Western Regal Fritillary ESA Listing Not Warranted,
Says Oil and Natural Gas Associations

October 7, 2024

Casper, Wyo. –

Today, the Petroleum Association of Wyoming (PAW) and Western Energy Alliance (Alliance) submitted comments to the U.S. Fish & Wildlife Service (USFWS) on the proposed listing of the Western Regal Fritillary butterfly as threatened under the Endangered Species Act (ESA). The associations urged the USFWS to withdraw the proposed listing because it is based on broad assumptions not supported by scientific evidence or actual data about the fritillary. Rather, the service should collect species-specific data, identify suitable habitat, and develop targeted conservation efforts that will actually protect the species. The associations provided credible evidence that not only do oil and natural gas activities have minimal impacts on the butterfly, but the industry can aid in the conservation of the species along with the states.

“The USFWS claims the proposal is based on scientific and commercial data but then relies on surrogate species to back up what appears to be a predestined decision,” said Pete Obermueller, president of PAW. “Based on the data provided for the western regal fritillary, it would be just as reasonable for the USFWS to have proposed to list Bigfoot or the Chupacabra.”

“In our comments, we have shown that the oil and natural gas industry has minimal impact on western regal fritillary habitat and how modern industry practices and technology have reduced wildlife fragmentation by 70% or more,” said Kathleen Sgamma, president of the Alliance. “In North Dakota, where the best survey data are available, observations of the butterfly increased from three counties to 43 from 2010 to 2019. If USFWS and other states likewise conducted the comprehensive, multi-year surveys that North Dakota has done, perhaps the USFWS would likewise record increased observations of the species in other states. Without doing that hard work, USFWS is just stabbing in the dark and making assumptions about this specific species by using data from other insects or without data at all. We urge USFWS to avoid a knee-jerk listing decision before it has data to support such a decision.”

The full comment letter can be found here.

About PAW: Representing Wyoming’s primary economic engine, the Petroleum Association of Wyoming, is the voice of the oil and gas industry. Our members produce 90% of Wyoming’s oil and gas, generating over $8 billion in economic activity and employing more than 19,000 of Wyoming’s hard-working men and women. PAW strives to foster mutually beneficial relationships with Wyoming’s landowners, businesses, and communities while promoting the sustainable production of Wyoming’s abundant resources.

The Petroleum Association of Wyoming provides a forum for education, interaction, and unified action for members, policymakers, and the public.