Delhi Sands flower-loving fly and the Colton Dunes Conservation Bank, California
- Per credit (one acre); the total of credit sales is not on record 0.15 million US dollars were earned in sales in my name. No one has measured what reached me. Ecosystem Marketplace
- In 2008 at least 90 percent of my historical Delhi Soils were lost, and urban land on those soils rose from 53% to 64% between 1998 and 2004, according to FWS. US Fish and Wildlife Service, Carlsbad Fish and Wildlife Office
- In 2008 only about 10% of my remaining potential habitat had protected status, and 62 of 162 conserved acres were actively managed, according to FWS. US Fish and Wildlife Service, Carlsbad Fish and Wildlife Office
- In 2021 my fly survived in five core areas, and FWS wrote that development continues to be the primary threat. US Fish and Wildlife Service, Carlsbad
- Government and regulators US Fish and Wildlife Service (1993 listing rule, quoted in 2008): "over 97 percent of the suitable habitat. primarily measured by Delhi Soils, was eliminated". US Fish and Wildlife Service, Carlsbad Fish and Wildlife Office
- Government and regulators US Fish and Wildlife Service (2008): At least 90 percent of historical Delhi Soils lost; urban land within Delhi Soils rose from 53% to 64% between 1998 and 2004. US Fish and Wildlife Service, Carlsbad Fish and Wildlife Office
- Government and regulators US Fish and Wildlife Service (2014): "Less than 5 percent of the species' historic range is left". US Fish and Wildlife Service
- Press and investigations Ecosystem Marketplace (2006): The habitat had been reduced to 2% of its former extent. Ecosystem Marketplace
- Press and investigations PBS SoCal (2014): At least 97 percent of the habitat is gone, but also that development reduced it to roughly 40 acres of Delhi Sands soils, a figure that conflicts with FWS's hundreds of acres and is not corroborated. PBS SoCal
- Communities and civil society A comment received during the 2008 review: Claimed that 254.07 ha (627.63 acres) had been set aside. US Fish and Wildlife Service, Carlsbad Fish and Wildlife Office
- Government and regulators US Fish and Wildlife Service (2008): Its records showed about 66 ha (162 acres) acquired, plus the 61 ha (150-acre) bank. US Fish and Wildlife Service, Carlsbad Fish and Wildlife Office
A conservation bank set up in 2005 on 150 acres of Delhi Sands dune habitat in Colton, California, sold one-acre credits to developers and public agencies whose projects affected the endangered Delhi Sands flower-loving fly. The credit price rose from US$100,000 to US$150,000 per credit; 28 credits had been sold by March 2008, and no source measures whether the credits offset the habitat lost at the development sites.
Count from the US Fish and Wildlife Service's 2008 five-year review; it is the only count of credits sold in the sources reviewed. One credit equals one acre.
Status As of March 2026: the fly remains listed as endangered; FWS began new five-year status reviews in 2026; the number of credits sold after March 2008 and the bank's revenue are not on record.
- Vulcan Materials — Sold credits from the bank it established in 2005; 28 credits sold by March 2008; total revenue not on record US Fish and Wildlife Service, Carlsbad Fish and Wildlife Office
- Developers and public agencies buying credits — Met habitat-compensation requirements by buying credits; the first customer was a developer, and the City of Rialto bought one acre in 2014 Ecosystem Marketplace
- City of Colton — Under the 2015 agreement with FWS the city may develop 416 acres near Interstate 10 and Pepper Avenue (press report) San Bernardino County Sentinel
- City of Colton — Officials said the fly's protection restricted growth; the city's lost-revenue estimates were not tested against a fiscal document NBC News (AP)
- Delhi Sands flower-loving fly — Over 97 percent of suitable habitat eliminated by 1993; at least 90 percent of historical Delhi Soils lost by 2008; development remained the primary threat in 2021 US Fish and Wildlife Service, Carlsbad Fish and Wildlife Office
What happened
The Delhi Sands flower-loving fly (Rhaphiomidas terminatus abdominalis), a fly of the Delhi sand dunes in inland southern California, was listed as endangered under the US Endangered Species Act on 23 September 1993 (58 FR 49881). Ecosystem Marketplace described it as the first fly ever listed, and the Associated Press as the only fly on the federal list. The US Fish and Wildlife Service (FWS) quoted the 1993 listing rule in its 2008 five-year review: "over 97 percent of the suitable habitat. primarily measured by Delhi Soils, was eliminated", mainly by agriculture and then by residential, industrial and commercial development. The FWS 1997 recovery plan said the habitat once covered approximately 40 square miles in northwestern Riverside and southwestern San Bernardino Counties, and that in spring 1997 12 sites were inhabited, with approximately 450 acres of suitable habitat.
In 2005 Vulcan Materials, Incorporated established the Colton Dunes Conservation Bank, which FWS and the City of Colton describe as 150 acres (61 ha). Ecosystem Marketplace reported that Vulcan had acquired 130 acres, and that it set up the bank with the Riverside Land Conservancy (named Rivers and Land Conservancy in the 2021 review). In a conservation bank the protected land is divided into credits that a developer can buy to meet the legal requirement to offset habitat destroyed elsewhere; at Colton Dunes one credit equals one acre. Ecosystem Marketplace reported in April 2006 that the bank had opened in June 2005, sold its first three credits by December 2005 and sold one-acre credits at US$100,000 each, a price that "has since risen to $150,000". The first customer was a developer. PBS SoCal reported that around 2008 the rumoured price reached as high as US$150,000 per acre. FWS recorded in its March 2008 review that 28 credits had been sold, and that long-term protection "will be assured when all conservation credits are sold". A 2014 FWS notice recorded the City of Rialto buying one acre of occupied habitat in the bank for a street-widening project that affected 0.74 acre.
Colton officials said the fly's protection restricted the city's growth. In 1999 the city manager told CBS News "There is no support for the fly", and CBS reported that the city put its lost taxes and revenue at about US$200,000 per fly. In 2007 the Associated Press wrote that the restrictions had "cost tens of millions of dollars in economic development" and the city manager called it "absurd that an economy and a community should be held hostage by a fly"; neither figure was tested against a fiscal document. In January 2006 the city adopted an emergency ordinance barring dealings in fly-affected property without a general plan amendment or conditional use permit; Vulcan said the ordinance prevented it from selling credits and that it was suing the city. The outcome of that suit is not on record. A draft Habitat Conservation Plan was prepared for Colton in June 2014, and on 2 February 2015 FWS issued the incidental take permit. The San Bernardino County Sentinel reported that the city council approved the agreement on 3 February 2015, that the city would set aside 50 acres of undisturbed riverbank as breeding habitat, and that it could develop 416 acres near Interstate 10 and Pepper Avenue. The draft plan proposed mitigation through land acquisition and credits from the Colton Dunes bank, with a 5:1 compensation ratio for certain infringements.
Earlier, the National Association of Home Builders challenged the application of the Endangered Species Act to the fly in a case arising from a San Bernardino County hospital site. The US Court of Appeals for the D.C. Circuit held on 5 December 1997 (130 F.3d 1041) that applying the Act to the fly was within Congress's commerce power; Judge Sentelle dissented. The opinion records that the county planned a US$470 million hospital, moved it 250 feet and set aside an 8.35-acre preserve; Ecosystem Marketplace reported that the item re-sited was a parking lot, at a cost "reported" at US$4 million.
FWS's reviews describe the fly's status after the bank opened. The 2008 review found that at least 90 percent of historical Delhi Soils had been lost, that urban land within Delhi Soils had risen from 53% to 64% (6,276 to 7,576 ha) between 1998 and 2004, that only about 10% of the remaining potential habitat had protected status and that 62 of 162 conserved acres were actively managed. Survey counts gave a median of 4.5 flies per sample, with no statistically significant trend; FWS wrote "if a trend exists, it is a decline". The 2021 review, signed 31 August 2021, found that the fly remained endangered, extant in all three recovery units, in five core areas (Colton Dunes Core 430 acres, Angelus 257, King is Coming 225, Hospital 111, Southridge/Teledyne 54), and that habitat destruction from development "continues to be the primary threat". It listed as a recovery action securing commitments "to direct mitigation and other funding for purchase of credits at the Colton Dune Bank". A recovery plan amendment was dated 4 October 2019, and a March 2026 FWS notice began new five-year status reviews that list the fly as endangered. No source gives a population estimate, credit sales after March 2008, or the bank's total revenue.
- 1993Fly listed as endangered under the Endangered Species Act (final rule 58 FR 49881, 23 September); the rule records over 97 percent of suitable habitat eliminated
- 1997FWS recovery plan (14 September): about 40 square miles of former habitat, 12 inhabited sites and approximately 450 acres of suitable habitat in spring 1997; D.C. Circuit upholds application of the Act to the fly (5 December)
- 1999Colton city manager says the city counts lost taxes and revenue at about US$200,000 per fly (CBS News, 27 August)
- 2005Vulcan Materials establishes the 150-acre Colton Dunes Conservation Bank (opened June); first three credits sold by December at US$100,000 per credit
- 2006Colton adopts an emergency ordinance on fly-affected property (January); Vulcan says it prevents credit sales and that it is suing; credit price reported at US$150,000
- 2007Colton offers FWS a plan to develop about 200 acres along Interstate 10 and to charge developers US$25,000 per acre purchased and protected (Associated Press, 8 February)
- 2008FWS five-year review (31 March): 28 credits sold, no change in endangered status
- 2014Colton Habitat Conservation Plan (June); FWS notice calls conservation banks the species' best chance at recovery (7 April)
- 2015FWS issues incidental take permit to Colton (2 February); city council approves the agreement (3 February)
- 2019Recovery plan amendment adds downlisting and delisting criteria (4 October)
- 2021FWS five-year review signed (31 August): fly remains endangered; development is the primary threat
- 2026FWS notice initiating five-year status reviews lists the fly as endangered (scheduled for Federal Register publication 9 March)
What was said
“The land is now dedicated in perpetuity to fly habitat. We hold the title, and the Land Conservancy maintains it”
“Industry, a non-profit group, and the government linked for a common purpose.”
“Conservation banks, like the Colton Dunes Conservation Bank, are this species' best chance at recovery.”
“There is no support for the fly”
“We believe that this fly is going extinct solely as a function of human activity”
“It's absurd that an economy and a community should be held hostage by a fly”
“There could be a fungus that cures cancer growing in the dirt here”
“There is no commerce in the Delhi Sands Flower-Loving Fly”
“if a trend exists, it is a decline”
Where accounts differ
Each party's account, side by side, with its source. The record does not settle these points; it shows them.
The city manager said in 1999 "There is no support for the fly" and, per CBS, the city estimated lost taxes and revenue at about US$200,000 per fly; in 2007 the Associated Press wrote that restrictions had cost tens of millions of dollars in economic development.
CBS NewsDescribed the fly as an indicator of a threatened dune ecosystem and conservation banks as its "best chance at recovery"; an FWS spokeswoman hoped in 2007 for a solution that would accommodate the city's economic development needs while ensuring adequate conservation.
NBC News (AP)The cost figures are the city's estimates or the reporters' characterisations; they were not audited or tested against a fiscal document.
NBC News (AP)"over 97 percent of the suitable habitat. primarily measured by Delhi Soils, was eliminated".
US Fish and Wildlife Service, Carlsbad Fish and Wildlife OfficeAt least 90 percent of historical Delhi Soils lost; urban land within Delhi Soils rose from 53% to 64% between 1998 and 2004.
US Fish and Wildlife Service, Carlsbad Fish and Wildlife Office"Less than 5 percent of the species' historic range is left".
US Fish and Wildlife ServiceThe habitat had been reduced to 2% of its former extent.
Ecosystem MarketplaceAt least 97 percent of the habitat is gone, but also that development reduced it to roughly 40 acres of Delhi Sands soils, a figure that conflicts with FWS's hundreds of acres and is not corroborated.
PBS SoCalClaimed that 254.07 ha (627.63 acres) had been set aside.
US Fish and Wildlife Service, Carlsbad Fish and Wildlife OfficeIts records showed about 66 ha (162 acres) acquired, plus the 61 ha (150-acre) bank.
US Fish and Wildlife Service, Carlsbad Fish and Wildlife OfficeThe county planned a US$470 million hospital, moved the hospital 250 feet and set aside an 8.35-acre preserve.
US Court of Appeals for the D.C. CircuitThe hospital "re-sited its parking lot by 250 feet, with an added cost to the project of a reported $4 million"; the figure is described as reported, not sourced to a filing.
Ecosystem MarketplaceHow it looked
Shown
- The bank described as an arrangement in which land is "dedicated in perpetuity to fly habitat" with the title held by Vulcan and maintenance by a land conservancy.Vulcan Materials (Brian Ferris), as reported by Ecosystem Marketplace · Ecosystem Marketplace
- Conservation banks described as the species' "best chance at recovery".US Fish and Wildlife Service · US Fish and Wildlife Service
- Fly protection described as costing the city "tens of millions of dollars" in development and about US$200,000 per fly in lost taxes and revenue.Associated Press (2007) and CBS News (1999), reporting Colton officials' estimates · NBC News (AP)
Recorded
- The 1993 listing rule records that over 97 percent of suitable habitat had been eliminated; the 2008 review records at least 90 percent of historical Delhi Soils lost.
- 28 credits had been sold by 31 March 2008; no later count of credits sold, and no revenue figure, appears in the sources reviewed.
- In 2008 about 10% of the remaining potential habitat had protected status and 62 of 162 conserved acres were actively managed.
- In 2021 FWS found habitat destruction from development "continues to be the primary threat" and listed funding for purchase of Colton Dunes credits as a recovery action.
- The D.C. Circuit held on 5 December 1997 that applying the Endangered Species Act to the fly was within Congress's commerce power.
- No source reviewed measures whether the habitat lost at development sites covered by sold credits was equivalent to the habitat protected at the bank.
In nature's name
Promised
- “The land is now dedicated in perpetuity to fly habitat. We hold the title, and the Land Conservancy maintains it” — Brian Ferris, Vulcan Materials vice president, as quoted by Ecosystem Marketplace (April 2006) Ecosystem Marketplace
- “Conservation banks, like the Colton Dunes Conservation Bank, are this species' best chance at recovery.” — US Fish and Wildlife Service (7 April 2014) US Fish and Wildlife Service
Money moved in nature's name
| What | Kind | Amount | Period |
|---|---|---|---|
| Colton Dunes credit price at opening, per one-acre credit Vulcan Materials (seller) Ecosystem Marketplace | Sales | $0.1m | 2005 |
| Colton Dunes credit price after the increase, per one-acre credit Vulcan Materials (seller) Ecosystem Marketplace | Sales | $0.15m | 2006 |
| Charge to developers per acre purchased and protected, proposed by the City of Colton City of Colton NBC News (AP) | Fees | $0.03m | 2007 |
What was measured
No source reviewed measures whether the credits sold at Colton Dunes offset the fly habitat lost at the development sites; records of impact-site losses were not found. FWS counts the bank among the fly's conserved land, and the fly remained endangered in 2021, but the sale figures and management claims are those of FWS and the bank's seller, not an independent measurement of benefit.
Findings on record
- Court or regulator ruling US Court of Appeals for the D.C. Circuit (1997-12-05) · National Association of Home Builders v. Babbitt, 130 F.3d 1041 US Court of Appeals for the D.C. Circuit
- Official audit US Fish and Wildlife Service, five-year review (2008-03-31) · Delhi Sands Flower-loving Fly 5-Year Review: Summary and Evaluation: “if a trend exists, it is a decline” US Fish and Wildlife Service, Carlsbad Fish and Wildlife Office
- Official audit US Fish and Wildlife Service, five-year review (2021-08-31) · 2021 5-year Review for Delhi Sands Flower-Loving Fly: “continues to be the primary threat” US Fish and Wildlife Service, Carlsbad
Who gained
Reached nature or the ground
Gained elsewhere
Responses on record
- Vulcan Materials (April 2006): Said the land was "dedicated in perpetuity to fly habitat", that it held the title and that the Land Conservancy maintained it; said in 2006 that the city's emergency ordinance prevented it from selling credits and that it was suing the city. · Ecosystem Marketplace
- US Fish and Wildlife Service (2008; 7 April 2014): Described conservation banks as the species' "best chance at recovery"; in 2008 wrote that long-term protection would be assured when all credits were sold. · US Fish and Wildlife Service
- City of Colton (1999–2015): Officials said the fly's protection restricted growth and revenue; in 2007 the city offered FWS a plan to develop about 200 acres along Interstate 10 and to charge developers US$25,000 per acre purchased and protected; in 2015 the council approved an agreement with FWS. · NBC News (AP)
- Rivers and Land Conservancy: No statement of its own is recorded in the sources reviewed.
In court and with insurers
Lawsuits and rulings
- 1997Defendant wonNational Association of Home Builders v. Babbitt (130 F.3d 1041)US Court of Appeals for the D.C. Circuit · Civil · National Association of Home Builders → Babbitt, as named in the case caption (federal government)
Commerce Clause challenge to applying section 9(a)(1) of the Endangered Species Act to the fly, arising from a San Bernardino County hospital site. On 5 December 1997 the court held that applying the Act to the fly was within Congress's commerce power and affirmed the district court; Judge Henderson concurred in the judgment on a different rationale and Judge Sentelle dissented. Ecosystem Marketplace reported that the Supreme Court declined to hear the case in 1998. US Court of Appeals for the D.C. Circuit
- 2006–Outcome not on recordVulcan Materials suit against the City of Colton over the 2006 emergency ordinanceNot stated in the sources reviewed · Civil · Vulcan Materials → City of Colton
Ecosystem Marketplace reported in April 2006 that Vulcan stated the city's January 2006 emergency ordinance prevented it from selling credits and that it was suing the city. The outcome is not on record. Ecosystem Marketplace
Insurers
What nature saw
Nature's report opens this page. Below: further outcomes measured on the ground.
What we don't know
Nature
Court
- Unclear Vulcan Materials suit against the City of Colton over the 2006 emergency ordinance: outcome not on record.
Accounts
Record
- None on record None on record: a credit price of US$250,000 per acre for Colton Dunes credits. The highest price in the sources reviewed is US$150,000 per credit.
- None on record None on record: total revenue of US$20 million for the Colton Dunes bank. The only count of credits sold is 28, as of March 2008, and the sources reviewed give no sale prices for individual credits.
- None on record None on record: the number of credits sold after March 2008, any credit sales price after 2008 or the total number of credits issued. The 2021 FWS review lists funding for credit purchases as a recovery action, which implies credits remained unsold in 2021.
- None on record None on record: a financial breakdown of the bank in Vulcan Materials' filings; the sources reviewed do not report one.
- None on record None on record: the outcome of Vulcan's 2006 suit against the City of Colton over the emergency ordinance.
- Not measured Not measured: whether the habitat destroyed at the sites covered by sold credits was equivalent to the habitat protected at the bank; no source reviewed records the impact-site losses.
- Not measured Not measured: the number of flies. FWS surveys are sample counts (median 4.5 per sample in 2008, range 0 to 25) and no population estimate is on record.
- Disputed Disputed: the loss of habitat is given as over 97 percent (1993), at least 90 percent of historical Delhi Soils (2008) and less than 5 percent of the historic range left (2014), on different bases.
- Disputed Disputed: the area set aside. A comment received in the 2008 review claimed 254.07 ha (627.63 acres); FWS records showed about 66 ha (162 acres) acquired plus the 61 ha (150-acre) bank.
- Unclear Unclear: the bank's size. FWS and the City of Colton give 150 acres; Ecosystem Marketplace and PBS SoCal say Vulcan acquired 130 acres. The sources do not reconcile the figures.
- Insufficient Unconfirmed: the Colton city estimates of lost revenue ("tens of millions"; about US$200,000 per fly) were not tested against any fiscal document.
Did the harm stop?
The sources reviewed show habitat loss continuing: the 2021 FWS review states that habitat destruction from development continues to be the primary threat, and that most remaining habitat lies in small fragmented parcels not actively managed.
Who paid?
Developers and public agencies that bought credits paid US$100,000 to US$150,000 per one-acre credit according to Ecosystem Marketplace (2005–2006); the City of Rialto bought one acre in 2014. Total payments are not on record. The 2021 FWS review lists securing funding for further credit purchases as a recovery action.
Sources
Government and regulators
- Delhi Sands Flower-loving Fly (Rhaphiomidas terminatus abdominalis) 5-Year Review: Summary and EvaluationUS Fish and Wildlife Service, Carlsbad Fish and Wildlife Office · 2008-03-31
- 2021 5-year Review for Delhi Sands Flower-Loving FlyUS Fish and Wildlife Service, Carlsbad · 2021-08-31
- Final Recovery Plan for the Delhi Sands Flower-Loving FlyUS Fish and Wildlife Service · 1997-09-14
- Federal Register notice, Vol. 79, No. 66 (incidental take permit notice, City of Rialto)US Fish and Wildlife Service · 2014-04-07
- Endangered and Threatened Wildlife and Plants; Initiation of 5-Year Status Reviews for 56 Pacific Southwest Species (public-inspection copy)US Fish and Wildlife Service · 2026-03-09
Courts
- National Association of Home Builders v. Babbitt, 130 F.3d 1041 (D.C. Cir. 1997), copy on FindLawUS Court of Appeals for the D.C. Circuit · 1997-12-05
Press and investigations
- Peace proposed in battle over endangered fly (Gillian Flaccus, Associated Press)NBC News (AP) · 2007-02-08
- Save the flies (Bill Whitaker)CBS News · 1999-08-27
- Walmart Developer Wants Permit to Kill Endangered Insect (Chris Clarke)PBS SoCal · 2014-07-23
- Colton Reaches Delhi Sands Fly Protection Compromise With Fish & WildlifeSan Bernardino County Sentinel · 2015-02-07
Connected cases
- US compensatory mitigation and conservation banking under the "no net loss" policy United States · 1988–2026 Related matter
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Approves conservation banks under the Endangered Species Act
- African Parks Odzala-Kokoua abuses (Republic of Congo) Republic of Congo · 2010–2025
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Funder (2024)
- Beach nourishment and armoring on Florida's loggerhead nesting beaches United States · 2011–2025
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Issued the Statewide Programmatic Biological Opinion of 13 March 2015
- Black-footed ferret cloning (Antonia) and wild plague United States · 1988–2024
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Federal agency; project partner
- CAMPFIRE and elephant trophy hunting Zimbabwe · 2010–2015
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Trophy-import regulator
- Colossal Biosciences: de-extinction ventures, funding and the Burgum remark United States · 2022–2026
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Signed a memorandum of understanding with Colossal; co-author of the July 2026 harm-definition rule
- Hawaii shallow-set longline swordfish fishery: loggerhead interaction limits, Ninth Circuit ruling and 2018 closure United States · 2004–2020
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Defendant agency (Interior)
- Lumber Liquidators Lacey Act guilty plea over Russian Far East oak flooring Russia · 2010–2024
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Co-investigator; recipient of community service payment
- Removal of the Endangered Species Act 'harm' definition United States · 2025–2026
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Agency that removed the definition from its regulations
- Starbase launch site, Boca Chica, Texas: environmental review, penalties and Starship debris United States · 2022–2025
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Federal wildlife agency; reported the fire after the first flight
- US bans DDT in 1972; bald eagle breeding pairs rebound United States · 1972–2019
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: published bald eagle population data
- Volusia County, Florida: beach driving and lighting, Endangered Species Act suit with sea turtles as named plaintiffs United States · 1995–1998
- US Fish and Wildlife Service (Government agency) — here: Listed the fly, approves the bank, issued the 2015 permit and wrote the five-year reviews; there: Named among the parties; role not described in the sources reviewed