral Reef Commons site is presently developed. Perhaps there is a more appropriate use for this rare habitat than yet more development, which can be moved elsewhere in the county at no loss of revenue to Ram Realty. Over 98% of the Pine rocklands (outside the ENP) have been destroyed, like the type locality for the Miami tiger beetle (image from Google Earth):2014 typeLet’s restore and preserve the seven-eighths of the CRC property that is undeveloped and constructively use or mitigate the fraction of the property that is already developed. Pine rocklands are a unique and valuable part of Florida’s natural history and are worth preserving.
The greatest destruction of natural environments anywhere in the state has taken place in this area and is particularly deplorable because the region seems to have been a center of distribution for a number of other organisms as well as the tree snails. (Frank Young, discoverer of the MTB)

RIchmond Heights pine rocklands 2014

Above: The Richmond Heights pine rocklands in 2014 (from Google Earth)

It is fashionable in some quarters to wave aside the small and obscure, the bugs and weeds, forgetting that an obscure moth from Latin America saved Australia’s pastureland from overgrowth by cactus, that the rosy periwinkle provided the cure for Hodgkin’s disease and childhood lymphocytic leukemia, that the bark of the Pacific yew offers hope for victims of ovarian and breast cancer, that a chemical from the saliva of leeches dissolves blood clots during surgery, and so on down a roster already grown long and illustrious despite the limited research addressed to it. (The Diversity of Life by Edward O. Wilson)

References

Bousquet, Y. 2012. Catalogue of Geadephaga (Coleoptera, Adephaga) of America, north of Mexico. ZooKeys 245. 1722 pp.

Brzoska, D., C.B. Knisley, and J. Slotten. 2011. Rediscovery of Cicindela scabrosa floridanaCartwright and its elevation to species level. Insect Mundi 162: 1-7.

Cartwright, O.L. 1939. Eleven new American Coleoptera (Scarabidae, Cicindelidae). Annals of the Entomological Society of America 32:353-364.

Choate, P.M. 1984. A new species of Cicindela Linnaeus (Coleoptera: Cicindelidae) from Florida, and elevation of C. abdominalis scabrosa Schaupp to species level. Entomological News 95: 73-82.

Franzen, M. and W. Heinz. 2005. Morphology, genitalia, and natural history notes on the enigmatic tiger beetle, Mantica horni Kolbe, 1896 (Coleoptera, Cicindelidae). Bonner zoologische Beiträge 53: 297-301

Knisley, C. B. 2008. Current status of the “Miami Tiger Beetle” (Cicindela floridana). Final Report: South Florida Ecological Services Office, Vero Beach, FL

Knisley, C.B. 2011. Taxonomy, Biology, and Conservation of the Florida Tiger Beetle, Cicindela Floridiana, report to South Florida Ecological Services Office.

Knisley, C.B. and C. Gowan. 2008. Biology and Conservation of the Coral Pink Sand Dunes Tiger Beetle, Cicindela albissima: Part I: Year 2008 Results and previous years, Part II: Population Viability Analysis of C. albissima and implications for management. Report to Bureau of Land Management. 23 pp.

Knisley, C., M. Kippenhan, and D. Brzoska. 2014. Conservation status of United States tiger beetles. Terrestrial Arthropod Reviews. 7: 93-145.

Knisley, C. B. and T. D. Schultz. 1997. The Biology of Tiger Beetles and a Guide to the Species of the South Atlantic States. Virginia Museum of Natural History, Martinsville. 260 pp.

Knisley, C.B. and C.C. Wirth. 2013. Biological Studies of the Florida Tiger Beetle, Cicindela floridana, 2011-2013: Final Report. Report to the U.S. Fish and Wildlife Service, South Florida Ecological Services Office. 13pp.

Pearson, D. L., C. B. Knisley and C. J. Kazilek. 2006. A field guide to the tiger beetles of the United States and Canada. Oxford University Press, New York.

Ram Realty. 2015. Habitat Conservation Plan for Coral Reef Commons. Available through the Miami Herald.

URS Corporation, The Institute for Regional Conservation, and Muller and Associates, Inc. 2007. Miami Dade County Environmentally Endangered Lands Program Management Plan, Part II: Management of specific habitat types, Chapter 1: The pine rockland habitat. Submitted to Environmentally Endangered Lands Program, Miami, Florida by URS Corporation. K.A. Bradley, G.D. Gann, M.J. Barry, contributors.

Wilson, E. O. 1992. The Diversity of Life. Cambridge, Massachusetts: Belknap.

Young, F. N. 1951. Vanishing and extinct colonies of tree snails, Liguus fasciatus, in the vicinity of Miami, Florida. Occasional Papers of the Museum of Zoology, University of Michigan. 531: 21 p.

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