[Federal Register: April 27, 2010 (Volume 75, Number 80)]
[Rules and Regulations]               
[Page 22012-22025]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]



Fish and Wildlife Service

50 CFR Part 17

[Docket No. FWS-R6-ES-2009-0025]
[MO 92210-0-0008]

Endangered and Threatened Wildlife and Plants; 12-Month Finding 
on a Petition to List Susan's Purse-making Caddisfly (Ochrotrichia 
susanae) as Threatened or Endangered

AGENCY: Fish and Wildlife Service, Interior.

ACTION: Notice of 12-month petition finding.


SUMMARY: We, the U.S. Fish and Wildlife Service (Service), announce a 
12-month finding on a petition to list Susan's purse-making caddisfly 
(Ochrotrichia susanae) as endangered and to designate critical habitat 
under the Endangered Species Act of 1973, as amended. After review of 
all available scientific and commercial information, we find that 
listing Susan's purse-making caddisfly is not warranted at this time. 
However, we ask the public to submit to us any new information that 
becomes available concerning the threats to the Susan's purse-making 
caddisfly or its habitat at any time.

DATES: The finding announced in this document was made on April 27, 

ADDRESSES: This finding is available on the internet at http://
www.regulations.gov at docket number FWS-R6-ES-2009-0025. Supporting 
documentation we used in preparing this finding is available for public 
inspection, by appointment, during normal business hours at the U.S. 
Fish and Wildlife Service, Western Colorado Field Office, 764 Horizon 
Drive, Building B, Grand Junction, CO 81506. Please submit any new 
information, materials, comments, or questions concerning this finding 
to the above street address.

FOR FURTHER INFORMATION CONTACT: Patricia S. Gelatt, Supervisor, 
Western Colorado Field Office, (see ADDRESSES); by telephone (970-243-
2778, extension 26); or by facsimile (970-245-6933). Persons who use a 
telecommunications device for the deaf (TDD) may call the Federal 
Information Relay Service (FIRS) at 800-877-8339.



    Section 4(b)(3)(B) of the Endangered Species Act of 1973, as 
amended (Act) (16 U.S.C. 1531 et seq.), requires that, for any petition 
to revise the Federal Lists of Endangered and Threatened Wildlife and 
Plants that contains substantial scientific or commercial information 
that listing the species may be warranted, we make a finding within 12 
months of the date of receipt of the petition. In this finding, we will 
determine that the petitioned action is: (1) Not warranted, (2) 
warranted, or (3)

[[Page 22013]]

warranted, but the immediate proposal of a regulation implementing the 
petitioned action is precluded by other pending proposals to determine 
whether species are threatened or endangered, and expeditious progress 
is being made to add or remove qualified species from the Federal Lists 
of Endangered and Threatened Wildlife and Plants. Section 4(b)(3)(C) of 
the Act requires that we treat a petition for which the requested 
action is found to be warranted but precluded as though resubmitted on 
the date of such finding, that is, requiring a subsequent finding to be 
made within 12 months. We must publish these 12-month findings in the 
Federal Register.

Previous Federal Action

    On July 8, 2008, we received a petition via e-mail from the Xerces 
Society for Invertebrate Conservation, Dr. Boris C. Kondratieff 
(Colorado State University), Western Watersheds Project, WildEarth 
Guardians, and Center for Native Ecosystems requesting that we list 
Susan's purse-making caddisfly as endangered under the Act and 
designate critical habitat. The petition included supporting 
information regarding the species' description, taxonomy, historical 
and current distribution, present status, habitat requirements, and 
potential threats. We acknowledged the receipt of the petition in a 
letter to the petitioners dated August 5, 2008. In the letter, we 
stated that we determined an emergency listing was not necessary. We 
also stated that, due to court orders and settlement agreements for 
other listing and critical habitat actions, all of our fiscal year 2008 
listing funds had been allocated and that further work on the petition 
would not take place until fiscal year 2009.
    Funding became available in fiscal year 2009, and we began work on 
the 90-day finding in November 2008. The 90-day finding was published 
in the Federal Register on July 8, 2009 (74 FR 32514). This notice 
constitutes the 12-month finding on the July 8, 2008, petition to list 
Susan's purse-making caddisfly as endangered.

Species Information

Species Description
    Susan's purse-making caddisfly is a small, hairy, brown caddisfly 
in the family Hydroptilidae under the Order Trichoptera. Most of its 
life is spent as an aquatic larva in spring and nearby stream habitats. 
Adults have forewings 2 millimeters (mm) (0.08 inch (in.)) long. The 
wings are dark brown with three transverse silver bands, one each at 
the wing base, the midline, and the apex (Flint and Herrmann 1976, p. 
    The larvae of Hydroptilidae are unusual among the case-making 
families of Trichoptera in that they are free-living until the final 
(fifth) larval instar (developmental stage between molts) (Wiggins 
1996, p. 72). When the larvae molt to the fifth instar, they develop 
enlarged abdomens, build purse-shaped cases from silk and sand, and 
become less active (Wiggins 1996, p. 71). They construct a case that 
can be portable or cemented to the substrate (Wiggins 1996, p. 71). 
Larvae in this family are very small but can reach up to 6 mm (0.3 in.) 
in length (Wiggins 1996, p. 71). The head and the dorsal surface (top) 
of all three thoracic segments are dark brown and sclerotized 
(hardened) (Flint and Herrmann 1976, p. 894). Larval cases are small, 
flattened, bivalved, and open at each end, similar to other members of 
the genus Ochrotrichia. However, Susan's purse-making caddisfly larval 
cases are slightly shorter proportionally and are made from smaller 
grains of sand (Flint and Herrmann 1976, p. 894). The larvae eventually 
pupate (metamorphose from a larvae to an adult) within the case.
    Feeding behavior of Susan's purse-making caddisfly larvae has not 
been observed directly, but larvae in this genus generally feed by 
scraping diatoms from rocks (Wiggins 1996, p. 96), and larvae in the 
Hydroptilidae have been described as eating the cellular content of 
algae (Vieira and Kondratieff 2004, p. 47). Where the species has been 
collected, rocks that were thickly covered with larval cases were 
associated with heavy growth of filamentous algae and moss (Flint and 
Herrmann 1976, p. 897).
    Adult Trichoptera have reduced mouthparts and lack mandibles, but 
can ingest liquids. The adult flight period is estimated to be from 
late June to early August (Flint and Herrmann 1976, p. 897), although 
Herrmann et al. (1986, p. 433) stated that adults were collected from 
mid-April to late July. The specific life cycle of Susan's purse-making 
caddisfly is not known (Kondratieff 2009a, pers. comm.; Ruiter 2009a, 
pers. comm.). They are thought to produce one generation per year 
(Flint and Herrmann 1976, p. 897). After emerging from their pupal 
cases, they will mate and lay eggs in the water (Myers 2010, pers. 
comm.) and most likely only live for a week or two as adults. It is not 
known how long it takes for Susan's purse-making caddisfly eggs to 
develop into larvae, how long each larval stage lasts, or how long they 
are in the pupal state.
    Susan's purse-making caddisfly was first described as Ochrotrichia 
susanae by Flint and Herrmann (1976, pp. 894-898) from specimens 
collected in 1974 at Trout Creek in Chaffee County, Colorado. The genus 
Ochrotrichia is widespread and fairly diverse in North America, with 
over 50 described species (Wiggins 1996, p. 96). Adults can be 
distinguished from other species in the genus Ochrotrichia based on 
characteristics of the genitalia. No challenges to the taxonomy have 
arisen since the species was named. We find that Flint and Hermann 
(1976, pp. 894-898) provide the best available information on the 
taxonomy of Ochrotrichia susanae. Therefore, we consider the Susan's 
purse-making caddisfly a valid species for listing under the Act.
Historic and Current Distribution
    Susan's purse-making caddisfly has only been historically 
documented from three sites: (1) Trout Creek Spring in Chaffee County, 
Colorado; (2) High Creek Fen in Park County, Colorado; and (3) 
Jaramillo Creek in Valles Caldera, New Mexico. Based on the best 
available information, we consider all three locations to be extant, as 
described in more detail below.
    From 1974 to 1994, Susan's purse-making caddisfly was only known to 
exist at and below Trout Creek Spring on U.S. Forest Service (USFS) 
land (Pike-San Isabel National Forest) in Chaffee County, Colorado 
(Herrmann et al. 1986, p. 433). Larvae, pupae, and adults were 
collected at the spring outfall area and downstream in Trout Creek at 
the Highway 285 Bridge, about 130 meters (m) (430 feet (ft)) away from 
the spring. Multiple collection attempts below the Highway 285 Bridge 
have not resulted in the caddisfly being found. There is no known 
reason for lack of occurrence downstream of the bridge (Herrmann 2010, 
pers. comm.). The spring and downstream stretch of creek habitat will 
hereafter simply be called Trout Creek Spring unless specific areas are 
mentioned. Trout Creek Spring is at an elevation of about 2,750 m 
(9,020 ft). The last known observation of the caddisfly at Trout Creek 
Spring was by one of the co-authors of the species description, Dr. 
Scott Herrmann, in 2007 (Herrmann 2009a, pers. comm.). We 
unsuccessfully attempted to relocate the species at this location at 
the end of July 2009; however, survey conditions were poor (Ireland 
2009, p. 2). Based on the long-term history of occupancy and the poor 
survey conditions at our last

[[Page 22014]]

site visit, we consider the Trout Creek Spring site to still be 
    In 1995, Susan's purse-making caddisfly specimens were discovered 
and collected at High Creek Fen in Park County, Colorado, about 27 
kilometers (km) (17 miles (mi)) north of the previously known locality 
(Durfee and Polonsky 1995, pp. 1, 5, 7). High Creek Fen is a unique 
groundwater-fed wetland with high ecological diversity. It is 
considered a rare type of habitat and the southernmost example of this 
unique habitat in North America (Cooper 1996, pp. 1801, 1808; Rocchio 
2005, p. 10; Legg 2007, p. 1). High Creek Fen is primarily owned by The 
Nature Conservancy (TNC) and the Colorado State Land Board (CSLB), as 
well as private landowners. The fen is about 2,980 m (9,320 ft) in 
elevation. Susan's purse-making caddisfly pupae were found at High 
Creek Fen on July 29, 2009, during a site visit in conjunction with the 
Trout Creek Spring site visit (Ireland 2009, p. 1). A subsequent visit 
to High Creek Fen on August 11, 2009, resulted in capture of an adult 
Susan's purse-making caddisfly (Ruiter 2009b, pers. comm.).
    In July 2008, an adult Susan's purse-making caddisfly was 
discovered near Jaramillo Creek within the Valles Caldera National 
Preserve (VCNP) west of Los Alamos, New Mexico (Flint 2009a, pers. 
comm.). The Preserve is owned by the U.S. Department of Agriculture 
(part of the National Forest System) but run by a nine member Board of 
Trustees; the Supervisor of Bandelier National Monument, the Supervisor 
of the Santa Fe National Forest, and seven other members with distinct 
areas of experience or activity appointed by the President of the 
United States (Valles Caldera Trust 2003, pp. 46-47). Dr. Oliver Flint, 
one of the co-authors of the species' description, identified the 
caddisfly collected from VCNP. The elevation of the capture area is 
approximately 2,750 m (8,600 ft). No larvae were discovered at the 
Jaramillo Creek site, so we do not know if the adult caddisfly 
represents a breeding population. If there is a breeding population in 
VCNP, it is unknown how close the adult was to its larval habitat and 
whether larvae are occupying a spring near Jaramillo Creek, Jaramillo 
Creek only, or a spring or creek in a nearby drainage. Adults are 
thought to be weak fliers, likely only flying 1 to 2 m (3 to 7 ft) when 
disturbed. They are thought to remain close to larval habitat for 
mating and oviposition (Xerces Society et al. 2008, pp. 6-7). 
Therefore, dispersal distance is thought to be very small (Xerces 
Society et al. 2008, pp. 6-7). This suggests that larval habitat was 
close to the adult capture site on Jaramillo Creek, but larval or pupal 
surveys specific to Susan's purse-making caddisfly have not been 
conducted on Jaramillo Creek or in VCNP. The postulated small dispersal 
distance also suggests that the population in VCNP is isolated from the 
populations in Colorado, and that the populations within Colorado are 
isolated from one another (Xerces Society et al. 2008, pp. 5, 12, 15). 
It is possible that incidental dispersal via wind or adhesion to 
animals or humans could occur, but neither dispersal method has been 
documented, and dispersal is likely uncommon (Kondratieff 2010, pers. 
    The Service recognizes that only three populations of Susan's 
purse-making caddisfly have been found since the species' discovery in 
1974 (Flint and Herrmann 1976), and they are undoubtedly rare. In 1986, 
Herrmann et al. compiled a list of records for Susan's purse-making 
caddisfly, but this was only based on existing records and not the 
result of comprehensive field surveys. Despite the probable rarity, we 
believe additional populations may exist based on the following: (1) 
surveys have not encompassed all potential spring habitats in Colorado 
and New Mexico (Herrmann 2010, pers. comm.; Jacobi 2009, pers. comm.; 
Kondratieff 2010, pers. comm.; Ruiter 2010, pers. comm.); (2) it is 
particularly likely that potential spring habitats occurring on private 
land have not been surveyed (Kondratieff 2010, pers. comm.); (3) the 
caddisfly can only be identified at the pupal and adult stages so the 
species could easily be missed if surveys take place outside of the 
period from mid-June to early August (Flint and Herrmann 1976); (4) the 
adults are very small, only live for a week or two, and may not fly if 
conditions are too cold or windy, again causing surveyors to miss them; 
and (5) general surveys of aquatic species (not focusing on this 
particular species) may simply miss either pupae or adults due to low 
population size.
    Susan's purse-making caddisfly has a Global Heritage Status Rank of 
G2, a National Status Rank of N2, and a Colorado State Rank of S2 
(NatureServe 2008, pp. 1-4). NatureServe defines the G2 rank as 
signifying that a species is imperiled (at a high risk of extinction) 
globally due to a very restricted range, very few populations, steep 
population declines, or other factors. Species in these categories are 
defined as vulnerable to extirpation nationally or within a State or 
province. Only the Trout Creek Spring site is on file with NatureServe 
(2008, p. 1), but if High Creek Fen and Jaramillo Creek were added the 
rank would not change, since the NatureServe ranking system of G2 and 
N2 allows for 20 or fewer populations (NatureServe 2009, pp. 4, 7). No 
population estimate exists for the caddisfly at Trout Creek Spring, but 
Flint and Herrmann (1976, p. 898) collected 237 adults on July 1, 1975, 
and 118 adults on July 20, 1975. No adults were present during an 
August 5, 1975, collection attempt at Trout Creek Spring (Flint and 
Herrmann 1976, p. 898). Similarly, no extensive collection or 
population size estimate has been made for either High Creek Fen or 
Jaramillo Creek.
Habitat Requirements
    Larval and adult Susan's purse-making caddisflies are found in and 
around spring and stream habitat (Flint and Herrmann 1976, p. 897). 
Larvae inhabit waters that are cold, hard, well-oxygenated, highly 
buffered, and extremely low in trace metals (Flint and Herrmann 1976, 
p. 897). Adult riparian habitat preferences, if they exist, are unknown 
(Kondratieff 2009b, pers. comm.; Ruiter 2009c, pers. comm.). Since the 
adults only live for a week or two, it is possible that a specific 
vegetation type is not important to them. The riparian habitats 
adjacent to the streams at Trout Creek Spring and High Creek Fen are 
quite different from each other in both species present and vegetative 
structure (Ireland 2009, pp. 1-2), suggesting a lack of vegetation 
preference. However, riparian vegetation of some sort is likely 
beneficial for adult shelter and survival (Kondratieff 2009b, pers. 
comm.; Ruiter 2009c, pers. comm.).
    After emerging from their pupal cases as adults, females will mate 
and lay eggs in the water (Myers 2010, pers. comm.). Caddisflies 
typically lay eggs on immobile rocks, gravel, rooted vegetation, or 
anchored wood that will reduce movement of the eggs and, hence, reduce 
chances of abrasion or burial of the eggs by sediment (Myers 2010, 
pers. comm.). Specific information on substrate used for egg-laying by 
Susan's purse-making caddisfly is not available.
    Physical and chemical conditions of Trout Creek Spring were 
assessed in 1975 (Flint and Herrmann 1976, pp. 894-897). Water 
temperatures in the spring habitat were cold and varied little (14.4 to 
15.8 \o\C (57.9 to 60.4 \o\F)). Stream conditions included extremely 
high levels of dissolved oxygen (at or near 100-percent saturation), as 
well as high concentrations of dissolved calcium (Ca), magnesium (Mg), 

[[Page 22015]]

sulfate (SO4) (see Table 1 below), which gave the water a 
higher electrical conductance value than typically seen in most 
regional streams at the same elevation (Flint and Herrmann 1976, p. 
897). Conductivity is a measure of the level of salts in water as a 
result of elements such as calcium and magnesium. In 2009, temperature, 
pH, and total alkalinity were within the range of samples analyzed in 
1975 (Herrmann 2009b, pers. comm.). Analysis of additional water 
chemistry variables has not been completed.
    Water quality samples were taken in 1995 at High Creek Fen by 
Durfee and Polonsky (1995) and on undisclosed dates by Cooper (1996). 
High Creek Fen appears to have similar water quality characteristics 
(see Table 1 below) as Trout Creek Spring (Durfee and Polonsky 1995, p. 
5 and Table 2; Cooper 1996, pp. 1801, 1803). Water samples in Jaramillo 
Creek were taken in 2005 (Brooks 2009). The range of pH in Jaramillo 
Creek and a nearby spring is similar to the other two sites (see Table 
1 below). The conductivity was lower than Trout Creek Spring or High 
Creek Fen (Brooks 2009), indicating there are less salts in the water 
at VCNP.
    Trout Creek Spring values in Table 1 incorporate the range for both 
the spring proper and samples taken in the creek down to the Highway 
285 Bridge (Flint and Herrmann 1976, p. 897). High Creek Fen samples 
incorporate a range from three water sources feeding the fen (Cooper 
1996, p. 1803). Jaramillo Creek sample values include both the creek 
and a nearby spring location (Brooks 2009).

                          Table 1. Physio-chemical properties of water at Susan's purse-making caddisfly locations (Brooks 2009; Cooper 1996; Flint and Herrmann 1976).
              SITE                        pH             ([micro]S/cm)         Ca(mg/l)            Mg(mg/l)            Na(mg/l)             K(mg/l)            SO4(mg/l)           Cl(mg/l)
Trout Creek Spring                7.2-8.2             280-400             38-52               14-21               2.1-5.3             0.4-1.32            19-59               1.5-2.2
High Creek Fen                    7.8-8.1             420-2558            55-93               30-98               8.4-25.4            0.8-2.7             34.7-815.4          4.6-42.6
VCNP                              6.6-8.0             61-76                                                                                               3.1-3.9             0.3-1.5

    Flint and Herrmann (1976, p. 897) state that conductance was 
directly related to calcium, magnesium, and sulfate concentrations. 
This conclusion appears logical, as High Creek Fen also had high 
concentrations of these elements and an even higher range of 
conductance than Trout Creek. Jaramillo Creek had low sulfate and low 
conductance compared to the other two locations (see Table 1 above). 
This outcome may suggest that calcium and magnesium levels were low as 
well, but actual levels were not analyzed. Since only an adult 
caddisfly was caught near Jaramillo Creek and we do not know if it came 
from the creek near the capture site, a nearby spring, or elsewhere, we 
do not know if the low conductance and sulfate (SO4) and 
chloride (Cl) values represent a lower range that Susan's purse-making 
caddisfly larvae and pupae can survive in.
    Temperature, pH, dissolved oxygen, total dissolved solids, and 
conductivity probably have the greatest influence on distribution of 
the caddisfly (Myers 2009, pers. comm.). Only pH and conductivity were 
measured at all three sites, and total dissolved solids were not 
analyzed at any of the three locations. We do not know if the caddisfly 
prefers springs with higher conductivity. Both Trout Creek Spring and 
High Creek Fen, where both larvae and pupae have been identified, have 
high conductivity. However, Jaramillo Creek has relatively low 
conductivity. Consequently, a range of conductivity levels may be 
suitable for Susan's purse-making caddisfly, and, therefore, more 
springs may be available for occupancy. However, as Myers (2009, pers. 
comm.) mentions, factors other than conductivity may be influencing 
habitat occupancy by Susan's purse-making caddisfly. With only three 
locations and scant available data, the range of habitat Susan's purse-
making caddisfly can live in remains unknown, but the best available 
information suggests that the water quality will be similar to the 
range of variables analyzed in the Trout Creek Spring and High Creek 
Fen areas.
    Larval and pupal Susan's purse-making caddisfly were collected at 
Trout Creek Spring in 1974 and 1975 (Flint and Herrmann 1976). Larvae 
and pupae primarily inhabited the sides of rocks in both the spring 
outfall and downstream locations. Concentrations of caddisflies were 
found in areas directly below small waterfalls and were often clustered 
in clumps that covered the rocks (Flint and Herrmann 1976, pp. 894-
897). During a 2009 site visit, concerns were raised that Trout Creek 
Spring may be impacted by poor water quality because of large amounts 
of filamentous algae in Trout Creek (Xerces Society 2009, p. 2). 
However, during earlier collections, larval and pupal cases were often 
found on the same rocks that had thick growths of moss and filamentous 
algae (Flint and Herrmann 1976, p. 897). Additionally, temperature, pH, 
and total alkalinity in 2009 were within the range of samples analyzed 
in 1975, indicating that the water quality at Trout Creek Spring has 
remained the same in these respects since 1975 (Herrmann 2009b, pers. 

Summary of Information Pertaining to the Five Factors

    Section 4 of the Act and its implementing regulations (50 CFR 424) 
set forth procedures for adding species to, removing species from, or 
reclassifying species on the Federal Lists of Endangered and Threatened 
Wildlife and Plants. Under section 4(a)(1) of the Act, a species may be 
determined to be endangered or threatened based on any of the following 
five factors: (A) The present or threatened destruction, modification, 
or curtailment of its habitat or range; (B) overutilization for 
commercial, recreational, scientific, or educational purposes; (C) 
disease or predation; (D) the inadequacy of existing regulatory 
mechanisms; or (E) other natural or manmade factors affecting its 
continued existence. In making this finding, information pertaining to 
Susan's purse-making caddisfly in relation to the five factors provided 
in section 4(a)(1) of the Act is discussed below. In making our 12-
month finding, we considered and evaluated the best available 
scientific and commercial information.

[[Page 22016]]

A. The Present or Threatened Destruction, Modification, or Curtailment 
of the Species' Habitat or Range

Livestock Grazing
    Susan's purse-making caddisfly appears to require cold and well-
oxygenated water (Flint and Herrmann 1976, p. 897). The species could 
be negatively impacted by decreased riparian vegetation, stream bank 
destabilization, and increases in water temperature if livestock 
grazing is not well managed. Intensive grazing may lead to erosion due 
to removal of riparian and upland vegetation, removal of soil litter, 
increased soil compaction via trampling, and increased area of bare 
ground (Schulz and Leininger 1990, pp. 297-298; Fleischner 1994, pp. 
631-636). Bare, compacted soils allow less water infiltration, which 
generates more surface runoff and can contribute to erosion as well as 
flooding and stream bank alterations (Abdel-Magid et al. 1987, pp. 304-
305; Orodho et al. 1990, pp. 9-11; Chaney et al. 1993, pp. 8-15). 
Increased erosion leads to higher sediment loads in nearby waters, 
which can degrade in-stream and riparian habitat and increase water 
turbidity. The more turbid the water, the more sediment it is carrying. 
Sediment can affect the caddisfly by reducing respiration ability; 
smothering eggs, larvae, and pupae; reducing forage for the larvae; and 
limiting suitable sites for egg laying (Myers 2010, pers. comm.).
    The combined impacts of vegetation loss, soil compaction, stream 
bank destabilization, and increased sedimentation associated with 
intensive livestock grazing can have a profound effect on aquatic 
macroinvertebrates. One study found a dramatic decline in 
macroinvertebrate abundance and species richness for some taxa, 
including caddisflies, on grazed versus ungrazed sites in Oregon 
(McIver and McInnis 2007, pp. 293, 300-301). A variety of aquatic 
macroinvertebrate community attributes relating to taxa diversity, 
community balance, trophic status (what level an animal is on the food 
chain), and pollution tolerance were negatively impacted by moderate or 
heavy grazing in small mountain streams in Virginia, compared to 
lightly grazed or ungrazed control areas (Braccia and Voshell 2007, pp. 
    In 2008, the USFS issued an environmental assessment (EA) for 
Rangeland Allotment Management Planning in the Salida-Leadville 
Planning Area (USFS 2008a) that covers about 115,000 hectares (ha) 
(284,000 acres (ac)) around Trout Creek Spring. Trout Creek Spring is 
in the extreme uppermost portion of a finger of a grazing allotment 
(the Fourmile Allotment) on the Pike-San Isabel National Forest (USFS 
2008a, Appendix 1, p. 1). The majority of the allotment does not 
influence the Trout Creek Spring habitat. No grazing from cattle on the 
Fourmile Allotment occurs around the caddisfly's habitat in Trout Creek 
Spring because the only place where cattle could access the spring, the 
western bank from County Road 309, is steep (Gaines 2009a, pers. comm.; 
USFS 2009, p. 5).
    The Bassam Allotment is immediately downstream of the Fourmile 
Allotment. The allotment ends at the Highway 285 Bridge, and livestock 
cannot go upstream due to a fence at the allotment boundary (USFS 
2008a, Appendix 1 Bassam C&H Range Improvements, p. 1). Cattle can 
access the area below the bridge but rarely do (USFS 2010, p. 1). 
Grazing impacts could affect Susan's purse-making caddisfly habitat 
downstream of the bridge if the species historically occurred down 
there, but it has never been collected downstream of the bridge 
(Herrmann 2010, pers. comm.). Consequently, grazing on the Bassam 
Allotment is not currently known to impact the caddisfly or its 
    The Chubb Park Allotment lies immediately upstream of Trout Creek 
Spring. The cattle on the Chubb Park Allotment cannot get to Trout 
Creek Spring because of allotment fences and cattle guards (USFS 2009, 
p. 5). Consequently, direct impacts to the caddisfly and its habitat do 
not occur from cattle on the Chubb Park Allotment. However, grazing in 
this allotment in the upper portion of the Trout Creek drainage has the 
potential to impact the caddisfly's habitat downstream through 
vegetation removal, erosion, and subsequent downstream sedimentation in 
the caddisfly habitat. The Trout Creek drainage becomes ephemeral 
within 300 m (984 ft) above Trout Creek Spring (Flint and Herrmann 
1976, p. 895; USFS 2009, p. 5), and may occasionally run during spring 
snowmelt or large thunderstorms (Ireland 2009, p. 2). These irregular 
seasonal flows in combination with increased vegetation and recently 
implemented improvements in grazing management (as discussed below) 
likely reduce the amount of sediment reaching the caddisfly habitat. 
However, we are not aware of any measurements of sediment deposition in 
the Trout Creek Spring habitat.
    The Chubb Park Allotment has split ownership between the USFS, 
CSLB, and private lands, with roughly three-quarters in USFS ownership 
(USFS 2008a, p. 53). From 1996 through 2008, 146 total cow/calf pairs 
were permitted on the Chubb Park Allotment for 153 days or 983 Animal 
Unit Months (AUMs) (USFS 2009, p. 6; USFS 2010, p. 1). In 2009, the 
USFS and CSLB reduced the AUMs by shortening the grazing period to 41 
days and allowing 410 cow/calf pairs to graze for a new total of 740 
AUMs (USFS 2009, p. 6). The private landowner elected to not graze due 
to drought and, along with the USFS and CSLB, rested the Chubb Park 
Allotment for 5 years from 2003-2007 (USFS 2010, p. 1). An electric 
fence erected for 8 km (5 mi) along Trout Creek upstream of the spring 
prior to the 2009 grazing season now prevents cattle from accessing 
this stretch of Trout Creek (USFS 2009, p. 5). However, the USFS may 
adjust the fence as they determine appropriate to meet the desired 
conditions (USFS 2010, p. 2). Currently all the pastures in the 
allotment are moving toward or meeting desired conditions (USFS 2010, 
p. 1). Herbaceous riparian vegetation appeared lush in July 2009 
(Ireland 2009, p. 2), and the cattle did not enter the fenced-off 
portion of the riparian zone (USFS 2009, p. 4). An increase in 
vegetative cover in the 8 km (5 mi) stretch of Trout Creek should limit 
sediment deposition downstream during snowmelt and thunderstorm events.
    The USFS installed a well in June 2005 about 8 km (5 mi) upstream 
of Trout Creek Spring that pipes water to a large holding tank, then 
into seven float-controlled livestock tanks to draw the livestock away 
from riparian areas (USFS 2009, p. 6). This action may limit grazing in 
the riparian areas, thereby further retaining vegetation and reducing 
sedimentation, but may negatively impact water quantity (see 
``Dewatering of Spring Habitat'' section below).
    The USFS (2009, pp. 1-5) provided present-day photos, as well as 
historical information and photos of Trout Creek in 1921 and 1933, that 
showed extensive erosion both upstream and downstream from Trout Creek 
Spring from excessive grazing and logging. Based on the photos, the 
sediment loads in the 1920s and 1930s almost certainly exceeded 
present-day loads. This means that the caddisfly was either able to 
withstand the sediment loads, the sediment was not deposited in the 
spring (allowing the caddisfly to survive), or conditions have improved 
since then to the extent that the caddisfly was able to colonize or 
recolonize Trout Creek Spring. Because cattle on the Bassam and 
Fourmile Allotments do not graze in the known

[[Page 22017]]

caddisfly habitat and grazing on the Chubb Park Allotment appears to be 
managed adequately, it is unlikely that cattle grazing on any of the 
three allotments under current and adaptive management causes 
sedimentation or direct impacts to the caddisfly or its habitat. The 
USFS has committed to adaptive management of the Chubb Park Allotment, 
which means that grazing or other actions may be adjusted based on 
observation of impacts on the ground or through scientific monitoring 
of conditions or both (USFS 2008b, p. 4). Adaptive management in the 
Chubb Park Allotment includes a variety of actions that can be 
categorized as adjusting grazing duration and timing, rotating cattle 
in different pastures, fencing cattle out of riparian areas, drawing 
cattle away from riparian areas with water developments, adjusting 
stocking rates, and managing vegetation (USFS 2008a, p. 28).
    No grazing occurs at High Creek Fen. The closest grazing occurs 
upstream about 1.5 km (0.9 mi) (Pague 2009, pers. comm.). Cattle also 
graze about 0.4 km (0.6 mi) downstream (easterly) and about 0.8 km (0.5 
mi) north and south of the fen (Pague 2009, pers. comm.). No grazing-
related impacts to the fen have been noted to date (Pague 2009, pers. 
comm.) or are expected in the future (Pague 2009, pers. comm.).
    The Valles Caldera National Preserve (VCNP) is approximately 36,000 
ha (89,000 ac) (Valles Caldera Trust 2009, p. 16), with 31 percent of 
the area suitable for grazing, including the area near where the adult 
caddisfly was found (Valles Caldera Trust 2009, pp. 75, 77). 
Historically, a large number of sheep and cattle were grazed on VCNP, 
but only cattle have been grazed for the last 40 years (Valles Caldera 
Trust 2009, p. 61). Historically, cattle and sheep grazing had an 
impact on Jaramillo Creek drainage, but since VCNP was created 
conditions have improved. Beginning in 2001, shortly after the VCNP was 
created, the number of cattle was reduced by about 93 percent 
(Parmenter 2009a, pers. comm.). Approximately 550 adult cows and 250 
calves were grazed in 2009, and this level is expected to continue in 
the future (Parmenter 2009b, pers. comm.). Cattle were grazed in the 
pasture surrounding the caddisfly location in 2008, but it was closed 
to grazing and herding in 2009 (Parmenter 2010, pers. comm.). The 
pasture is expected to remain closed to grazing and herding in the 
future (Parmenter 2010, pers. comm.).
    The primary native grazer in the VCNP is elk, with numbers of 
resident elk typically about 2,500 (Valles Caldera Trust 2009, p. 22). 
Seven thousand free-roaming elk live in the Jemez Mountains, which 
surround VCNP (Valles Caldera Trust 2009, p. 22). However, no 
measureable impact from elk grazing occurs in the area where the 
caddisfly was captured (Parmenter 2009b, pers. comm.).
    Stream condition in the VCNP appears to be improving. A proper 
functioning condition analysis was done in 2000 and 2006 to assess 
stream condition in VCNP (Valles Caldera Trust 2009, p. 68). 
Determining proper functioning condition includes analysis of 
vegetation, soils, geology, and hydrology but does not include water 
quality assessment (BLM 1998, pp. 2, 4). Four of five sections of the 
creek were rated as being in proper functioning condition in 2006, 
versus two of five in 2000 (Valles Caldera Trust 2009, p. 68). The 
other sections (three of five in 2000 and one of five in 2006) were 
rated as being on an upward trend. The section around the adult 
caddisfly capture site was rated as being in proper functioning 
condition (McWilliams 2006, pp. 7, 8, 17). Overall, 75 percent of the 
streams in VCNP are in proper functioning condition (Parmenter 2009a, 
pers. comm.). However, most of the streams on VCNP have water of 
quality that is considered impaired by State standards, primarily as a 
result of turbidity and temperature (Parmenter 2009a, pers. comm.). 
Unfortunately, temperature at the Jaramillo Creek caddisfly capture 
site is not known. Jaramillo Creek was one of the streams rated as non-
impaired overall in 2000, and was used as a reference stream during a 
benthic survey (Valles Caldera Trust 2009, p. 67). Jaramillo Creek had 
the highest number of taxa (31) and the highest diversity of aquatic 
insects of any creek in VCNP (Valles Caldera Trust 2009, p. 67). 
Therefore, we believe that livestock and elk grazing are not impairing 
water quality in a manner that threatens the Susan's purse-making 
caddisfly in Jaramillo Creek.
    In summary, the restricted distribution and narrow habitat 
requirements of Susan's purse-making caddisfly elevate the likelihood 
that grazing-induced impacts would have a negative impact on this 
species. Despite this possibility, no grazing impacts are apparent in 
the immediate vicinity of Trout Creek Spring. Additionally, there is no 
evidence that sedimentation from grazing in the Chubb Park Allotment is 
currently affecting Trout Creek Spring and effects are unlikely in the 
foreseeable future, considering current and adaptive management 
commitments. Grazing does not occur around the High Creek Fen caddisfly 
occurrence. There is no evidence that grazing at VCNP has impacted the 
caddisfly's habitat in recent years. We believe that grazing will 
continue for at least the next 20 years on both the Chubb Park 
Allotment and VCNP. However, we do not expect grazing to impact the 
caddisfly in the foreseeable future at either High Creek Fen or VCNP 
due to management practices currently in place and expected to continue 
in the future (Pague 2009, pers. comm.; Parmenter 2009a, pers. comm.; 
Parmenter 2009b, pers. comm.; Parmenter 2010, pers. comm.; Valles 
Caldera Trust 2009). We find no credible evidence that grazing is a 
threat to Susan's purse-making caddisfly now or in the foreseeable 
Hazardous Fuel Reduction Activities
    The North Trout Creek Forest Health and Hazardous Fuel Reduction 
Project (North Trout Creek Project) (USFS 2007a) may impact Trout Creek 
Spring. The project is proposed to treat approximately 3,500 ha (8,700 
ac) out of a 6,200-ha (15,300-ac) project area with salvage logging, 
thinning, and prescribed fire to reduce hazardous fuel loads (USFS 
2007a, p. 1). The various components of the project are projected to 
take place over 5 to 7 years dependent on funding (USFS 2007a, p. 13). 
The closest proposed action under the project is about 10 km (6 mi) 
north of Trout Creek Spring. An additional timber sale project (Ranch 
of the Rockies Project) could result in 35 ha (86 ac) of impacts in the 
Trout Creek Pass area 5 to 8 km (3 to 5 mi) upstream of Trout Creek 
Spring (USFS 2007b, pp. 1-3). This timber sale project involves 
skidding and storing live and dead trees and piling the resulting 
slash. Although the proposed North Creek project location is at least 
10 km (6 mi) from caddisfly habitat, roads and prescribed fire related 
to logging and hazardous fuels reduction could potentially impact 
Susan's purse-making caddisfly as described in the ``Logging Roads'' 
and ``Prescribed Fire'' sections below.
    Very few or no harvestable trees occur at High Creek Fen, so 
logging there is not a potential threat. From 1935 to 1972, logging 
(particularly clear-cut logging) was conducted on VCNP (Valles Caldera 
Trust 2009, p. 164). Logging ceased in 1972, as result of a lawsuit 
(Valles Caldera Trust 2009, p. 164). Only minor selective logging has 
occurred since 1972, and it is expected that some thinning of second 
growth forests will continue to occur to prevent massive wildfires. 
However, no commercial logging is proposed (Parmenter 2009b, pers. 
comm.). There may be higher spring snowmelt from

[[Page 22018]]

thinning of trees, and possibly increased sedimentation, but the 
Science and Education Director of VCNP believes there should be minimal 
impact to the caddisfly (Parmenter 2010, pers. comm.). We do not expect 
any impacts to the caddisfly or its habitat from logging in the High 
Creek Fen and VCNP areas.
Logging Roads
    Disturbance associated with logging road construction and operation 
is a significant source of sediment load in streams (Cederholm et al. 
1980, p. 25). Unpaved permanent or temporary roads are a primary source 
of sediment in forested watersheds (Vora 1988, pp. 117, 119; Sugden and 
Woods 2007, p. 193). Similar to the effects of livestock grazing on 
aquatic habitats, roads remove vegetation, compact soil (reducing water 
infiltration), increase erosion and sedimentation, increase the amount 
of surface runoff and change its pattern, introduce contaminants, and 
facilitate the spread of invasive plant species (Anderson 1996, pp. 1-
13; Forman and Alexander 1998, pp. 210, 216-221; Jones et al. 2000, pp. 
77-82; Trombulak and Frissell 2000, pp. 19, 24; Gucinski et al. 2001, 
pp. 12-15, 22-32, 40-42; Angermeier et al. 2004, pp. 19-24). The 
cumulative effects on streams include increases in siltation, increases 
in nonpoint source pollution, increases in water temperatures, and 
decreases in dissolved oxygen levels. Since the caddisfly appears to 
inhabit springs with high dissolved oxygen, relatively low and stable 
water temperatures, and low trace metals (Flint and Herrmann 1976, p. 
897), we investigated the possibility that the cumulative effects of 
roads could threaten the caddisfly.
    The North Trout Creek Project would not create new permanent roads, 
but would allow creation of about 10 km (6 mi) of new temporary roads 
and reopen 16 km (10 mi) of existing closed roads (USFS 2007a, p. 83). 
The sediment yield from construction of temporary roads and reopening 
of closed roads associated with the fuel reduction project is estimated 
to be 41.2 tons/year, with 9.3 times greater sediment load in the Trout 
Creek watershed predicted from the action versus no action alternatives 
(USFS 2007a, p. 83). However, it is uncertain if the sediment will be 
deposited at, and affect the caddisfly or its habitat in, Trout Creek 
Spring, especially with actions described above improving the riparian 
area upstream of Trout Creek Spring. The riparian vegetation in the 
ephemeral upper Trout Creek channel will likely act as a sediment trap, 
thereby limiting the rate and average amount of sediment deposited in 
Trout Creek Spring. Since activities under the fuel reduction project 
have not yet occurred, it is presently unknown what effects the 
predicted sediment increase will have on Susan's purse-making 
    Historic timber activities resulted in about 50 percent of VCNP 
being logged, with over 1,600 km (1,000 mi) of 1960s-era logging roads 
(Valles Caldera Trust 2009, p. 164) being built in winding and 
spiraling patterns around hills (Valles Caldera Trust 2009, pp. 59-60). 
The logging resulted in accelerated run-off and erosion that is still 
evident or active to some extent including continued erosion in gullies 
and roads immediately adjacent to Jaramillo Creek (Parmenter 2010, 
pers. comm.; Valles Caldera Trust 2009, p. 60). However, the run-off 
has been reduced by natural revegetation of grasses, forbs, and small 
trees and only minimal administrative use of logging roads (Parmenter 
2010, pers. comm.). Jaramillo Creek has improved with better management 
and is currently considered in good ecological condition (Valles 
Caldera Trust 2009, p. 68). Assuming that the adult caddisfly found 
next to Jaramillo Creek was hatched from nearby larval habitat, 
sedimentation from logging roads does not appear to be a threat to 
Susan's purse-making caddisfly habitat in the area now or in the 
foreseeable future.
    In addition to logging, the North Trout Creek Project involves 
prescribed burns (USFS 2007a, map 2.3). Regular burns conducted around 
the area of Trout Creek Spring could have a negative impact on stream 
quality, because burning has been shown to affect aquatic habitats and 
watersheds in a variety of ways (Neary et al. 2005, pp. 1-250). For 
example, mechanical site preparation and road construction needed to 
conduct prescribed burns can lead to increased erosion and sediment 
production, especially on steep terrain (Neary et al. 2005, pp. 54, 56, 
58). Removal of leaf litter from the soil surface through burning can 
lead to reduced water infiltration into the soil, increasing the amount 
of surface runoff into streams. Additionally, ash depositions following 
a fire can affect the pH of water. Negative impacts may be exacerbated 
by burning slash piles, since the fire intensity is greater when the 
fuel is piled in a small area, which can have a stronger impact on the 
underlying soil (Neary et al. 2005, p. 83). No prescribed burns will 
occur immediately around or upstream of Trout Creek Spring, but burns 
higher up in the Trout Creek watershed could add sediment from the 
burning and thinning activities (USFS 2007a, map 2.3). The proposed 
Ranch of the Rockies timber sale does not involve burning (USFS 2007b, 
pp. 1-3). Of course, natural wildfires could have the same effect as 
the prescribed burns or a more significant effect if burn intensity is 
high. However, the thinning and prescribed burning program is intended 
to reduce fuel loads to prevent high intensity wildfires.
    Prescribed burning does not take place at High Creek Fen (Schulz 
2009, pers. comm.). At VCNP, natural fire patterns were disrupted in 
the late 1800s with the introduction of livestock, human activities, 
and intentional fire suppression (Valles Caldera Trust 2009, pp. 96-
97). Natural fire events have not occurred in VCNP in many years. 
Prescribed fire at VCNP has been limited, with only one burn in 2004 
that is described as creating a positive vegetation response (Valles 
Caldera Trust 2009, p. 97). A prescribed fire plan is expected to be 
developed (Valles Caldera Trust 2009, p. 97), as there is concern for 
massive fires to occur (Parmenter 2009b, pers. comm.). Massive fires 
uphill or upstream of the caddisfly capture location would likely have 
a much greater effect on the caddisfly as there would be less 
vegetation to hold soil in place. However, thinning of secondary growth 
should help prevent massive fires in the future (Parmenter 2009b, pers. 
    In summary, proposed logging activities and prescribed burning 
activities in the Trout Creek Spring watershed could potentially have 
negative impacts on the caddisfly by increasing the sediment load in 
Trout Creek. None of these activities is occurring at present, so there 
is no evidence of immediate impacts. If sediment transport does 
increase as a result of future logging and burning activities, it is 
unknown if the sediment will be deposited in Trout Creek Spring to an 
extent where it will affect the caddisfly. Sediment transport and 
deposition to the caddisfly habitat in the foreseeable future may be 
ameliorated by increased vegetation in the upper Trout Creek watershed 
under current grazing management. The VCNP is still experiencing some 
erosion from logging-related roads developed before 1972, but Jaramillo 
Creek is in good ecological condition and continues to improve. Since 
the adult caddisfly has limited dispersal, suggesting larval habitat is 
nearby, the caddisfly's existence in Jaramillo Creek indicates that 
sedimentation effects from logging roads do not appear to be having 

[[Page 22019]]

impacts. Erosion and sedimentation is not expected to be a threat in 
the foreseeable future with increased vegetation, minimal logging, and 
minimal logging road use.
Dewatering of Spring Habitats
    Reduction of stream flow due to increased groundwater use and water 
diversion can have a dramatic impact on stream habitat and associated 
macroinvertebrate communities. Artificial flow reductions frequently 
lead to changes, such as decreased water depth, increased 
sedimentation, and altered water temperature and chemistry, whichh can 
reduce or influence macroinvertebrate numbers, richness, competition, 
predation, and other interactions (Dewson et al. 2007, pp. 401-411).
    The development of springs in the upper Trout Creek watershed could 
affect the hydrology of remaining springs and streams, in addition to 
reducing potential new habitat for Susan's purse-making caddisfly 
colonization. Trout Creek Spring itself is not currently proposed for 
livestock water development, but a well installed in 2005 pumps water 
from the upper ephemeral part of Trout Creek (USFS 2008a, Appendix 3 
Chubb Park C&H, p. 5). The well is 70 m (220 ft) deep and diverts 15 
liters (4 gallons) per minute, but it is not known what percentage of 
the available water this constitutes (USFS 2009, p. 6). Another six 
developments are planned in ephemeral tributaries to Trout Creek, 
consisting of water piped from six seeps to nearby stock tanks (USFS 
2008a, Appendix 1 Chubb Park C&H Range Improvements, p. l). The exact 
groundwater source or sources for Trout Creek Spring are unknown, and 
no study was conducted on the existing well to determine if it is 
capturing groundwater from a tributary to Trout Creek Spring (USFS 
2008c, p. 34). Trout Creek Spring discharge will be measured twice 
yearly to determine if water use in Chubb Park is affecting caddisfly 
habitat (USFS 2008a, p. 43). The USFS has not identified what actions 
it will take if spring discharge is found to be less than previous 
years (USFS 2010, p. 2).
    High Creek Fen is part of a 464-ha (1,147-ac) preserve owned and 
managed by TNC. Park County, where the preserve is located, has 
experienced significant population increases since the 1990s (Miller 
and Ortiz 2007, p. 2). Population growth in this area is accompanied by 
an increased demand for fresh drinking water. In 2000, 89 percent of 
the population of Park County received water from groundwater sources 
(Miller and Ortiz 2007, p. 2). The area surrounding High Creek Fen is 
currently being protected, but the fen itself is fed by groundwater 
sources. Sustained or increasing groundwater removal of water sources 
for the fen could have a deleterious effect on the hydrology of the fen 
and the invertebrate species it supports, including Susan's purse-
making caddisfly.
    However, we have no information to quantify the magnitude or 
temporal aspect of potential effects from groundwater withdrawal. TNC 
believes the water sources for the fen are fairly secure because there 
are conservation easements to the west (upstream) of the fen on private 
land, and water use in a sub-development around Warm Springs uses water 
that does not appear to be supporting High Creek Fen (Schulz 2009, 
pers. comm.). Additionally, the CSLB and Colorado Natural Areas Program 
(CNAP) signed an article of designation in 2001 to conserve 972 ha 
(2,401 ac) of CSLB land on the north side of the fen, and land on Black 
Mountain to the west of the fen, for the protection of the land and at 
least one water source (CNAP 2001, pp. 1-7). The land is included as a 
State Natural Area under CNAP.
    The VCNP contains 136 earthen stock ponds with about 30 percent of 
the ponds failing and causing erosion and sedimentation (Valles Caldera 
Trust 2009, pp. 24, 93). However, only two to four appear to be in the 
Jaramillo Creek drainage, and the amount of sedimentation they cause is 
minor (Parmenter 2009b, pers. comm.). The stock ponds capture snowmelt 
and rainwater and do not require water delivery from streams (Parmenter 
2009b, pers. comm.). No water is diverted from Jaramillo Creek 
(Parmenter 2009b, pers. comm.), and no additional water use is expected 
in the foreseeable future in VCNP (Parmenter 2009c, pers. comm.).
    In summary, the restricted distribution and narrow habitat 
requirements of Susan's purse-making caddisfly make it possible that 
human-induced alterations in stream hydrology and water chemistry, such 
as what could occur from dewatering of spring habitats, would have a 
negative impact on this species. Although groundwater development in 
the areas around caddisfly habitat has the potential to impact springs 
and streams, we do not have any data showing that quantity of water has 
been lowered to date. Consequently, the information that we do have 
does not indicate that dewatering is currently occurring and impacting 
caddisfly habitat or that it will impact the caddisfly in the 
foreseeable future.
    In addition to roads associated with hazardous fuel reduction 
projects as described above, Trout Creek Spring may be impacted by 
Highway 285 and County Road 309 (USFS 2007a, map 2.3). Highway 285, 
which receives heavy traffic, runs within 30 m (100 ft) of Trout Creek 
Spring on the eastern side of the spring. Roads accumulate a variety of 
contaminants including brake dust, heavy metals, and organic 
pollutants, which can be carried into streams by overland runoff 
(Forman and Alexander 1998, pp. 219-221; Trombulak and Frissell 2000, 
pp. 19, 22-24; Gucinski et al. 2001, pp. 40-42). Highway 285 receives a 
sand and 3-percent road salt mixture as a wintertime deicer (Cady 2009, 
pers. comm.). Based on the condition of vegetation around the spring, 
there is no indication of any effects from the sand/salt mixture 
(Ireland 2009, pp. 1-2). County Road 309, which is immediately above 
the spring on the west side, receives occasional snow plowing for a 
short distance up to a private residence (Gaines 2009b, pers. comm.) 
and also may occasionally get graded, which can increase the rate of 
erosion and deliver increased silt loads to Trout Creek Spring 
(Gucinski et al. 2001, pp. 12-15). However, there is no recent 
information on water quality or sedimentation at Trout Creek Spring to 
assess whether these factors are impacting Susan's purse-making 
caddisfly habitat.
    Highway 285 crosses High Creek on the western side of High Creek 
Fen. There also is a little-used dirt access road about 300 m (938 ft) 
north of High Creek Fen. Neither the highway nor the dirt road appears 
to be causing impacts to the caddisfly's habitat, as water quality 
appears good (Cooper 1996) and an adult caddisfly and pupae were found 
there in 2009 (Ireland 2009, p. 1; Ruiter 2009b, pers. comm.).
    One maintained dirt road crosses Jaramillo Creek next to the 
collection site in VCNP and continues north on the eastern side of the 
creek for about 2.4 km (1.5 mi). It is unknown how much sediment this 
contributes to the creek, but it may contribute some. This road 
connects with another approximately 2.4 km (1.5 mi) upslope from the 
caddisfly capture site. The second follows upper Jaramillo Creek for 
about 5 km (3 mi) and deposits sediment into the creek during 
rainstorms (Parmenter 2009b, pers. comm.). These roads are not open in 
the winter and no salt, chemicals, or herbicides are used along them 
(Parmenter 2009b, pers. comm.), so road contaminants are not an issue

[[Page 22020]]

around the known caddisfly location in VCNP.
    In summary, the restricted distribution and narrow habitat 
requirements of Susan's purse-making caddisfly make it possible that 
road contaminants could have a negative impact on this species. 
However, the available evidence does not support a conclusion that 
roads in and near Susan's purse-making caddisfly habitat are negatively 
impacting water quality or habitat at present or will do so in the 
foreseeable future.
    Population growth in central Colorado has led to increased numbers 
of recreational users. The population of Chaffee County increased 28.1 
percent from 1990 to 2000, with much of the growth occurring in 
unincorporated areas, and the population of Colorado is expected to 
increase by about 50 percent within the next 20 to 25 years (Chaffee 
County Comprehensive Plan 2000, p. 10). A study of outdoor recreation 
trends in the United States found increases in participation in most of 
the activities surveyed, which included bicycling, primitive or 
developed-area camping, bird watching, hiking, backpacking, and 
snowmobiling (Cordell et al. 1999, pp. 219-321). Additionally, on the 
national level, off-road vehicle (ORV) usage has risen substantially. 
The number of people who reported engaging in ORV activities rose by 8 
million individuals between 1982 and 1995, and an increase of 16 
percent nationally is anticipated during the next 50 years (Bowker et 
al. 1999, pp. 339-340; Garber-Yonts 2005, p. 30). ORV use can 
negatively impact conditions in riparian areas through damage to 
riparian vegetation and stream banks, leading to increased 
    ORV impacts have been documented at Trout Creek Spring (USFS 2007c, 
pp. 2-3). However, ORV use is restricted to existing roads in the Trout 
Creek Spring/Chubb Park area (USFS 2010, p. 2). The likelihood of 
future ORV use impacting the caddisfly's habitat at Trout Creek Spring 
is low due to fences above and below the spring as well as steep slopes 
down to the spring. ORV use in the Chubb Park Allotment could 
contribute sediment to Trout Creek through vegetation destruction and 
erosion, but road-restricted ORV use should greatly limit ORV-caused 
    Damage to Trout Creek Spring also is possible from water withdrawal 
by campers (USFS 2007c, p. 2). Increased human passage to the spring to 
obtain water could damage the riparian zone and disturb habitat. 
However, the proximity to Highway 285, steep slopes off of County Road 
309, and open, narrow riparian zone limits the desirability for camping 
at the spring. People may occasionally go down to Trout Creek Spring 
proper for water, but if so, this occurrence appears to be limited as 
no sign of trampled vegetation or other impacts were evident during the 
July 2009 site visit. People also may use the ``parking area'' on the 
downstream side of the Highway 285 bridge to obtain water from Trout 
Creek, to fish, or to temporarily use the area for other purposes. 
However, the impact of people using the area below the bridge is likely 
minimal or non-existent since the caddisfly has only been collected 
upstream between the bridge and spring (Flint and Herrmann 1976, p. 
898; Herrmann 2010, pers. comm.). More specimens of another caddisfly, 
O. logana (no common name), were collected at the bridge site than at 
the spring. Consequently, Flint and Herrmann (1976, p. 898) 
hypothesized that O. logana replaces Susan's purse-making caddisfly in 
Trout Creek as it gets farther away from the spring. Additionally, 
Herrmann (2010, pers. comm.) has never collected the caddisfly 
downstream of the bridge.
    High Creek Fen is accessible to the public, but recreation of any 
kind is not known to be a threat (Schulz 2009, pers. comm.). The VCNP 
allows public access, with thousands of visitors annually (Valles 
Caldera Trust 2009, p. 142). However, VCNP uses reservations and a 
lottery to manage popular recreation activities or limits events to 
certain days and times (Valles Caldera Trust 2009, p. 212). Recreation 
is monitored, and no impacts from recreational activities have been 
noted in caddisfly habitat (Parmenter 2009b, pers. comm.). No ORV use 
is allowed in VCNP (Parmenter 2009c, pers. comm.). An environmental 
impact statement for public access and use is being prepared (Parmenter 
2009b, pers. comm.).
    In summary, although recreation is growing nationwide, the 
available information does not support a conclusion that any of the 
sites inhabited by Susan's purse-making caddisfly are being negatively 
impacted by recreational activities or that they will be in the 
foreseeable future.
Global Climate Change
    The effects of global climate change are being assessed in North 
America and throughout the world, and changes in precipitation 
patterns, stream hydrology, and bloom time have already been observed. 
Stream flows decreased by about 2 percent per decade across the last 
century in the central Rocky Mountain region (Rood et al. 2005, p. 
    Effects of global climate change are anticipated to include warming 
in the western mountains, causing snowpack and ice to melt earlier in 
the season (Field et al. 2007, pp. 627, 632, 635). These changes could 
lead to both increased flooding early in the spring, and drier summer 
conditions, particularly in the arid western areas, which rely on 
snowmelt to sustain stream flows. Spring and summer snow cover has 
already been documented as decreasing in the western United States, and 
drought has become more frequent and intense (Intergovernmental Panel 
on Climate Change (IPCC) 2007, pp. 8, 12). Major hydrologic events, 
such as floods and droughts, are projected to increase in frequency and 
intensity (IPCC 2007, p. 18). Erosion also is projected to increase as 
the result of a combination of factors, such as decreased soil 
stability from higher temperatures and reduced soil moisture, and 
increases in winds and high intensity storms (IPCC 2007, pp. 12, 14, 
15, 18). However, IPCC (2007) data can only predict on a regional scale 
and are not predictive of conditions at specific sites. Ray et al. 
(2008) predict that Colorado will warm by about 1 degree Celsius 
([deg]C) (2.5 degrees Fahrenheit ([deg]F)) by 2025 and by about 2 
[deg]C (4.0 [deg]F) by 2050. Most of the observed snowpack loss in 
Colorado has occurred below 2,500 m (8,200 ft) with snowpack loss above 
this elevation predicted at between 10 and 20 percent (Ray et al. 
2008). With the lowest known caddisfly site in Colorado (Trout Creek 
Spring) occurring at 2,750 m (9,020 feet), the chance of effects from 
hydrological change and a warming climate is lessened.
    There is evidence that the temperature has been rising at VCNP 
since 1914 (Parmenter 2009a, pers. comm.; Parmenter 2009b, pers. comm.) 
and that precipitation has been dropping (Parmenter 2009b, pers. 
comm.). Average annual temperatures at Jemez Springs, New Mexico, which 
is about 16 km (10 mi) south of VCNP, rose from about 10.3 [deg]C (50.5 
[deg]F) in 1914 to 11.7 [deg]C (53 [deg]F) in 2005 (Parmenter 2009b). 
The mean January temperature rose from about 0 to 1 [deg]C (32 to 34 
[deg]F) during this time period (Parmenter 2009b). The mean July 
temperature increase stands out as it increased from about 20.6 to 23.1 
[deg]C (69 to 73.5 [deg]F) from 1914 to 2005 (Parmenter 2009b). The 
average annual precipitation at Jemez Springs decreased from about 46 
centimeters (cm) (18 inches (in)) to just over 38 cm (15 in) from 1914 
to 2005 (Parmenter 2009b). In 2006, following a

[[Page 22021]]

very dry winter and spring, Jaramillo Creek went dry for 30 days 
(Valles Caldera Trust 2009, p. 68). This was the driest period in 112 
years of records (Parmenter 2009a, pers. comm.). However, the caddisfly 
was found in 2008 on Jaramillo Creek. Consequently, Susan's purse-
making caddisfly larvae may survive in springs that had some water in 
them in 2006, or the caddisfly could have recolonized Jaramillo Creek 
since 2006 from some nearby refuge or drainage that was not dry in 
2006. We are not aware of any historical temperature or precipitation 
data that have been compiled or analyzed for the Trout Creek area or 
High Creek Fen area.
    In summary, based on predictions from IPCC over the next 40 years, 
the western United States is predicted to get warmer and dryer and have 
altered hydrologic cycles. Despite these predicted changes, the 
caddisfly does appear to have the ability to adapt to warmer and drier 
conditions from observations of weather patterns around the VCNP site. 
Furthermore, the high elevations that the caddisfly occurs at in 
Colorado will help shield it from climate change effects.
Summary of Factor A
    Although we have identified potential impacts to the caddisfly from 
livestock grazing, hazardous fuel reduction activities, logging roads, 
prescribed fire, current and proposed water development, road 
sedimentation and contamination, and recreation, the available 
information does not support a conclusion that these actions are 
currently impacting the caddisfly. Current management practices and 
restrictions appear to adequately control these potential impacts so 
that they do not pose a substantial threat to the caddisfly. 
Additionally, there is currently no reliable way to predict if sediment 
and upstream water development will affect the caddisfly in the future.
    Climate change could pose a problem to Susan's purse-making 
caddisfly if water levels, water temperature, or other habitat 
variables that affect the caddisfly change as a result of global 
warming. However, there is currently no model or supporting information 
that can reliably or credibly predict climate change effects at a local 
enough scale to ascertain whether climate change is, or will become, a 
threat to Susan's purse-making caddisfly. Furthermore, despite an 
extremely dry year in 2006, the caddisfly was able to persist in or 
recolonize the Jaramillo Creek area, indicating that the species can 
survive with at least occasional dry years and perhaps with decreased 
precipitation over a longer period. Additionally, the high elevation of 
the Colorado sites are expected to shield the caddisfly from 
potentially negative consequences of warmer and drier conditions within 
the foreseeable future. The available data do not support the 
conclusion that potential threats are currently impacting Susan's 
purse-making caddisfly habitat or that they will impact the caddisfly 
habitat in the foreseeable future. Therefore, we conclude that the best 
scientific and commercial information available indicates that Susan's 
purse-making caddisfly is not threatened by the present or threatened 
destruction, modification, or curtailment of its habitat or range.

B. Overutilization for Commercial, Recreational, Scientific, or 
Educational Purposes

    Susan's purse-making caddisfly is only known to occur at three 
sites, so its rarity may pose a collection threat. However, the only 
people known to collect the caddisfly in any number are Dr. Scott 
Herrmann and his students in 1974 and 1975 (Flint and Herrmann 1976, p. 
898). Because of the high fecundity of insects, their collection 
typically poses little threat to their populations (Xerces Society et 
al. 2008, p. 15), but it is nonetheless possible to overcollect a 
species that occurs in relatively isolated habitat areas. We do not 
have evidence of any collections since 1975 at Trout Creek Spring. 
Other than a couple specimens collected during the July 2009 field trip 
at High Creek Fen (2009, p. 2) and a subsequent visit in August 2009 
(Ruiter 2009b, pers. comm.), we do not have evidence of any other 
collections since 1995 at High Creek Fen.
Summary of Factor B
    There is no evidence that overutilization has been a threat to 
Susan's purse-making caddisfly. Further, even though small collections 
will likely continue to occur absent any permitting requirements, we do 
not believe these collections will constitute a threat to the species. 
Therefore, we conclude that the best scientific and commercial 
information available indicates that Susan's purse-making caddisfly is 
not now, nor in the foreseeable future, threatened by overutilization 
for commercial, recreational, scientific, or educational purposes.

C. Disease or Predation

    Neither disease nor predation is known to be a threat to Susan's 
purse-making caddisfly. Given only three known locations and unknown 
population sizes, it is possible that disease or predation could pose a 
threat in the future. However, we have no evidence to suggest that 
disease or predation will be a threat to the species. Consequently, we 
conclude that the best scientific and commercial information available 
indicates that Susan's purse-making caddisfly is not now, nor in the 
foreseeable future, threatened by disease or predation to the extent 
that listing under the Act as a threatened or endangered species is 

D. The Inadequacy of Existing Regulatory Mechanisms

    Susan's purse-making caddisfly is listed as a U.S. Forest Service 
(USFS) Region 2 sensitive species (USFS 2007c, pp. 1-3). The Forest 
Service Manual (FSM) has direction for management and conservation of 
sensitive species (FSM 2670.31-2670.32). The FSM states that the USFS 
will: (1) Integrate available scientific information, including 
Regional species evaluations, species and ecosystem assessments, and 
conservation strategies, into USFS planning and implementation; (2) 
Conduct appropriate inventories and monitoring of sensitive species to 
improve knowledge of distribution, status, and responses to management 
activities, coordinating efforts within the Region and with other 
agencies and partners where feasible; and (3) Analyze and manage for 
sensitive species in a manner to realize efficiencies of multi-species 
and ecosystem management approaches.
    Potential impacts to Susan's purse-making caddisfly were not 
addressed in planning documents for the North Trout Creek Project (USFS 
2007a, p. 48) or the Ranch of the Rockies Timber Sale Project (USFS 
2007b, pp. 1-3). The USFS is not bound to apply sensitive species 
policies if an ongoing project's Environmental Assessment (EA) under 
the National Environmental Policy Act (NEPA) (42 U.S.C. 4231 et seq.) 
was written prior to designation of a sensitive species, but the USFS 
could choose to apply sensitive species policies to those projects 
(Gaines 2010, pers. comm.). As discussed under Factor A (Livestock 
Grazing), the Final Grazing EA did address the caddisfly (USFS 2008a). 
The Final Grazing EA states that Trout Creek Spring discharge will be 
measured twice yearly to determine if up-valley water use (in Chubb 
Park) is affecting the caddisfly's habitat (USFS 2008a, p. 43). The 
USFS does not currently know if a well upstream of the caddisfly's 
habitat used for cattle watering contributes to Trout Creek

[[Page 22022]]

Spring. However, to reduce water usage, the USFS put float valves on 
the stock tanks so that water only runs when the cows have lowered the 
water level in the tanks or when minor evaporative loss occurs (USFS 
2008a, p. 108). If the float valves are not working, an overflow valve 
at the well will return water to the drainage upstream of Trout Creek. 
Additionally, when the cattle are not grazing in Chubb Park, the water 
will be turned off (USFS 2008a, p. 108). Grazing was conducted for only 
41 days in fall 2009 (USFS 2009, p. 4), and desired vegetative 
utilization levels were not exceeded (USFS 2009, p. 4). An electric 
fence also was installed along 8 km (5 mi) of riparian habitat upstream 
of Trout Creek Spring that prevented grazing there (USFS 2009, p. 5). 
These actions illustrate that regulatory mechanisms can and are being 
implemented by the USFS.
    The USFS assumes presence of the caddisfly in suitable habitat 
unless adequate surveys determine otherwise (USFS 2008a, p. 103). 
Although the USFS does not know what the desired conditions should be 
for the caddisfly, they are managing the riparian area around Trout 
Creek Spring with the desired future condition for suitable habitat for 
all aquatic species (USFS 2008a, p. 105). This includes:

 A riparian plant community that is meeting or moving toward at 
least a mid-seral class (a suite of vegetation that is in the middle of 
the natural succession process);
 The presence of healthy and self-perpetuating riparian plant 
 Compliance with State and Federal water quality standards;
 The presence of stable and well-vegetated shorelines with 
appropriate species;
 The presence of suitable habitat for viable populations of 
aquatic invertebrates; and
 The absence of upstream deplections that would reduce the 
Trout Creek Spring discharge.

    The Valles Caldera National Preserve (VCNP) does not have specific 
regulations protecting the Susan's purse-making caddisfly, as the 
species was not known to occur there until June 2009 (Flint 2009b, 
pers. comm.). However, the occupied site lies within a national 
preserve created by the Valles Caldera Preservation Act of July 25, 
2000. The VCNP was created ``to protect and preserve the scientific, 
scenic, geologic, watershed, fish, wildlife, historic, cultural, and 
recreational values of the preserve, and to provide for multiple use 
and sustained yield of renewable resources within the preserve, 
consistent with this title'' (VCPA sec. 105 [b]) (Valles Caldera Trust 
2003, p. 47). As described above, the Preserve is federally owned but 
run by a nine member Board of Trustees (Valles Caldera Trust 2003, pp. 
46-47). The VCNP Board of Trustees allows for public input in 
management decisions through public review of draft environmental 
assessments and a variety of other avenues (Valles Caldera Trust 2003, 
pp. 75-81). The multiple-use mandate does create the potential for 
conflicts with management of the caddisfly; however, it also provides 
wildlife protection and, based on recent information provided in Factor 
A, the Service finds that adequate regulatory mechanisms are being 
implemented to conserve the caddisfly.
    For all projects on Federal land, or that are federally funded or 
authorized, an EA or environmental impact statement will be prepared 
under NEPA. Categorical exclusion documents also could be prepared 
under NEPA for projects if they are determined to be minor and would 
not affect rare or sensitive species. Therefore, because the caddisfly 
has been designated a sensitive species, NEPA documents can provide 
protection to the caddisfly by assessing impacts to the caddisfly and 
presenting actions to avoid or minimize any impacts. The Clean Water 
Act of 1977 (33 U.S.C. 1251 et seq.) also may provide indirect 
protection to the caddisfly. This law was written to restore and 
maintain the chemical, physical, and biological integrity of the 
Nation's waters. States have authority over water rights. The USFS must 
comply with Federal, State, and local water quality laws and rules, 
coordinate actions that affect water quality with States, and control 
nonpoint source pollution (USFS 2008a, p. 24).
    The Susan's purse-making caddisfly is not a State-protected species 
in either Colorado or New Mexico. Title 33, Article 1-102 of the 
Colorado Revised Statutes defines wildlife in Colorado as vertebrates, 
mollusks, and crustaceans; therefore, caddisflies are not eligible for 
protection by the State. Likewise, Chapter 17, Article 2 of the New 
Mexico Statutes does not include non-mollusk or crustacean 
invertebrates in its definition of wildlife.
    The Colorado State Land Board (CSLB), a Colorado State government 
entity, owns about 1,215 ha (3,000 ac) in Chubb Park as part of the 
Chubb Park Allotment. The CSLB cooperates with the USFS and manages the 
land with the same grazing seasons as the USFS land and combines AUMs 
to manage the Chubb Park Allotment as a single allotment.
    The CSLB also owns part of High Creek Fen and much of Black 
Mountain, which provides at least one source of water to High Creek Fen 
(Cooper 1996, p. 1803). The CSLB and Colorado Natural Areas Program 
(CNAP) designated 972 ha (2,401 ac) of land to the north of TNC-owned 
land and to the west on Black Mountain as a State Natural Area to help 
conserve land and water for the fen (CNAP 2001, pp. 1-7). In addition 
to the CSLB land, the CNAP also designated 464 ha (1,147 ac) of TNC-
owned land in 1994 as the High Creek Fen State Natural Area (CNAP 1994, 
pp. 1-7). The 2001 designation was an addition to the High Creek Fen 
State Natural Area designation of 1994. The caddisfly was not listed as 
a reason for the designations, but the designations do help protect the 
caddisfly by limiting resource development and protecting water 
The Nature Conservancy
    The Nature Conservancy (TNC) owns 464 ha (1,147 ac) of land and 
habitat for the caddisfly at High Creek Fen. The actual amount of 
Susan's purse-making caddisfly habitat protected on TNC land has not 
been calculated, nor is the extent of occupied habitat known on High 
Creek or within the fen proper. Additionally, TNC has facilitated 
several private land conservation easements (of unknown area) around 
and upstream of High Creek Fen for the fen's protection (TNC 2009, pp. 
1-2). Although TNC is a not a regulatory agency and cannot enact State 
or Federal regulations, their primary mission is to protect native 
ecosystems. TNC's current management plan (TNC 1993, pp. 1-14) does not 
specifically mention protection of Susan's purse-making caddisfly, but 
general protections for the fen provide protection for the caddisfly by 
eliminating peat extraction and housing development in and around the 
fen and by managing the area to maintain a natural hydrologic and 
vegetative state. Consequently, the Service believes the High Creek Fen 
site is adequately protected.
Summary of Factor D
    Susan's purse-making caddisfly is a USFS Sensitive Species. Despite 
the caddisfly not being addressed in the EAs for the North Trout Creek 
Project (USFS 2007a) or the Ranch of the Rockies Timber Sale Project 
(USFS 2007b), we believe that sensitive species

[[Page 22023]]

direction provided in the Forest Service Manual (FSM) (FSM 2670.31-
2670.32) will continue to be followed under the EA for the Rangeland 
Allotment Management Planning in the Salida-Leadville Planning Area 
(USFS 2008a) and the Decision Notice and Finding of No Signficant 
Impact for the project (USFS 2008b). The project area for the Rangeland 
Allotment Management Planning in the Salida-Leadville Planning Area 
(USFS 2008a) includes the areas addressed in the North Trout Creek 
Project (USFS 2007a) and the proposed Ranch of the Rockies Timber Sale 
Project (USFS 2007b). Consequently, adequate regulatory mechanisms 
exist to protect the species and its habitat at Trout Creek Spring. If 
other locations of the caddisfly are discovered on USFS land, the 
sensitive species policies also would apply.
    The CSLB cooperatively manages its lands above Trout Creek and at 
High Creek Fen with the USFS and TNC, respectively, so even though the 
State of Colorado does not recognize invertebrates as wildlife, 
cooperative grazing management provides adequate regulatory mechanisms 
around the known locations of the caddisfly. TNC and CSLB own a 
majority of the land around High Creek Fen, and the lack of development 
and the conservation of the land through State Natural Area designation 
and implementation of a habitat management plan help to protect the 
fen. The designation and management of VCNP provides adequate 
protection to the caddisfly site by preserving the land from housing 
development; limiting and managing recreational use, logging, road use, 
and domestic livestock use (thereby allowing natural revegetation); 
reducing sedimentation; and preserving water resources. We believe that 
these management plans and regulatory mechanisms provide conservation 
benefit to the species now and into the foreseeable future.
    We conclude that the best scientific and commercial information 
available indicates that Susan's purse-making caddisfly is not now, or 
in the foreseeable future, threatened by inadequate existing regulatory 

E. Other Natural or Manmade Factors Affecting the Species' Continued 

Small Population Size and Stochastic Events
    Since we do not know the caddisfly population size at any of the 
known locations, we considered whether small population size or rarity 
might pose a potential threat to the species. Small populations are 
generally at greater risk of extirpation from normal population 
fluctuations due to predation, disease, and changing food supply, as 
well as from stochastic (random) events such as floods or droughts 
(Xerces Society et al. 2008, p. 15). However, we do not consider rarity 
alone, without corroborating information regarding threats, to meet the 
information threshold indicating that the species may warrant listing. 
In the absence of information identifying threats to the species and 
linking those threats to the rarity of the species, the Service does 
not consider rarity alone to be a threat. Further, a species that has 
always had small population sizes or been rare, yet continues to 
survive, could be well-equipped to continue to exist into the future. 
Many naturally rare species have persisted for long periods within 
small geographic areas, and many naturally rare species exhibit traits 
that allow them to persist despite their small population sizes. 
Consequently, that fact that a species is rare or has small populations 
does not necessarily indicate that it may be in danger of extinction 
now or in the foreseeable future. We need to consider specific 
potential threats that might be exacerbated by rarity or small 
population size.
    Due to the presumed limited dispersal ability of Susan's purse-
making caddisfly between the known populations, loss of genetic 
variability and reduced fitness due to inbreeding could occur (Bjjlsma 
et al. 2000, p. 502; Saccheri et al. 1998, p. 491; Xerces Society et 
al. 2008, p. 15). However, we could find no specific literature 
addressing genetic effects in caddisflies. Although low genetic 
variability and reduced fitness from inbreeding could occur, at this 
time we have no evidence that genetic problems are occurring. Based on 
the limited available information, and fact that the caddisfly has 
survived for an unknown number of years, we conclude that genetic 
variability and reduced fitness are not an imminent threat now or in 
the foreseeable future. Although we have only known of the species' 
existence since 1974 (Flint and Herrmann 1976), it has likely 
historically survived floods, drought, and other stochastic events. We 
do not believe that such stochastic events would eliminate all of the 
populations at one time or place the species at risk of extinction 
within the foreseeable future.
    Further, with the discovery of the adult caddisfly at VCNP, the 
potential range of the caddisfly has expanded significantly. Although 
the USFS' Sensitive Species Form states that extensive surveys have 
taken place (USFS 2007c), species experts agree that more populations 
could exist, especially in light of the New Mexico discovery (Jacobi 
2009, pers. comm.; Kondratieff 2010, pers. comm.; Ruiter 2010, pers. 
Summary of Factor E
    Although the limited distribution and presumably small size of the 
three populations of Susan's purse-making caddisfly could be a concern, 
there is no current evidence that the caddisfly is being impacted as a 
result of small population size or stochastic events. Consequently, we 
conclude that the best scientific and commercial information available 
indicates that Susan's purse-making caddisfly is not now, nor in the 
foreseeable future, threatened by other natural or manmade factors 
affecting the species' continued existence.


    As required by the Act, we considered the five factors in assessing 
whether Susan's purse-making caddisfly is threatened or endangered 
throughout all or a significant portion of its range. We have carefully 
examined the best scientific and commercial information available 
regarding the past, present, and future threats faced by the species. 
We reviewed the petition, information available in our files, and other 
available published and unpublished information, and we consulted with 
recognized caddisfly experts, other Federal agencies, and non-
governmental entities. On the basis of the best scientific and 
commercial information available, we find that Susan's purse-making 
caddisfly is not in danger of extinction (endangered) now, or likely to 
become endangered within the foreseeable future (threatened), 
throughout all or a significant portion of its range. Therefore, we 
find that listing Susan's purse-making caddisfly as a threatened or an 
endangered species is not warranted throughout all or a significant 
portion of its range at this time.
    This species is only known from three locations, and there is 
limited scientific information available regarding its basic biology, 
life cycle, and habitat preferences. There is no available information 
regarding population sizes or trends at any of the known locations. 
Additional research and a species-specific survey effort are needed. We 
do have information regarding ongoing and potential future activities 
adjacent to each of the sites as described above.
    Our finding is based on the best available information that does 

[[Page 22024]]

support a detrmination that any current activities are impacting the 
caddisfly or its known habitats, and on current management practices 
and protections that would limit or prevent possible negative impacts. 
Although there are projects proposed that could potentially impact 
occupied caddisfly habitats, especially from sedimentation and upstream 
water use that could reduce spring flows, we have no credible 
information as to the potential effects of the actions on the species 
or its habitat. There is evidence that the VCNP area is getting warmer 
and dryer. However, even if warmer and dryer trends continue, we do not 
know at what point climate change may negatively impact the caddisfly. 
The caddisfly apparently survived the driest period in 112 years at 
VCNP. Based on our current knowledge of the species, the fact that it 
occurs in mid- to high-elevation sites that appear less prone to 
climate change impacts, and the lack of local-scale predictability of 
climate change effects, we do not believe or have evidence that the 
species is threatened by climate change now or in the foreseeable 
future. We do not believe overutilization for commercial, recreational, 
or scientific use under Factor B is a threat to the species at this 
time. Neither disease nor predation under Factor C is known or expected 
to be a threat to the species. We believe adequate regulatory 
mechanisms under Factor D exist at the known locations to protect the 
caddisfly and its habitat. For Factor E, we do not consider rarity or 
small populations alone to be a threat; there must be some likely 
stressor acting on the species or its habitat that may affect the 
caddisfly's status such that the species may be threatened now or 
within the foreseeable future. The information we have does not 
indicate that the caddisfly is being impacted genetically or in any 
other way, as a result of small population size, or that it will become 
threatened or endangered in the foreseeable future due to stochastic 

Distinct Vertebrate Population Segments

    The species is not a vertebrate; therefore, the Service's Distinct 
Population Segment (DPS) policy does not apply. Thus, there are no 
population segments that qualify as a DPS under the Service's DPS 

Significant Portion of the Range

    Having determined that Susan's purse-making caddisfly does not meet 
the definition of a threatened or endangered species, we must next 
consider whether there are any significant portions of the range where 
the species is in danger of extinction or is likely to become 
endangered in the foreseeable future.
    On March 16, 2007, a formal opinion was issued by the Solicitor of 
the Department of the Interior, ``The Meaning of `In Danger of 
Extinction Throughout All or a Significant Portion of Its Range''' 
(USDI 2007c). That formal opinion informs our analysis that occurs 
below. A portion of a species' range is significant if it is part of 
the current range of the species and it contributes substantially to 
the representation, resiliency, or redundancy of the species. The 
contribution must be at a level such that its loss would result in a 
decrease in the ability to conserve the species.
    In determining whether a species is threatened or endangered in a 
significant portion of its range, we first identify any portions of the 
range of the species that warrant further consideration. The range of a 
species can theoretically be divided into portions an infinite number 
of ways. However, there is no purpose to analyzing portions of the 
range that are not reasonably likely to be significant and threatened 
or endangered. To identify only those portions that warrant further 
consideration, we determine whether there is substantial information 
indicating that: (1) The portions may be significant, and (2) the 
species may be in danger of extinction there or likely to become so 
within the foreseeable future. In practice, a key part of this analysis 
is whether the threats are geographically concentrated in some way. If 
the threats to the species are essentially uniform throughout its 
range, no portion is likely to warrant further consideration. Moreover, 
if any concentration of threats applies only to portions of the 
species' range that are not significant, such portions will not warrant 
further consideration.
    If we identify portions that warrant further consideration, we then 
determine whether the species is threatened or endangered in these 
portions of its range. Depending on the biology of the species, its 
range, and the threats it faces, the Service may address either the 
significance question or the status question first. Thus, if the 
Service considers significance first and determines that a portion of 
the range is not significant, the Service need not determine whether 
the species is threatened or endangered there. Likewise, if the Service 
considers status first and determines that the species is not 
threatened or endangered in a portion of its range, the Service need 
not determine if that portion is significant. However, if the Service 
determines that both a portion of the range of a species is significant 
and the species is threatened or endangered there, the Service will 
specify that portion of the range as threatened or endangered under 
section 4(c)(1) of the Act.
    To determine whether any portions of the range of Susan's purse-
making caddisfly warrant further consideration as possible endangered 
significant portions of the range, we reviewed the supporting record 
for the status review done for this 12-month petition finding, with 
respect to the geographic concentration of threats and the significance 
of portions of the range to the conservation of the species. In this 
case, we first evaluated whether substantial information indicated (i) 
the threats are so concentrated in any portion of the species' range 
that the species may be currently in danger of extinction in that 
portion; and (ii) if so, whether those portions may be significant to 
the conservation of the species.
    Our rangewide review of the species concluded that Susan's purse-
making caddisfly is not endangered now or in the foreseeable future. As 
described above, to establish whether any areas may warrant further 
consideration, we reviewed our analysis of the five listing factors to 
determine whether any of the significant threats identified were so 
concentrated in any of the three known caddisfly populations, that some 
portion of the caddisfly's range may be in danger of extinction now or 
in the foreseeable future. We found that none of the potential threats 
evaluated in this rule act were specific to one population or range of 
the caddisfly. Based on our review of the record, the available 
information does not indicate that any of the potential threats we 
evaluated were so concentrated as to find that some portion of the 
caddisfly's range qualifies as endangered. As a result, we have 
determined that the best available data show that there are no portions 
of the range in which the threats are so concentrated as to place the 
species in danger of extinction now or in the foreseeable future. 
Because we find that Susan's purse-making caddisfly is not endangered 
in any portion of its range now or in the foreseeable future, we need 
not address the question of whether any portion may be significant.


    Our review of the information pertaining to the five factors does 
not support the assertion that there are significant threats acting on 
the species or its habitat that have rendered Susan's purse-making 
caddisfly to be in danger of extinction or likely to become so in the 
foreseeable future, throughout all or

[[Page 22025]]

a significant portion of its range. Therefore, listing Susan's purse-
making caddisfly as threatened or endangered under the Act is not 
warranted at this time.
    We request that you submit any new information concerning the 
status of, or threats to, Susan's purse-making caddisfly to our Western 
Colorado Field Office (see ADDRESSES) whenever it becomes available. 
New information will help us monitor the caddisfly and encourage its 
conservation. If an emergency situation develops for the caddisfly, or 
any other species, we will act to provide immediate protection.

References Cited

    A complete list of references cited is available on the Internet at 
http://www.regulations.gov and upon request from the Western Colorado 
Field Office (see ADDRESSES).


    The primary authors of this notice are the staff members of the 
Western Colorado Field Office.


    The authority for this action is the Endangered Species Act of 
1973, as amended (16 U.S.C. 1531 et seq.).

    Dated: April 12, 2010
Daniel M. Ashe,
Deputy Director, U.S. Fish and Wildlife Service.
[FR Doc. 2010-9458 Filed 4-26- 10; 8:45 am]