Species Status Assessment for the Sand Verbena Moth (Copablepharon Fuscum)

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Species Status Assessment for the Sand Verbena Moth (Copablepharon fuscum)

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2019 U.S. FISH AND WILDLIFE SERVICE EXECUTIVE SUMMARY This document presents the species status assessment (SSA) for the sand verbena moth (Copablepharon fuscum), completed to characterize the species’ overall viability by using the three conservation biology principles of resiliency, redundancy and representation. We identify the species’ ecological requirements for survival and reproduction at the individual, population, and species levels, and describe risk factors influencing the species’ current and future condition. The sand verbena moth is a narrow endemic that primarily occupies nearshore areas around the Salish Sea in southern British Columbia, Canada, and northern Washington in the United States, with the exception being a single detection on the west coast of Vancouver Island, in British Columbia. Since the species was first discovered in 1994, it has been detected at 11 sites; six in Canada and five in the United States. Searches/surveys for sand verbena moth have been inconsistent in frequency, scope, and intensity, and have only provided information on species presence (e.g. positive and negative detections); the limited demographic information available for the species prevents the development of abundance estimates or population trends for the sand verbena moth. Species viability relies on interconnected healthy populations with habitat that provides for feeding, sheltering, and protection from predators, but we don’t have information to confirm dispersal between the disparate detection sites for the sand verbena moth. The sand verbena moth completes its entire life cycle on and around the yellow sand verbena plant (Abronia latifolia). The sand verbena moth mates on the plant, lays its eggs in the flowers, and feeds on the leaves and flowers of the plant during its developmental stages, shelters under it from early instar through pupation, and provides pollination services to it as a winged adult feeding on the flowers’ nectar. Resilient populations of sand verbena moth should: (1) be of sufficiently large size; (2) have dense patches of flowering A. latifolia with leaf cover totaling at least 400 m2 (0.10 ac), in loose, open sand; (3) be within maximum dispersal distance of each other; and (4) be where 30-year normal precipitation is below 1950 mm (77 in) and 30-year normal temperatures is above 7.47 °C (45 °F). Though no data exists on historical abundance and distribution of the sand verbena moth that we can compare to current condition, best available information suggests that the species has likely been negatively affected by some risk factors. For this assessment we analyzed the effects on the sand verbena moth by the following: habitat loss, modification, and fragmentation (from erosion, inundation from sea level rise and debris deposition, development, recreational/human use, and invasive plants and animals) and predations by bats, red foxes, and tiger beetles. Analysis of Current Condition Of the 11 sites with detections of the sand verbena moth there are six where it has been detected within the last five years; three in British Columbia, Canada (Goose Spit, Island View Beach/Cordova Spit, and James Island) and three in Washington in the United States (American Camp/Cattle Point, Deception Pass, and Fort Worden State Park). There was more information regarding recent detections at these six sites than for the other five, so we refer to these six sites as potential populations. Recent monitoring data (Fleckenstein et al. 2018a/b) for American Camp/Cattle Point and Fort Worden provides confidence that the species currently persists at these two sites in a self- sustaining way, meaning that the recruitment rate at these sites appears to consistently meet or exceed the mortality rates on average over time. All six of the sites with potential populations have 30-year normal precipitation below 1950 mm (77 in) and 30-year normal temperatures above 7.47 °C (45 °F) (see discussion in Section 3.0). The habitat at all six of these sites is currently affected by several risk factors on an ongoing basis, likely degrading the suitability of habitat over time. These habitat risk factors include erosion, inundation by sea water and deposit of woody debris, recreation and human use, development, and invasive plant species. Sand verbena moths at all of these sites also likely experience some level of predation by red fox, tiger beetles and bats, or other effects from invasive animal species, however, we have no information to determine whether these two factors are currently causing population-level effects at any of the sites.

We determined ratings of current site condition based on the criteria summarized in the following table: Rating Categories Mostly Somewhat Compromised Higly Criteria Stable Stable Compromised Compromised ≥ 400 m2 (0.04 ha or 4,306 ft2) total leaf cover of Abronia X X X X X X X X latifolia Patch density ≥ 25 percent leaf cover of Abronia latifolia, high X X X X flower production May –July Both 30-year normal precipitation below 1950 mm (77 in) and 30-year normal X X X X X temperatures above 7.47 °C (45 °F) Low X Moderate X Low OR X X Site Moderate Vulnerability High X X X X

Low OR Moderate OR X High

American Camp/Cattle Point has an overall site condition rating of ‘Somewhat Compromised.’ The site contains greatest area of Abronia latifolia of any of the sites and it occurs in dense patches, but ongoing erosion in the dunes and in areas along the bluffs puts portions of the habitat at risk. Additionally, invasive plant species are exerting a strong negative effect on the A. latifolia across the site. Regardless, the records of sand verbena moth detections at the site suggests it currently harbors a robust, self-sustaining population of sand verbena moths (e.g. recruitment rate at the site appears to consistently meet or exceed the mortality rate on average over time).

The other two sites in the United States with potential populations of sand verbena moth also have overall site condition ratings of ‘Somewhat Compromised.’ When last surveyed, Fort Worden had over 400 m2 (0.04 ha or 4,306 ft2) total leaf cover of Abronia latifolia but with densities of less than 25

percent leaf cover in most patches. Deception Pass has high pressure from recreation at the site and moderate to high competition with invasive plant species.

The condition of the three Canadian sites with potential populations (Goose Spit, James Island, Island View Beach/Cordova Spit) is unknown due to lack of information on the total leaf cover, leaf density, and flower density of Abronia latifolia. Information from the British Columbia Conservation Data Centre suggests that there may be ≥ 400 m2 (0.04 ha or 4,306 ft2) of A. latifolia at these sites, but we received no information regarding total leaf cover and quality of the habitat. The current condition of sites with a potential population is summarized in the table below:

≥ 400 m2 Patch density Both 30-year normal total leaf ≥ 25 percent leaf cover of precipitation below 1950 Overall site cover of Abronia latifolia, , with mm (77 in) and 30-year condition Abronia high flower production normal temperatures Site Site Name latifolia from May-July above 7.47 °C (45 °F) Vulnerability

CANADA Unknown Goose Spit no data no data yes High (missing data) Island View Unknown Beach and no data no data yes Moderate (missing data) Cordova Spit Unknown James Island no data no data yes Moderate (missing data) UNITED STATES American Camp (AC) Somewhat yes yes yes High and Cattle Compromised Point (CP) Deception Somewhat Pass State yes no yes Moderate Compromised Park Fort Worden Somewhat yes no yes Moderate State Park Compromised

Redundancy for the sand verbena moth appears to be limited to six potential populations, although the lack of information regarding presence/absence at other sites, trends in occupancy and abundance over the known range of the species, and historical redundancy make it difficult to judge whether our current estimate of low redundancy is accurate. Specifically, there has been inconsistent or little monitoring of sites where the sand verbena moth has been detected over the past 24 years. Although we have evidence to suggest that sand verbena moth populations may occur at six sites range-wide indicating low redundancy, without recent surveys for almost half the sites where the sand verbena moth has been previously detected, our estimate of redundancy is very uncertain. Our capacity to estimate representation for the sand verbena moth is limited, but we presume that it is low, based on the minimal information we have. The best available information does not indicate any behavioral or morphological diversity in the sand verbena moth. Additionally, little ecological diversity can be identified because the sand verbena moth inhabits a narrow ecological band and is restricted to a single host plant in sandy coastal habitat with maritime temperatures that exhibit little fluctuation.

There has been little genetic analysis of the sand verbena moth conducted to date and there are no data to describe the genetic representation of the species range wide. There have been no studies conducted to characterize the dispersal distance of the sand verbena moth. The sand verbena moth has been observed to fly strongly in winds between 5 and 15 km per hour and some related moth species have been documented to fly great distances, but the sand verbena moth has rarely been detected greater than 25 m (82 ft) from Abronia latifolia. There at least one report of indicating that a sand verbena moth dispersed at least 475 m (1558 ft) (Hudson 2018, in litt.; Hudson 2019, in litt.). The sites where the sand verbena moth has been detected are separated by distances that may be greater than the sand verbena moth can disperse; if this is indeed the case it would suggest that most sites have low connectivity necessary to facilitate genetic exchange, and therefore the sand verbena moths at the sites are likely to exhibit low genetic diversity. Projected future condition For our analysis of the sand verbena moth’s future condition, we considered only those risk factors for which there is enough information to reasonably predict the severity or presence of the risk factor into the future; we analyzed how changes in that severity or presence will impact sand verbena moth habitat. We evaluated future conditions based on the effects of inundation from seal level rise and coastal flooding on sand verbena moth habitat, and the effects of potential management actions on controlling invasive plant species that degrade habitat. We constructed four future scenarios and projected each scenario to a future time period of the present to 2100, corresponding to climate modeling data. The four scenarios are summarized in the table below:

Scenario #1 Scenario #2 Scenario #3 Scenario #4

Moderate carbon cuts Moderate carbon cuts Unchecked emissions Unchecked emissions (RCP4.5) (RCP4.5) (RCP8.5) (RCP8.5) Invasive management Invasive management Invasive management Invasive management (+) (=) (+) (=) We analyzed how the effects of the future scenarios changed the site condition rating for the locations with detections of the sand verbena moth. We created three condition categories to characterize future site condition as described below:

• Status Quo: Habitat for the species at the site is likely to persist in a condition similar to its current condition, or not deteriorate significantly. Due to the limited demographic data for sand verbena moth at most of these sites, this evaluation does not necessarily mean that the sand verbena moth will actually exist in good condition at the site in the future scenario, but that the current condition of the habitat at the site is not likely to decrease significantly in quantity or quality into the future. • Decreased: Some habitat may persist into the future at the site, but is likely to persist in poorer condition. • Imperiled: Significant loss of habitat is projected and extirpation of the sand verbena moth at the site, if it currently exists there, is likely in the timeframe of the future scenarios considered (by 2100).

Under our Future Condition projections, Goose Spit, Island View Beach/Cordova Spit, and Deception Pass are categorized as ‘Decreased’ under the first scenario only, though sand verbena moth may not persist at all areas of the sites. Under all other scenarios, the sites are categorized as ‘Imperiled.’ James Island is ‘Imperiled’ under all scenarios due to the projections for inundation at this low lying site. American Camp/Cattle Point will be ‘Decreased’ in Scenarios 2 and 4 due to some loss of habitat, but in the increased management scenarios (Scenario 1 and 3) the site maintains good suitable habitat and ‘Status Quo’ condition; the sand verbena moth is expected to persist at this site into the future. The majority of the suitable habitat at American Camp is expected to be unaffected by strong storm surges and inundation associated with sea level rise, but may continue to be strongly affected by invasive plant species. Cattle Point, though not expected to be inundated, is likely to experience an increased rate of erosion driven by fierce winter storms and increasing wind and wave energy. Fort Worden is likely to be in ‘Decreased’ condition but maintain enough habitat for sand verbena moth for the species to persist in all but the worst case scenario (4), where the site will be ‘Imperiled’ from a significant decrease in habitat resulting from the combination of all three risk factors. Future conditions for sites with potential populations are summarized in the table below:

Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Goose Spit Decreased Imperiled Imperiled Imperiled Island View Imperiled Imperiled Imperiled Beach/ Decreased Cordova Spit James Island Imperiled Imperiled Imperiled Imperiled American Camp/Cattle Status Quo Decreased Status Quo Decreased Point Deception Decreased Imperiled Imperiled Imperiled Pass Fort Decreased Imperiled Decreased Decreased Worden

The current level of redundancy for sand verbena moth is projected to decrease in the future. Only one of these six sites, American Camp/Cattle Point, is projected to potentially maintain enough suitable habitat for sand verbena moth to persist in all four scenarios. James Island will likely lose the low-lying areas to sea-level rise under all scenarios. Goose Spit and Fort Worden maintain enough suitable habitat for sand verbena moth to persist in at least two future scenarios. Island Beach/Cordova Spit and Deception Pass are only likely to maintain enough suitable habitat for sand verbena moth to persist in the best case scenario. Most of the sites with potential populations are clustered at the southern end of the known range of the species. The outlier is Goose Spit at the northern end of the range. If Goose Spit were to become extirpated, there would be a significant reduction in the distribution of these potential populations and therefore the species would be at greater risk from catastrophic events.

Based on the information we have, it appears that representation is currently low for sand verbena moth and if future conditions result in extirpation of some populations, any diversity that may exist range-wide will be reduced. Therefore, future representation is expected to decrease in parallel with decreased redundancy.

CONTENTS 1.0 INTRODUCTION ...... 1 1.1 Previous Federal Actions ...... 1 1.1.1 Canada ...... 1 1.1.2 United States ...... 2 1.2 Knowledge Gaps ...... 2 1.3 Analytical Framework ...... 4 2.0 SPECIES BACKGROUND ...... 7 2.1 Species Basics ...... 7 2.1.1 Taxonomy ...... 7 2.1.2 Description ...... 9 2.1.3 Life History ...... 10 2.2 Distribution ...... 14 2.3 Habitat ...... 15 2.3.1 Habitat Surveys ...... 16 2.3.2 Habitat Associations ...... 17 2.4 Sand Verbena Moth Detection Methods and Records ...... 25 2.4.1 Sand Verbena Moth Surveys ...... 25 2.4.2 Site Descriptions and Detection Information ...... 29 2.4.3 Summary of Detections and Potential Populations ...... 43 3.1 Individual Needs ...... 45 3.1.1 Leaves and flowers of Abronia latifolia ...... 45 3.1.2 Loose sandy soil ...... 45 3.1.3 Abronia latifolia in open sand areas ...... 46 3.1.4 Precipitation and temperature limitations ...... 46 3.2. Population Needs- Resiliency ...... 47 3.3 Species Needs- Representation and Redundancy ...... 50 4.0 CURRENT CONDITIONS ...... 52 4.1 Factors Influencing Viability ...... 53 4.1.1 Habitat Loss, Modification, and Fragmentation ...... 53 4.1.2 Predation ...... 66 4.1.3 Influence Diagram of Current Risk Factors ...... 70 4.1.4 Summary of habitat risk factors and overall site vulnerability ...... 70 4.2 Current Conditions Site Summary ...... 71 4.2.1 Sites with potential populations ...... 71 4.2.2 Sites with potential historic but unknown current populations ...... 75 4.2.3 Sites with unknown historic or current populations ...... 76 4.3 Current Condition 3Rs Summary ...... 78 4.3.1 Resiliency ...... 78 4.3.2 Redundancy ...... 79 4.3.3 Representation ...... 79 5.0 FUTURE CONDITIONS ...... 80 5.1 Climate Change ...... 80 5.2 Analysis of Future Condition ...... 85 5.2.1 Risk factors ...... 85 5.2.2 Influence Diagram of Future Risk Factors ...... 87 5.2.3 Descriptions of Future Scenarios ...... 87 5.2.4 Assumptions of Future Conditions ...... 89 5.2.5 Acknowledgement of Uncertainty ...... 90 5.3 Results of Future Condition Analysis ...... 90 5.3.1 Future Conditions Summary ...... 91 5.3.2 Resiliency ...... 97 5.3.3 Redundancy ...... 97 5.3.4 Representation ...... 98 6.0 SYNTHESIS ...... 98 7.0 LITERATURE CITED ...... 98 8.0 APPENDICES ...... 112 Appendix A. Additional Maps ...... 112 Appendix B. Future Conditions Site-by-Site ...... 125

ABBREVIATIONS AND ACRONYMS USED COSEWIC: Committee on the Status of Endangered Wildlife in Canada BCIRT: British Columbia Invertebrate Recovery Team NHP: Natural Heritage Program WDNR: Washington Department of Natural Resources WDFW: Washington Department of Fish and Wildlife

DEFINITION OF TERMS Detection: When a species has been collected or otherwise documented as present at a site. Erosion: When a net loss of material (usually sediment) occurs from a beach system over a defined time period. Sediment transport, in itself, is not erosion unless there is a net sediment loss from the beach. In response to erosion, a shoreline may retreat landward (Page et al. 2011, p. 12). Factor: A circumstance, fact, or influence that contributes to a result or outcome. Habitat: The natural environment in which a species occurs. Habitat Condition: The state of suitable habitat for the sand verbena moth. Inundation: to flood, cover, or overspread with water; deluge. Occupancy: When an area or space is under use by an organism, be it immature or mature. We do not include transient use in this definition. Occurrence: When a species is determined to be persistently present at a site. Normal: The 30-year average of a particular variable (e.g., temperature). Population: A breeding group of individuals with equal opportunity to mate with any other individual in the group. Risk Factor: Also known as a stressor or threat. Site: Locations where the sand verbena moth is either believed to be present or has been detected in the past.

Conversion of Some Units of Measure Meter = m = 3.28 linear feet Meter Squared = m2 = 10.76 square feet Hectare = ha = 10,000 square meters = 2.47 acres = 107639 square feet 400 m2 = 0.04 ha = 0.10 ac = 4305.56 square feet 500 m2 = 0.05 ha = 0.12 ac = 5381.96 square feet

1.0 INTRODUCTION In 2010, the U.S. Fish and Wildlife Service (Service) received a petition to list the sand verbena moth (Copablepharon fuscum) as endangered or threatened under the Endangered Species Act of 1973, as amended (Act; 16 U.S.C. 1531 et seq.) (Act) (1973, entire). We published a 90-day finding (76 FR 9309) in 2011 that found the petition presented substantial information indicating that listing the sand verbena moth may be warranted for listing under the Endangered Species Act, and that we would begin a status review of the species. This report, the Species Status Assessment (SSA) for the Sand Verbena Moth, represents our best understanding of the current and projected future condition of the species. The report is a review of the information available regarding the species’ biology and threats, an evaluation of its biological status based on that information, and an estimate of the resources and conditions needed to maintain long-term viability. The species’ current known distribution includes the southwestern portion of British Columbia Canada, and the northwest portion of Washington in the United States. 1.1 Previous Federal Actions Much like the Act in the United States, Canada has a Federal law that offers protections for species determined to be endangered or threatened with extinction, the Species At Risk Act (SARA) (2002, entire). However, there are some differences between the ways these Federal laws are enacted in each country. The evaluation of the status of imperiled species in Canada falls to an independent advisory board, the Committee on the Status of Endangered Wildlife in Canada (COSEWIC) (Waples 2013, p. 724), and compliance with protections for species listed as endangered or threatened under SARA is largely discretionary (Waples 2013, p. 724). In the United States, the Act is regulatory in nature, with listing determinations made by the Secretaries of the Departments of the Interior (DOI) and Commerce, based on recommendations of biological staff, and implemented by the Service and the National Marine Fisheries Service (NMFS) (Waples 2013, p. 724). 1.1.1 Canada The sand verbena moth was listed as endangered under SARA in 2005 based on a 2003 assessment by COSEWIC that determined the species was likely in decline due to small population size and habitat-related impacts (COSEWIC 2003, p. 23), specifically the reduction in the quantity and quality of host-plant resources from invasive species, secondary threats from human development and recreational use, and potential future threats from pesticides and sea level rise related to climate change (COSEWIC 2003, pp. 19–20). The species was re-examined and confirmed to be endangered in 2013 (COSEWIC 2013, entire). A recovery strategy was published for the sand verbena moth in 2012 that also identified critical habitat for the species (Environment Canada 2012, entire). In 2016, Parks Canada developed a Multi-species Action Plan for Pacific Rim National Park Reserve that includes specific management actions to be

taken to improve and maintain habitat for the sand verbena moth at Wickaninnish, one of the sites where the species has been detected (Parks Canada Agency 2016, pp. 11–14, 22–24). 1.1.2 United States On February 17, 2010, we received a petition, dated February 4, 2010, from WildEarth Guardians and the Xerces Society for Invertebrate Conservation requesting that the sand verbena moth be listed as endangered or threatened throughout its entire range and that critical habitat be designated under the Act (WildEarth Guardians and the Xerces Society for Invertebrate Conservation 2010) (Petition 2010)). On February 17, 2011, after evaluating all information presented in the petition, we published a 90-day finding (76 FR 9309) stating that the petition presented substantial scientific or commercial information indicating that listing the sand verbena moth may be warranted based on potential threats posed under Factor A-- The Present or Threatened Destruction, Modification, or Curtailment of Its Habitat or Range. Specifically, we found that dune stabilization and habitat conversion may pose a threat to the sand verbena moth throughout all or a significant portion of its range such that the petitioned action may be warranted. We found that information on other noted factors (recreation, coastal erosion, climate change, overutilization, disease and predations, pesticides and herbicides, and inherent biological vulnerability) failed to meet our standard for substantial scientific or commercial information indicating that they may pose a threat to the sand verbena moth such that the petitioned action may be warranted. We noted that although the petitioners presented little evidence for dune stabilization and habitat conversion beyond the opinion of COSEWIC in Canada, in cases where we have no information that would contradict the opinion of a credible expert on the species, we defer to that expert’s opinion for purposes of a 90-day finding. 1.2 Knowledge Gaps Very little information regarding the sand verbena moth exists due to its rarity and cryptic nature. Nearly all of the characteristics of the sand verbena moth and its life history are derived from to two documents, the original paper describing the sand verbena moth, Troubridge and Crabo 1995, and the Canadian determination to list the species as endangered (COSEWIC) 2003. We received some additional information that clarified our understanding of the species through information requests made to species experts, but uncertainty remains on the following topics: 1. Life history: a. The morphology of immature stages is not fully described; b. The length of developmental phases are not fully described; and c. Larval habitat is not fully characterized. 2. Habitat a. Host plant usage has not been fully characterized (e.g., specific plant part uses for each developmental phase); b. Optimal larval host plant characteristics have not been fully described (e.g., optimal density and/or ratio of flowers and foliage); and 2

c. Additional habitat characteristics such as the size, shape, and composition of sand particles and/or soil chemistry have not been defined for the sand verbena moth. 3. Minimum resource threshold for habitat a. The resource threshold for minimum patch size of a population is unknown. 4. Occupancy a. There are no estimates of occupied area available for any site where the sand verbena moth has been detected. 5. Distribution a. Surveys for sand verbena moth have focused on areas where Abronia latifolia (sand verbena moth’s host plant) occurs in patches larger than 400 m2 (4306 ft2); therefore, there is some uncertainty as to whether sand verbena moth may occur at sites with A. latifolia patches less than 400 m2 (4306 ft2). b. Surveys in Washington are estimated to have covered greater than 90 percent of potential suitable habitat, (i.e., 90 percent of areas with total host plant leaf cover of at least 400–500 m2 (4306–5382 ft2)); therefore, there is a small amount of uncertainty regarding the known distribution of the sand verbena moth associated with the remaining 10 percent of potentially suitable habitat in Washington. c. Formal surveys for the sand verbena moth have not occurred in Oregon. d. Surveys for the sand verbena moth have not occurred in California, but other moth surveys conducted in suitable habitat have resulted in the detection of other Copablepharon species, but not the sand verbena moth (Evans 2018 in litt.). 6. Previously detected occurrences a. Some detection sites included in this assessment are based on the detection of a single sand verbena moth with no subsequent detections despite additional surveys, leading to uncertainty regarding whether these sites have ever supported an actual population of sand verbena moth. b. Some sites had detections in the past suggesting there may have been a historical population there, but no recent surveys to affirm current populations at the sites. c. Some known sites have had recent detections reported by the public but no formal surveys. 7. Risk factors a. Risk factors are not fully characterized due to lack of information. b. Risk factors are not consistently characterized across all sites. 8. Genetics a. A single genetic barcoding investigation included three specimens of the sand verbena moth and yielded difficult to interpret results, therefore there is uncertainty regarding the: i. Genetic diversity within and between populations; ii. Genetic structure of populations and the species; and iii. Potential for inbreeding depression, etc.

9. Demographics a. No demographic investigation of the sand verbena moth has been conducted so we are unable to properly characterize: i. Population size; ii. Population structure; iii. Dispersal distance; iv. Genetic exchange; and v. Reproductive capacity.

1.3 Analytical Framework This SSA report is based on the SSA Framework, which is an analytical approach developed by the Service to deliver foundational science for informing all decisions under the Act (Smith et al., 2018, entire). Specifically, this SSA report summarizes and analyzes the biological information available for the sand verbena moth in order to inform decisions on whether to propose to list the species as threatened or endangered and, if so, whether to propose designating critical habitat. The assessment process and this SSA report do not represent a decision by the Service on whether or not to list a species under the Act. Instead, this SSA report provides a review of the best available information strictly related to the biological status of the sand verbena moth. The listing decision will be made by the Service after reviewing this document, all available scientific information, all public comments, and all relevant laws, regulations, and policies, and that decision will be announced in the Federal Register. Our intent is to update this SSA report as new information becomes available, and to support all functions of the Endangered Species Program (e.g., listing rules, recovery plans, Section 7 consultations) if the species is determined to warrant listing under the Act.

Figure 1. Species Status Assessment Analytic Framework The SSA framework begins with a compilation of the best available information on the species and its ecological needs at the individual, population, and/or species levels based on how environmental factors are understood to affect the species and its habitat. Next, we describe the current condition of the species’ habitat and demographics and the probable explanations for past and ongoing changes in abundance and distribution within the species’ ecological settings. Lastly, we forecast the species’ (or its habitat’s) response to probable future scenarios of environmental conditions and conservation efforts (Figure 1). The SSA uses the conservation biology principles of resiliency, redundancy, and representation (collectively known as the “3Rs”) as a lens to evaluate the current and future condition of the species (Figure 2). As a result, the SSA characterizes a species’ ability to sustain populations in the wild over time (i.e., its viability) based on the best scientific understanding of current and future abundance and distribution within the species’ ecological settings.

Figure 2: The factors that affect population resiliency, redundancy, and representation leading to an assessment of species viability. For the purpose of this assessment, we generally define viability as the likelihood of the species sustaining populations over time within a biologically meaningful timeframe. The available data allow us to reasonably predict the potential significant effects of some risk factors within the range of the sand verbena moth out to the year 2100 (approximately 80 years) (Mauger et al. 2015, entire). Resiliency, redundancy, and representation are defined as follows by (Smith et al., 2018): Resiliency is related to the ability of a population to withstand both demographic and environmental stochastic disturbance events: thus, resiliency is related to demographic factors (like population size, growth rate, and structure) that lead to an ability to absorb and bounce back from disturbance and persist at the population or meta-population scale. Resilient populations are better able to withstand disturbances such as random fluctuations in birth rates (demographic stochasticity), variations in rainfall (environmental stochasticity), or the effects of human activities. Redundancy spreads risk among multiple population or areas to minimize the risk of large-scale, high-impact, catastrophic events (e.g. tsunamis, large wildfires). Redundancy can be measured through the number and distribution of populations across the range of the species. Generally, the greater the number of populations or places a species is distributed across the landscape, the greater the chances it will withstand catastrophic events. Representation means having the breadth of genetic makeup at the species level to adapt to changing environmental conditions. Representation can be measured through the genetic diversity within and among populations and the ecological diversity (also called environmental variation or diversity) of populations across the species’ range. The more representation, or

diversity, a species has, the more it is capable of adapting to changes (natural or human caused) in its environment. 2.0 SPECIES BACKGROUND

2.1 Species Basics

2.1.1 Taxonomy

Scientific Name: Copablepharon fuscum Troubridge and Crabo, 1995. Synonyms: None found Moths of North America Number: 10692.2 The taxonomic classification of the species is shown below (Table 1).

Table 1. Taxonomy of Copablepharon fuscum. Order Lepidoptera

Superfamily Noctuoidea Latreille, 1809 Family Noctuidae Latreille, 1809 Subfamily Noctuinae Latreille, 1809

Tribe Noctuini Rambur, 1848 Subtribe Agrotina Harris, 1841 Genus Copablepharon Harvey, 1878 Species Copablepharon fuscum Troubridge and Crabo, 1995

Noctuoidea is the largest superfamily of Lepidoptera (Regier et al. 2016, p. 2). Noctuidae, the family to which the sand verbena moth belongs, is currently estimated to be the second largest family in the Noctuoidea, with an estimated 1089 genera and 11,772 species (Van Nieukerken et al. 2011, p. 217). For the purposes of this assessment, we defer to Lafontaine’s treatment of the subfamily Noctuinae (Lafontaine 2004, pp. 13–28; Lafontaine 2010, p. 149). The Noctuinae are a subfamily of cutworms with trifid hindwing venation and setae on the tibiae and larvae with a short, flattened, frequently apically fringed spinneret (Lafontaine 2004, p. 17). The genus Copablepharon is found in the subtribe Agrotina (LaFontaine and Schmidt 2010, pp. 99– 101) and is restricted to North America (Lafontaine 2004; p. 7); twenty-three species of Copablepharon have been described (Integrated Taxonomic Information System (ITIS) 2018). Like the sand verbena moth, all species of Copablepharon occur in light (e.g. unconsolidated) sandy soils and most are restricted to active dune systems (Lafontaine 2004, p. 15). The larvae of many species of the Agrotina, to which the sand verbena moth belongs, are subterranean cutworms and live a few centimeters (cm) below the surface of the soil where they feed on root crowns and stem bases (Lafontaine 2004, p. 15). Subterranean larval habits and the occurrence of most species in xeric (very dry), uninhabited areas result in a dearth of information regarding the immature stages for most species included in the Agrotina (Lafontaine 2004, p. 15). The 7

increased number and size of leg setae on these moths, along with granulose larval skin, may be adaptations to living in coarse, sandy, arid soils from which the adult must extricate itself after emerging from its subterranean pupal cell (Lafontaine 2004, pp. 14–15). The sand verbena moth is the only species of the genus Copablepharon known to occur west of the Cascade Mountains in the northwest United States (Troubridge and Crabo 1995, p. 89; COSEWIC 2003, p. 4). The sand verbena moth was first collected in 1994 from a locality on Vancouver Island, British Columbia, Canada, recorded simply as “Saanichton;” the specimen is stored at the University of Alberta Strickland Entomological Museum (UAM 2018, entire). Saanichton is in close proximity to Island View Beach, Cordova Spit, and James Island. The same collectors trapped additional specimens of the same species in 1995 at Deception Pass State Park on Whidbey Island, Washington, United States, which were identified as a new species and described in 1995 (Troubridge and Crabo 1995, pp. 87–90). A 2014 genetic “barcoding” study of owlet moths (Noctuoidea; the group to which the genus Copablepharon belongs), was unable to differentiate between the sand-verbena moth (C. fuscum) and the Columbia dune moth (C. absidum) based on a single locus of sequence data, the cox1 gene (Zahiri et al. 2014, table S1, tree S5.). There has been no revision to the taxonomic treatment of sand-verbena moth since this study, and the taxon is still considered a distinct species. However, this new genetic information, along with a reassessment of the degree of morphological difference between the sand-verbena moth and the Columbia dune moth, has led to a suggestion that the sand-verbena moth is not a distinct species but is a variant of the Columbia dune moth (Troubridge 2019, in litt.). Shared sequence, particularly from a single gene locus such as cox1, doesn’t automatically invalidate previously identified species designations, but indicates that further analysis is warranted to evaluate the appropriate designation; data from additional gene loci (including data based on both mitochondrial and nuclear genomes) would be helpful in corroborating the cox1 data and gene phylogenies (Barton 2019, in litt.; Soza 2019 (in Combs 2019a, in litt.)). Furthermore, regardless of the exact degree of morphological and genetic differences, the sand-verbena moth’s unique ecological preferences (mentioned above and described in greater detail below), as well as its unique wing coloration and seasonal activity patterns are important factors in justifying it’s taxonomic separation (Crabo 2019, in litt.; Combs 2019a; in litt.; Hammond 2019, in litt.; Schmidt 2019, in litt.). Though the two species are likely closely related, several experts believe the sand-verbena moth is properly classified as a distinct species (Crabo 2019, in litt.; Schmidt 2019, in litt.). Others suggest that if it is not a distinct species, it should be classified as a subspecies of the Columbia dune moth (Combs 2019a, in litt.; Hammond 2019, in litt.) and a subspecies is still considered a listable entity under Section 3 (16) of the Act. Therefore, given the breath of expert opinions solicited for this assessment, and the lack of conclusive evidence or complete agreement on the matter, we are continuing this analysis based on the current taxonomic treatment of the sand verbena moth (Copablepharon fuscum) as a distinct species.

2.1.2 Description Sand verbena moth males and females are similar in appearance (Troubridge and Crabo 1995, p. 87). Morphologically, the sand verbena moth appears to be most closely related to the Columbia dune moth (Troubridge and Crabo 1995, p. 89), but there is no other moth that resembles the sand verbena moth where it is known to occur (COSEWIC 2003, p. 5; Potter 2018a, in litt.). The sand verbena moth is very distinctive in the genus Copablepharon due to its rich brown or dark golden color and dark hindwing, and individual specimens are readily identifiable by this character alone (Crabo 2019, in litt.). The hindwing is dark gray-brown, sometimes slightly paler and fading to white-gray near the wing base (Troubridge and Crabo 1995, p. 87; LaFontaine 2004, p. 174). The forewing base coloration has been described as either golden brown and slightly darker than the thorax (Troubridge and Crabo 1995, p. 87), or olive green ranging in color to darker olive brown (LaFontaine 2004, p. 174). The forewings have distinctive contrasting yellow streaks that extend down the wing and have black shading along the interior terminal ends (Figure 3) (LaFontaine 2004, p. 174). The forewing length of sand verbena moths is approximately 15 to 19 millimeters (mm) (0.6–0.75 (inches)(in)) (Troubridge and Crabo 1995, p. 87; LaFontaine 2004, p. 174), with a total wingspan from 35 to 40 mm (1.38 to 1.57 in) in width (BCIRT 2008, p. iv). There is a subtle difference between the sand verbena moth and the Columbia dune moth in the width of the male valve (a clasping structure of the genitalia with which the female is held during mating) (Crabo 2019, in litt.); the clasper in the sand verbena moth is wedge shaped, tapered from base to apex (Lafontaine 2004, p. 174). Female genitalia in sand verbena moths differ from the Columbia dune moth in having a shorter last segment (A8) (Lafontaine 2004, p. 174). The middle leg parts (tibiae) of all sand verbena moths have stout setae (spinose hair-like structures) (Troubridge and Crabo 1995, p. 87).

Figure 3. Upper left: Copablepharon fuscum holotype specimen (image courtesy of the Canadian National Collection of Insects, Arachnids, and Nematodes); upper right, array of C. fuscum topotypes showing variation in wing color. Source: J.T. Troubridge, in COSEWIC 2003; bottom, holotype labels from Canadian National Collection.

2.1.3 Life History Information regarding the biology and habitat requirements of the sand verbena moth is scarce (Environment Canada 2012, pp. 3, 5), but inferences about the moth’s likely biology and habitat requirements can be drawn from information about other species in the same genus (Copablepharon) and tribe (Agrotini) (see the Taxonomy section above and the Habitat section below). All species of moths in the genus Copablepharon are closely associated with light sandy soils and most are restricted to active dunes (LaFontaine 2004, p. 15). The adults emerge in spring and early summer (mid-May to mid-June), mate and lay eggs that hatch in approximately two weeks (COSEWIC 2003, p. 16; Page in litt. 2018). The sand verbena moth is believed to go through five instars before forming a pupa. Larvae burrow into the sand during the day and come to the surface at night to feed on the leaves and flowers of its host plant, the yellow sand verbena (Abronia latifolia). Due to the similarity in common names of the sand verbena moth and yellow sand verbena, we will refer to the plant by its scientific name, Abronia latifolia, throughout this document to avoid confusion. 2.1.3.1 Life Stages

The sand verbena moth completes its entire life cycle on and around the Abronia latifolia plant (Figure 4). The moth has an obligate mutualist relationship with A. latifolia (i.e., the moth feeds on the plant during immature stages and provides pollination services in its adult phase); this was previously described as an obligate parasitic relationship (COSEWIC 2003, p. 10). There is no indication that sand verbena moth is able to use alternate host-plants.

Figure 4. Life stages of Sand verbena moth

Adults The sand verbena moth flies during the onset of warmer weather in late spring (COSEWIC 2003, p. 17). Adult sand verbena moths have been observed or trapped at dusk and early evening between mid-May and early July, on or near flowering Abronia latifolia (COSEWIC 2003, p. 16; Gatten 2019, in litt.; BCIRT 2008, p. iv). Sand verbena moths may exist in the adult (winged) form for as few as 5 days or up to 21 days (BCIRT 2008, p. 1; COSEWIC 2003, p. 16), but there is no specific information available regarding the length of their adult life stage. Adult sand verbena moths feed on the nectar of yellow sand verbena, using their long proboscis to reach the interior of the trumpet-shaped flowers (COSEWIC 2003, p. 16). There is little information available regarding the reproduction of this species including its mating behavior (e.g. pheromones, mate selection) (COSEWIC 2003, p. 16). Sex ratios in early collections were recorded as evenly split (Troubridge pers. comm. 2002, cited in COSEWIC 2003, p. 13). Female sand verbena moths lay eggs singly or in groups inside the corolla of the flowers of the Abronia latifolia (Environment Canada 2012, p. 1, and BCIRT 2008, p.1). It is thought that the sand verbena moth may also lay eggs in the sand, as do other closely related species of Copablepharon (Crabo 2017, in litt.; Page 2018, in litt.). Eggs It is estimated that eggs hatch within approximately 14 days (COSEWIC 2003, p. 16). This estimate is based on knowledge of other Copablepharon species; the eggs of C. longipenne were collected immediately after oviposition and they hatched out after three weeks (Page 2018, in litt.) Larvae The sand verbena moth likely goes through five instars (developmental stages) before developing into a pupa (Miller and Hammond 2007, p. 14), but there have been no natural history studies confirming the number of instars. The larval growth rate is believed to reach its maximum during July and August in correspondence with the warmest weather (COSEWIC 2003, p. 17). The larvae appear to enter a diapause phase of unknown length during the winter months (SARA Registry 2011, p. 4; Tatum n.d., entire) to overwinter in the sand, although conditions of dormancy (e.g., depth of burial) or other overwintering strategies are unknown. Surveys conducted by Fleckenstein et al. in October and November of 2017 revealed late instar larvae at a depth of no greater than 10cm (4 in) buried in sand within a meter (3 ft) of host plant patches (Combs 2019b, in litt). Larvae may use warmer periods during the fall and spring to feed briefly on Abronia latifolia leaves (J. Tatum pers. comm., 2002 in COSEWIC 2003, p. 17). Larvae are reported to be light green in color when they hatch, changing to a grayish brown with pale longitudinal light-colored stripes as they mature (BCIRT 2008, p. 1). Early instar larvae may function as leaf miners, feeding within the epidermis of the succulent leaves (COSEWIC 2003, p. 16). Sand verbena moth larvae burrow into the sand during the day and emerge at night to feed on the leaves and flowers of the plant (COSEWIC 2003, pp. 5, 16; Troubridge and

Crabo 1995, p. 89). Larvae that were captured and raised artificially emerged to feed on new flower buds in late April and early May (J. Tatum, pers. comm., 2002, in COSEWIC 2003, p. 16) Pupae Pupation occurs between late April and late May and takes place below ground in the sand, underneath Abronia latifolia patches (COSEWIC 2003, p. 16; BCRIT 2008, p. 1). Pupae measure approximately 20 mm (0.8 in) in length, are brown in color, and are protected by a thin layer of sand particles (BCRIT 2008, p. 1). Pupae have a distinct external compartment in which the proboscis develops (Figure 5) (COSEWIC 2003, pp. 5, 16). Adults are believed to emerge after a pupation period of approximately 10 days (COSEWIC 2003, p. 16; Page 2018, in litt.)

Figure 5. A pupa of a sand verbena moth. Note the external compartment for the haustellum. Photo credit: J. Tatum

2.1.3.2 Dispersal Dispersal and colonization abilities of the sand verbena moth have not been studied (Fleckenstein et al. 2018b, p. 1; COSEWIC 2003, p. 17) and are difficult to infer from other species. There is some information indicating that sand verbena moths have the capacity to disperse at least 200 m (656 ft), since smaller suitable habitat patches have been found to host sand verbena moths when those patches are within 200 m (656 ft) of larger occupied host plant patches (COSEWIC 2003, pp. 9–10). The dispersal capacity of the sand verbena moth has been presumed to be limited, because prior to this assessment the sand verbena moth has rarely been detected at a distance greater than 25 m (82 ft) from its host plant (COSEWIC 2003, p. 10). In response to an inquiry for this assessment, Nature Conservancy Canada reported a detection of the sand verbena moth in an upland area on James Island (Hudson 2018, in litt.), but additional information regarding the detection was not available (Hudson 2019, in litt.) and the species expert in Canada indicates that there is no habitat for the sand verbena moth in the upland area identified by Nature Conservancy Canada (Page 2019a, in litt.), suggesting that the movement could have been a dispersal attempt. If the record is correct, it represents the greatest distance from Abronia latifolia where a sand verbena moth has been detected. We measured the distance between the upland polygon on James Island where Nature Conservancy Canada reported the detection and the polygons where previously confirmed detections occurred (Carlson 2019, in litt.). The distance between the center point of the nearest polygon (Powder Jetty Spit) with a confirmed detection to the closest edge of the polygon where the sand verbena moth was reported yields approximately 710 m (2329 ft). When measuring from the edge to edge of the two polygons, the distance is approximately 475 m (1558 ft).

In older reports, the sand verbena moth has been described as a strong flier (COSEWIC 2003, p. 17), so it’s possible that the sand verbena moth could exhibit robust dispersal capacity if studied. Adults disturbed while nectaring were capable of evading capture by hand net through rapid flight (COSEWIC 2003, p. 17). Additionally, the places the sand verbena moth has been detected are frequently subject to high winds (e.g., American Camp, Cattle Point, Deception Pass, Rocky Point, etc.) and sand verbena moths have been observed flying strongly in winds between 5 and 15 km per hour (COSEWIC 2003, p. 17). Several other species of noctuid moths are migratory and are able to fly relatively long distances as evidenced by a mark recapture study that recorded a maximum distance of 32 km (20 mi) for one individual (Nieminen 1996, p. 649), though most migrations were between 110 m (328 ft) to 2800 m (9186 ft) (Nieminen 1996, p. 646). Additionally, some noctuids migrate vast distances, such as the Bogong moths in Australia that move from the northeastern plains of Queensland to the Snowy Mountains in Victoria, a migration of more than 1200 km (745 mi) (Green 2011, pp 26, 27). It is reasonable to assume that sand verbena moths have the potential for high dispersal capacity based on the information received from Nature Conservancy Canada, the strength of their flight, and the ability of other noctuids to fly long distances during migration, but there is no direct information about whether or not they regularly undergo dispersal of any great distance. 2.1.3.3 Behavior/Adaptability We have little information regarding the behavior of the sand verbena moth aside from an opportunistic life history study conducted by an individual in which larvae were collected and raised on Abronia latifolia leaves in a tub outside his residence (Tatum 2018, in litt.). Few records of this work were made and the sparse information that is available is published online (Tatum 2018, in litt.). Some monophagous insects (feed on a single kind of food) are able to change from one host plant to another closely related species (Young 1997, p. 124). There is currently no evidence that the sand verbena moth uses any other plant as an adult or larval food resource aside from Abronia latifolia (COSEWIC 2003, p. 18). The closely related pink sand verbena (A. umbellata) was planted alongside A. latifolia at sites where the sand verbena moth was detected in 2011 at Wickaninnish (Collyer 2018b, in litt.). However, there have been no detections of the sand verbena moth at Wickaninnish since the initial detection of a single sand verbena moth in 2011 (Collyer 2018b, in litt.) so there has been no opportunity to determine whether or not the sand verbena moth has the capacity to use this closely related species of plant.

Figure 7. Dense Patch of Flowering Sand Verbena on Sandy Ridge. . Yellow Sand Verbena Flowers and Leaves. Figure 6 Photo by Sarina Jepsen/Xerces Society.

2.2 Distribution The sand verbena moth appears to be a narrowly distributed endemic, known only from eleven sites where positive detections of the sand verbena moth have occurred (Figure 8). In Canada, there are five sites where the sand verbena moth has been detected. One of the five sites with positive sand verbena moth detections is on the west coast of Vancouver Island (Wickaninnish), two are in the Gulf Islands (Island View Beach/Cordova Spit south and southeast of the town of Sidney, and James Island east of Sidney), and two on the east coast of Vancouver Island (Goose Spit near Comex, and Sandy Island at the northern tip of Denman Island). In the United States, there are six sites where the sand verbena moth has been detected, all in Washington State. Three of the six sites are on islands in San Juan and Island counties (American Camp/Cattle Point, Deception Pass, and Rocky Point), and three are on the shores lining the Olympic Peninsula in Jefferson and Clallam counties (Fort Worden, Graveyard Spit, and Kulakala Point).

Figure 8. Known distribution (sites with positive detections) of sand verbena moth. 2.3 Habitat The specific habitat requirements of the sand verbena moth are poorly documented. This assessment draws on information included with the original description of the sand verbena moth (Troubridge and Crabo 1995, pp. 89–90) personal observations and research conducted

by a species expert in Canada (Page 2004, entire; Page 2005, entire; Page 2018, in litt.), the classification and recovery documents for sand verbena moth in Canada (COSEWIC 2003, entire; BCIRT 2008, p. 5; Environment Canada 2012, entire), information provided by state partners (Potter 2018b, in litt.), information regarding closely related species of moths (LaFontaine 2004, pp. 13–24, 160–178) and published information on coastal dune ecosystems (Beaugrand 2010, entire; Carson et al. 1991, entire; Heathfield and Walker 2011, entire; Maun 2009, entire; Reckendorf 1998, entire; Rocchio and Crawford 2015, pp. 232–235; Wiedemann 1998, entire). From the reports available (COSEWIC 2003; Gibble and Fleckenstein 2013; Fleckenstein et al, 2018b) three points are noteworthy: 1. Sand verbena moth has consistently been found in close spatial association with Abronia latifolia. The moth and the plant appear to have an obligate mutualist relationship. Although a variety of coastal sites have been surveyed, no sand verbena moths have been recorded where A. latifolia is absent. 2. Anecdotal observations indicate that Abronia latifolia is used for all phases of sand verbena moth’s lifecycle: adult sheltering, mating, nectaring, egg-laying, and larval development. While some other moths and insects are polyphagous, using a variety of plants for nectaring and feeding, sand verbena moth is considered a monophagous species with high fidelity to A. latifolia. In a single, unreplicated feeding test, sand verbena moth larvae refused all vegetation presented to them except for A. latifolia (Tatum no date, entire). Additionally, few other plant species found on coastal beaches have the combined resources (i.e., large, nectar-rich flowers, and succulent leaves) found in A. latifolia and there are no documented observations of sand verbena moth using any other plant species as a resource. 3. Only large, flowering patches of Abronia latifolia appear to support sand verbena moth and the quality and density of A. latifolia appear to be important factors in sustaining sand verbena moth populations (BCIRT 2008, p. 5; Fleckenstein 2018b, p. 12). The sand verbena moth has only been identified from sites with patches where the total leaf cover of A. latifolia was greater than 400–500 m2 (4306–5382 ft2), both in the United States (Gibble and Fleckenstein 2013, p. 14; Fleckenstein et al. 2018a, p. 6) and in Canada (BCIRT 2008, p. 5), except at large sites where smaller (+/- 50 m2 (538 ft2)) patches occur within approximately 200 m (656 ft) of the larger habitat patches (COSEWIC 2003, pp. 9–10). 2.3.1 Habitat Surveys After the sand verbena moth was first detected in 1994, additional moth surveys were conducted at more than 60 sites throughout the coastal sand ecosystem in the Georgia Basin/Salish Sea from 2001–2007 (Page 2018, in litt.), including sites in Washington. It was from these data the relationship was established between the detection of the sand verbena moth and the size of Abronia latifolia patches with greater than 400 m2 (0.04 ha or 4,306 ft2) total leaf cover (Page 2004, p. 3). Subsequent surveys seeking to identify new occurrences have

focused on areas where at least 400 m2 (0.04 ha or 4,306 ft2) total leaf cover of A. latifolia was available (Page 2004, p. 3; Gibble and Fleckenstein 2013, p. 2; Fleckenstein et al. 2018a p. 4). However, not all sites with A. latifolia patches with total leaf cover greater than 400 m2 resulted in sand verbena moth detections, highlighting the existence of other factors affecting occupancy. Additionally, sand verbena moths have not been captured or observed in diffuse or non-flowering A. latifolia patches, suggesting that sand verbena moth is only found above a certain threshold of resource availability. The British Columbia Invertebrate Recovery Team (BCIRT) specifically cautions that the observation that sand verbena moth does not reside where A. latifolia patches have less than 500 m2 (5382 ft2) leaf cover ‘‘…is only quantitative and neither indicates this area as a minimum patch size nor suggests that patches should be managed to this size’’ (BCIRT 2008, 5). To provide more conclusive evidence for a resource threshold for sand verbena moth, comprehensive surveys for the species would need to be conducted in areas with a variety of A. latifolia patch sizes starting well below the range of 400 to 500 m2 (4306 to 5382 ft2) total leaf cover since most recent surveys have focused only on areas with patch sizes of total A. latifolia leaf cover in that range. We have little information regarding the systematic approach to developing Abronia latifolia survey criteria in the search for new occurrences in Canada, but the coastal sand ecosystem is rare and there are not a great number of sites with A. latifolia in any quantity. In 2011 and 2012, surveys of potentially suitable habitat and known occupied sites were conducted in Washington (Gibble and Fleckenstein 2013, entire). The survey methods were developed based on information provided by collaborators in Canada (Gibble and Fleckenstein 2013, p. 1). Beaches selected for habitat surveys were prioritized based on review of herbarium records, aerial photographs of the entire coastline of Washington State, and outreach to botanists and land managers (Gibble and Fleckenstein 2013, p. 2). Habitat surveys were conducted by Washington Rare Plant Care and Conservation (Rare Care) staff and volunteers alongside USFWS staff (Gibble and Fleckenstein 2013, p. 2). Extent of leaf cover and percentage of leaf cover to area occupied were estimated for each site (Gibble and Fleckenstein 2013, p. 2). These data were then used to prioritize sites with host plant leaf cover greater than 400 m2 (0.04 ha or 4,306 ft2) for light trapping surveys for the sand verbena moth (Gibble and Fleckenstein 2013, p. 2). Sand verbena moth habitat information included in the survey reports is discussed in the following sections: Habitat Associations-Abronia latifolia, and Sand Verbena Moth Detection Methods and Records. 2.3.2 Habitat Associations 2.3.2.1 Abronia latifolia The sand verbena moth is an obligate mutualist of Abronia latifolia, meaning that it depends upon A. latifolia to complete all stages of its life cycle while providing pollination services to the host plant (COSEWIC 2003, pp. iv–v). Abronia latifolia, a member of the Nyctaginaeceae family, is a long-lived perennial plant with a distinctive prostrate growth form, bright yellow umbellate flowers, succulent leaves and stems, and stout, long (up to 4.25 m (14 ft)) fusiform roots (e.g.

roots that taper at both ends) (Figure 9) (Sturtevant 1919, p. 17; Tillet 1967, p. 320; Wilson, 1972, p. 427).

Figure 9. Illustration of Abronia latifolia’s growth habit taken from Wilson 1972, p. 426.

Abronia latifolia is endemic to the Pacific Coast of North America and distributed from the Haida Gwaii Islands, British Columbia, south to Santa Barbara County, California (Tillett, 1967, p. 304). In Canada, A. latifolia is restricted to dunes and sandy spits, islands, and beaches in the Strait of Georgia, the west coast of Vancouver Island and the Haida Gwaii Islands (COSEWIC 2003, p. 11). The global rank of Abronia latifolia is G5 (“demonstrably widespread, abundant and secure”) (assessed 1988, Naturserve 2019) and the BC provincial rank is S3 (“vulnerable to extirpation or extinction”) (BC CDC 2018). Figure 10 presents a map of the known occurrences of A. latifolia in relation to the known occurrences of sand verbena moth (note: does not include occurrences as far north in Canada as Haida Gwaii).

Figure 10. Known occurrences of Abronia latifolia in relation to the known detections of sand verbena moth. Abronia latifolia is classified as a coastal species (Wilson 1972, p. 423) and can be considered either a beach or dune obligate found near sea-level (Tillet, 1967, pp. 306–307). Abronia species are not true halophytes (salt tolerant plants) and are documented as living near saline environments, but not in them (Wilson 1972, p. 425), suggesting that inundation with sea water

is likely to lead to morbidity or mortality for the plant. Abronia species do not compete well in more stable sandy areas, but tend to occur in ecologically unstable, open areas (Couch 1941, p. 206; Wilson 1972, p. 425). Abronia latifolia occurs on the relatively unstabilized mid-dune areas or in open areas on dunes stabilized by scrub vegetation (Wilson 1972, p. 427). Sand verbena moth occurs in association with Abronia latifolia in spits, dunes, and other sand- dominated coastal sites where other vegetative cover is sparse or lacking (COSEWIC 2003, pp. iv, 10–11). Abronia latifolia populations are maintained by the natural disturbance regime of coastal sites that sustains open sand areas through wave, tide, and wind disturbance (Wilson 1972, p. 427). These sites occur where coastal erosion and transport of glacially derived sand deposits has created and sustained large depositional coastal features (e.g., dunes, spits, etc.) over the long term. Observations suggest that vigor and flowering decline when sand stabilization promotes development of bryophyte or herbaceous communities (Fleckenstein et al. 2018b, p. 10). Abronia latifolia is sometimes found in grass-dominated areas; however, flowering and growth is only vigorous in patches where sand verbena is the dominant species on open sand (COSEWIC 2003, p. 1; Fleckenstein et al. 2018b, pp. 9–10). It is not known if the lower growth rate and flowering is caused by reduced light, competition for soil resources (e.g., nutrients, water), or other factors. Succession in dunes is generally initiated by stabilization of the surface by bryophytes followed by development of grass- and shrub-dominated communities (Kumler 1969, p. 702; Maun 2009, p. 10; Page et al. 2011, p. 19). Sand-dominated coastal sites are generally rare in B.C. and are typically clustered spatially because of shared physiographic conditions and coastal processes. In Washington, coastal active or stabilized dunes are most common on the coast, south of the Copalis River (Rocchio and Crawford 2015, p. 232). In the Strait of Juan de Fuca, and throughout the larger extent of the Salish Sea where the sand verbena moth has been detected or is known to occur, coastal active or stabilized dunes are found in scattered small locations (Rocchio and Crawford 2015, p. 232). The Washington Department of Natural Resources classifies the Coastal Dune ecosystem as Critically Imperiled (S1) (Rocchio and Crawford 2015, p. 232). In Canada and Washington, the vast majority of Abronia latifolia occurrences large enough to sustain the sand verbena moth are less than 5 meters (m) above sea level (COSEWIC 2003, p. 11), with American Camp/Cattle Point and possibly an area at James Island being notable exceptions. American Camp is more than 50 m (164 ft) above sea level and the Cattle Point site is approximately 37 m (120 ft) above sea level (Fleckenstein et al. 2018b, p. 19), and James Island, in Canada, may also have an occurrence that is more than 5m (16.5 ft) above sea level (Hudson 2018, in litt.). Additionally, the American Camp and Cattle Point sites are the only Washington sites where A. latifolia is found more than 100 m (328 ft) from the shore (COSEWIC 2003, p. 11). These low elevations and near-shore habitat make A. latifolia vulnerable to inundation by sea water, a condition that is presumed to be detrimental to the plant. Within sites with large populations of Abronia latifolia, the plant is often patchily distributed, with expanses of sand or grass separating dense patches (COSEWIC 2003, p. 9). Competition 20

from dune stabilizing plants appear to reduce the capacity of A. latifolia to flower and areas where the plant has been observed competing with non-native grasses report low numbers of sand verbena moth detections, despite being directly adjacent to other patches occupied by the sand verbena moth (Fleckenstein et al. 2018b, p. 12). 2.3.2.2 Soil and Land Forms All species of moths in the genus Copablepharon are closely associated with light sandy soils and most are restricted to active dunes (LaFontaine 2004, pp. 15, 24). The larvae of the sand verbena moth live under the sand at the base of the host plant, which is restricted to coastal beaches, sandy spits and islands, and open, unstable dunes (LaFontaine 2004, pp. 174–175). Abronia latifolia grows in weakly acidic (pH 5.5–6.3), sandy (dominant particle size is between 0.25–0.15 mm), and nutrient poor soils (Page 2003, in COSEWIC 2003, p. 12). It is likely that larval habitat for the sand verbena moth is limited by factors that affect the capacity of the larvae to burrow into the soil, such as moisture, compaction, and composition (Potter 2018b, in litt.). For example, in areas with high foot traffic, highly compacted sand may be vertically impenetrable and therefore inaccessible to larvae (Potter 2018b, in litt.). Beaches, dunes, sand bars, and spits have undeveloped or young soils (regosols) that are composed of sand with small amounts of silt, clay, and organic matter (Page et al. 2011, p. 14). They are typically nutrient-poor, salt-rich (particularly in the lower beach zone), and have little moisture holding capacity because of the lack of fine particles or organic matter (Page et al. 2011, p. 14). In coastal climates with high precipitation, sandy soils experience rapid leaching, acidification, and podsolisation, because of high permeability and low acid buffering capacity (Page et al. 2011, p. 15; Sevink, 1991, p. 51). Beaches are dynamic features that are shaped by wind, wave, and tidal processes as well as by sediment supply conditions, and are constantly changing through erosion and sedimentation (Page et al. 2011, p. 12). A shoreline is considered stable when sediment supply is sufficient and erosive high water events are infrequent (Page et al. 2011, p. 12). Major sources of sediment for coastal dune systems include cliff and coastal erosion, river discharge, and input from tides and washovers (Maun 2009, p. 2). New or existing sand bars, dunes, or beach ridges form from accumulated sediments when a beach receives more sediment than it loses and accretion takes place (Page et al. 2011, p. 12). Sand spits are linear to curved coastal features made of sand that are formed by the deposition of sediment into shallow water (Page et al. 2011, p. 9). They are attached at one end to a larger terrestrial land mass and their form is controlled by the movement of sand by waves and nearshore currents (Page et al. 2011, p. 9). In the Salish Sea, coastal sand is primarily associated with glacial deposits known as Quadra sand (Clague 1977, entire). 2.3.2.3 Precipitation and Temperature Sand verbena moth is primarily restricted to the coastal areas within the Salish Sea despite the range of its host plant extending from southern British Columbia to Santa Barbara County, California (COSEWIC 2003, p. 11; Fleckenstein et al. 2018a, p. 1). There are two rain shadows in 21 the Salish Sea area, one on the east side of the Coast Mountain Range on Vancouver Island, and the other falling across the surrounding nearshore areas to the north east of the Olympic Mountain Range (Klock and Mullock 2001, p. 53; WRCC 2019, p. 2). The Coast and Olympic Mountain Ranges create barriers that shield parts of the Salish Sea area from precipitation, including that from winter storms and arctic air moving inland from over the ocean; this results in decreased annual precipitation and increased temperatures in the areas encompassed by the rain shadows as compared to other coastal areas (Klock and Mullock 2001, p. 53; WRCC 2019, p. 2). When sand verbena moth was described in 1995 it was noted that the two localities where it had been collected were both within rain shadows with annual precipitation of about 600 to 800 mm (24 to 31 in), significantly less than the minimum annual precipitation areas on the outside coast receive; precipitation was considered a potential limiting factor for sand verbena moth distribution (Troubridge and Crabo 1995, p. 89 (misnumbered as 99)). To see the difference in precipitation levels between areas on the outside coast and areas where the sand verbena moth has been detected within the Coast Mountains and Olympic Mountains rain shadows, we looked at a map of the 30-year normal precipitation levels (Figure 11) (Wang et al. 2016). The 30-year normals are baseline datasets describing average monthly and annual conditions over the most recent three full decades; the current set of 30-year normals covers the period 1981-2010 (NOAA 2019, entire). As shown in Figure 11, most outside coastal areas in the Vancouver Island–Olympic Peninsula area have 30-year normal precipitation levels between to 1960 mm and 4970 mm (77 in and 195 in). Other than the coastal site at Wickaninnish that faces the Pacific Ocean and receives up to 3110 mm (122 in) of precipitation annually, the remaining ten inland sites where the sand verbena moth has been detected are in rain shadows and have much lower precipitation. These inland sites report a 30-year normal precipitation of between approximately 367 mm and 1950 mm (14.4 in to 77 in). Furthermore eight of the ten inland sites have 30-year normal precipitation of below 952 mm (37 in), and all six of the Washington sites are below 641 mm (25 in), much lower precipitation than the west coast areas of Vancouver Island or the Olympic Peninsula. Temperature may also constrain sand verbena moth distribution to maritime climates. Temperatures in maritime environments undergo less variation throughout the year than upland areas (Sunday et al. 2011, p.1824). As shown on the map of 30-year normal temperatures for the area (Figure 12) (Wang et al. 2016), the 30-year mean average temperature of areas with a sand verbena moth site is between 7.47 °C and 12.1 °C (45 °F to 54 °F). The eight sites clustered in the southern portion of the range have a 30-year mean average temperature of 9.66 °C to 12.1 °C (49 °F to 54 °F).

30-year Normal Mean Annual Precipitation in Range of Sand Verbena Moth

Figure 11. 30-year Normal Mean Annual Precipitation (mm) for the known range of the sand verbena moth.

30-year Normal Mean Annual Temperature in Range of Sand Verbena Moth

Figure 12. 30-year Normal Mean Annual Temperature for 1981-2010 across the known range of the sand verbena moth.

2.4 Sand Verbena Moth Detection Methods and Records The sand verbena moth is largely cryptic due to its primarily subterranean existence, spending approximately eleven months of the year beneath the surface of the soil during daylight hours. It is most easily detected during the flight season, which may only last between two to four weeks of the species life cycle, and may shift earlier or later in the year based on as of yet unidentified environmental cues. Additionally, the immature stages of the sand verbena moth are not fully described, so larval detections of the species are considered inconclusive due to the potential for other Noctuid moths to occur in the same habitat and feed on the same plant. However, Fleckenstein et al. found late stage larvae to be distinct from other noctuids (Combs 2019b, in litt.). 2.4.1 Sand Verbena Moth Surveys Formal surveys for the sand verbena moth have been conducted using a mix of light-trapping and hand netting, taking place during the evening hours in suitable habitat (Page 2018, in litt.; Gibble and Fleckenstein 2013, p. 2; Fleckenstein et al. 2018b, p. 5). The sand verbena moth is not typically surveyed in its immature forms, since few surveyors can differentiate between Copablepharon fuscum and other noctuid moths that may be present. Therefore, surveys have been primarily focused on detection of adults and have been timed to coincide with flight season, which generally begins in late May and continues through June (Troubridge and Crabo 1995, p. 89 (misnumbered as 99)); Page 2001–2007, unpublished data in Page 2018 in litt; BCIRT 2008, p. 1). Informal surveys for the moth have been conducted by biologists with an interest in the moth and by the general public. Some of these opportunistic surveys have resulted in photographic documents, creating records of detection at a given site, allowing us to expand our data set for detection records. Another detection technique has been to conduct larval detections by searching for fresh herbivory signature and sifting through the sand under the affected host plant until a larva is located and documented. These have been opportunistic and conducted primarily by USFWS biologists at American Camp and Kulakala Point. Fleckenstein et al. (2018b) attempted to standardize a method for conducting larval surveys to determine whether it could be used as a proxy method for adult sampling, but additional work needs to be completed before larval sampling can be recommended for broader use. However, two important pieces of information regarding larval surveys were collected during this portion of study: (1) mature larvae were found at a depth of no greater than 10 cm (4 in) beneath the surface of the sand and (2) all larvae were found within 1 m (3 ft) of the host plant (Combs 2019b, in litt.). Additionally, late stage larvae of the sand verbena moth were found to be distinct and easily differentiated from the larvae of other co-occurring noctuids (Combs 2019b, in litt.). Occurrence data for the sand verbena moth may be incomplete due to lack of information regarding the species’ resource requirements, historical distribution, and/or sensitivity of existing survey methods, but species experts and the Washington Department of Natural Resources Natural Heritage Program express high confidence that the likelihood of identifying

new occurrences outside of the surveyed area is low (Fleckenstein et al. 2019, in litt.). Because the species was first detected in 1994 (UASM117219) and described in 1995 (Troubridge and Crabo 1995, entire), there is no information available regarding the historical distribution of the sand verbena moth. The lack of historical distribution data may have artificially restricted the survey range to British Columbia, Canada, and Washington in the United States, rather than extending down into Oregon and northern California where there are extensive patches of Abronia latifolia with the potential to support a population of the sand verbena moth. Some informal surveys for the sand verbena moth have been conducted in Oregon in conjunction with monitoring for the closely related pink sand verbena (Abronia umbellata), but no Copablepharon species were detected on the Oregon coast (Fleckenstein et al. 2019, in litt.) and Copablepharon detected on the California coast have been determined to belong to another species (Evans 2018, in litt.). Lastly, survey methods may not be sensitive enough to accurately detect the sand verbena moth at sites where the species is established. For example, surveying of one site resulted in negative detections before returning a positive detection (i.e., Wickaninnish) and additional intensive survey efforts have not resulted in additional detections (Collyer 2018b, in litt.). Surveys conducted at another site returned negative detections in one year and positive detections in subsequent years (e.g., Island View Beach/Cordova Spit in 2002), suggesting that negative surveys may not indicate absence of the species. Distribution and occupancy information may be incomplete and/or inaccurate for a number of reasons. Limited qualified surveyors, limited surveyor time, and limited resources have constrained formal surveys to a few nights at a time in most years. Inclement weather and moon phase can also affect whether moths are attracted to light traps. Additionally, flight phenology may shift from year to year and may be different from site to site, so even if a site is surveyed in a given year, that survey may represent a single night or handful of nights, may be affected by weather, and could potentially take place outside the peak flight season for the moth in that year. Furthermore, insects often have complex relationships with parasitoids that build up within a population over a multi-year cycle causing population crashes followed by robust numbers in following years (Troubridge 2019, in litt.). Most surveyors trapping for sand verbena moths attempt to include at least two trap nights per site per season in an attempt to reduce the likelihood of a false negative detection, but this is likely inadequate. Thus, surveys resulting in negative detections may be attributable to generally low survey effort (e.g., a single night of surveying), shifting flight phenology, or adverse sampling conditions (e.g. unfavorable temperatures, winds, or precipitation) rather than accurately reflecting the sand verbena moth’s absence from a site. Please note that count data associated with positive detections at a site resulting from light trapping cannot be used for estimates of abundance or population size. There is currently no method for generating estimates of abundance for the sand verbena moth. Currently, survey methods only generate presence data; absence cannot be assumed based on a negative detection. A robust survey method that detects both presence and absence and is 26

implemented consistently overtime would yield more accurate demographic information for sand verbena moth occurrence locations. Our data request to the Canadian Government resulted in a response pointing us to publicly available information (Henderson 2018, in litt.). All information regarding Canadian sites was gathered from publicly available sources, received from cooperating land managers, or received from members of the public. A broad moth sampling effort was conducted at approximately 60 locations in coastal sand sites in the Georgia Basin and on the west coast of Vancouver Island from 2001–2007 (Page et al. 2011, p. 33). We do not know how many of the 60 locations included suitable sand verbena moth habitat, but combined with previous work by the author (Page 2004, entire; Page and Harcombe 2010, p. 19) we conclude that only 6 of the 60 locations had what would be considered adequate suitable habitat and, of those 6, only 4 sampling locations resulted in positive detections for the sand verbena moth at that time; Goose Spit, Sandy Island, James Island, and Island View Beach/Cordova Spit. Most sites where the sand verbena moth has been previously detected in Canada do not report formal surveying for moths since 2007 (Page 2018, in litt.); these include Goose Spit, Sandy Island, and Island View Beach/Cordova Spit. Fifteen individuals were detected during light trapping at James Island in 2007 (Page 2001–2007, unpublished data). Wickaninnish, on the west coast of Vancouver Island, was included in the broader moth surveys, but did not result in a positive detection in 2001; a single sand verbena moth was captured and photographed by a student at Wickaninnish in 2011, but no additional detections have been made despite light-trapping efforts in 2014 and 2016. In addition to formal surveys, documented, informal observations of the sand verbena moth in Canada have substantially bolstered the information available from the Canadian Government, biologists studying the sand verbena moth, and land managers regarding the presence or absence of the sand verbena moth at three sites: Wickaninnish, Goose Spit, and Island View Beach/Cordova Spit (Gatten 2019, in litt.; Ingram 2019, in litt.; McCann 2019, in litt.). In Washington, the Service funded two extensive survey and monitoring efforts for the sand verbena moth; one that took place in 2011–2012, and one that took place in 2017 (Gibble and Fleckenstein 2013, entire; Fleckenstein et al. 2018a, entire; Fleckenstein et al. 2018b, entire). The first focused on identifying and surveying the extent of likely sand verbena moth habitat (see Habitat Surveys section above). The second focused on surveying additional potentially suitable sites, re-surveying sites where previous detections had taken place, and developing standardized methods for vegetative and larval surveys. Standardization of larval surveys was not possible due to lack of information regarding the life history of the sand verbena moth specifically, but also lack of information regarding identification of immature Noctuid moths generally (e.g., there is no known larval key for species identification for the Noctuid moths within the range of the sand verbena moth, making it impossible to ensure that larvae collected and counted were, indeed, only sand verbena moth larvae, since other Noctuid moth larvae could potentially live near and feed on Abronia latifolia). Regardless, the surveyors did convey

high confidence in their ability to identify late-instar sand verbena moth larvae accurately (Combs 2019b, in litt.). There have been no efforts made to estimate the area of occupied habitat at each site, nor has there been an effort to develop population estimates for the sand verbena moth. Please note that two sites consist of two different localities: Island View Beach/Cordova Spit and American Camp/Cattle Point. Each site has more than one owner and land manager and each likely represent a single sand verbena moth population (a group of individuals with equal opportunity to mate with any other individual in the group); we therefore consider these occurrences as a single sites, despite disparate ownership and management. While Deception Pass and Rocky Point are also close to each other, they are not connected by suitable habitat and we consider them as separate sites. In Canada, there are five sites where the sand verbena moth has been detected: 1. Goose Spit near Comox 2. Sandy Island at the northern tip of Denman Island 3. James Island, east of Sidney (the town) 4. Island View Beach and Cordova Spit, south and southeast of Sidney (the town) 5. Wickaninnish on the west coast of Vancouver Island

In the United States, there are six sites where the sand verbena moth has been detected: 1. American Camp and Cattle Point 2. Deception Pass 3. Fort Worden 4. Graveyard Spit 5. Kulakala Point 6. Rocky Point

Figure 13 presents a map of all sites with known occurrences of san verbena moth along with the most recent sites that have been formally surveyed for the species and for its host plant Abronia latifolia.

Figure 13. Sites with known positive detections of san verbena moth and sites that have been formally surveyed for the species and for its host plant Abronia latifolia.

2.4.2 Site Descriptions and Detection Information

British Columbia, Canada Goose Spit Location: Goose Spit is the northernmost site where the sand verbena moth has been detected. Located on the eastern side of Vancouver Island, Goose Spit protrudes from the eastern shore of Comox bay and runs west-southwest into Comox Harbor. 29

Land Form: In the available literature, Goose Spit is referred to both as a sand spit and a sand bar (Page et al. 2011, pp. 9, 10). The spit is supplied with sand from Willemar Bluff, immediately north of the spit (Page et al. 2011, p. 56).

Land Ownership and Management: The Canadian Department of National Defense (DND) uses the greatest proportion of land on Goose Spit, but the neck of Goose Spit is designated as a local park. The roots of Abronia latifolia were a traditional food resource for the Klallam and Makah peoples of Washington; it was prepared and eaten like a potato. On Vancouver Island, the Saanich collected and ate “wild potato” from beaches; it is believed that this “wild potato” may have been A. latifolia (Turner and Bell 1973, p. 85). If the K’ómoks First Nation participates in the traditional harvest of A. latifolia as a food resource, this may impact habitat availability for the sand verbena moth or may cause direct mortality to individual adults, eggs, larvae, and pupae. There is potential for management changes to the portion of Goose Spit where sand verbena moth habitat occur if property ownership is transferred to the K’ómoks First Nation (transfer of ownership is currently pending) (Goulden 2018, in litt.).

Habitat Surveys and Condition: Monitoring for Abronia latifolia is conducted annually at the site and is incorporated in the Species at Risk plan for the Department of National Defense at Goose Spit (Goulden 2018, in litt.). An estimated 7.0 ha (17.3 ac) of sand verbena moth habitat is located at the western tip of Goose Spit on land currently managed by the Canadian Department of National Defense and is between 3–5 m (10–16 ft) above sea level (Goulden 2018, in litt.). We did not receive information from the Canadian government regarding the location of the sand verbena moth or its habitat at Goose Spit but an estimate of the total extent of the area occupied by the sand verbena moth at Goose Spit was available online from the British Columbia Conservation Data Centre; the total extent of the area occupied by the sand verbena moth at Goose Spit is estimated to be 3.4 ha (8.4 ac) with the caution that “not all of which is used by C. fuscum [the sand verbena moth]” (BCCDC 2014a, p. 3). Forest and shrubs and invasive species have increased substantially between the years of 1930 and 2004, reducing the sparsely vegetated or open sandy habitat that sand verbena requires. Dunes on Goose Spit have declined by almost 80 percent since 1930 to 2.2 ha (5.4 ac) (Page et al. 2011, p. 56).

Sand Verbena Moth Surveys: Goose Spit was last surveyed for the sand verbena moth in 2006 when seven adults were captured in light traps (Page 2001–2007, unpublished data, in Page 2018, in litt.). There have been no formal surveys conducted at the site since 2006 but a member of the public documented an observation of the sand verbena moth at Goose Spit, posting a photograph to his blog that was taken there in 2014 (Ingram 2014, entire). Additional efforts to locate the sand verbena moth at Goose Spit in 2015 were unsuccessful (Ingram 2015, entire). Whether this same member of the public participated in efforts to locate the sand verbena moth at Goose Spit in years subsequent to 2015 is unclear.

Population Assessment: The detection records and habitat information available for Goose Spit provide enough information to suggest that the site may currently support a population of sand verbena moth. Island View Beach and Cordova Spit Location: Island View Beach and Cordova Spit are part of a larger area referred to as “the Cordova Shore” that consists of the feeder bluffs at Cowichan Head, coastal wetlands, coastal sand dunes along Island View Beach, and Cordova Spit (Page 2010, entire; Page et al. 2011, p. 4). Coastal sand ecosystems make up approximately 33 ha (82 ac) of the Cordova Shore (Page 2010, p. 26), but the area occupied by the sand verbena moth or Abronia latifolia is undefined. Island View Beach runs north-south along the coast from Cordova Spit to Cowichan Head. Both Island View Beach and Cordova Spit are to the south of Sidney (the town) on Vancouver Island and slightly south and west of James Island, which is separated from the Cordova Shore by Cordova Channel.

Land Form: Cordova Spit juts out into Cordova Channel; it is supplied with sediments, in part, from the feeder bluffs at Cowichan Head (Page et al. 2011, pp. 4, 49).

Land Ownership and Management: The Capital Regional District manages the Island View Beach Regional Park and much of the southern portion of the area where suitable habitat for the sand verbena moth occurs (Capital Regional District Parks 2018, entire). Cordova Spit, traditionally identified as T�IX̱EṈ (pronounced “tee-quan”) by the first peoples, is in the process of being transferred from ownership by Central Saanich Municipal District to the Tsawout First Nation (CSMDC 2018, entire; CSMD 2019, entire). The Tsawout First Nation has proposed a Lands Project to develop and implement a multi-jurisdictional plan for the management and restoration of the rare and vulnerable coastal dune ecosystem founds at T�IX̱EṈ (Tsawout First Nation 2019, entire). The Lands Project encompasses the 325 ha (803 ac) which includes 235 ha (581 ac) of land under the jurisdiction of Tsawout First Nation, 49 ha (121 ac) managed by Capital District Regional District Parks, and 7 ha (17 ac) under the jurisdiction of Central Saanich District Municipal Parks (Tsawout First Nation 2019, p. 1). It is unclear whether the area represented in Tswaout First Nation planning document as under the jurisdiction of Central Saanich District Municipal Parks is included in the area currently in the process of being transferred to Tsawout First Nation. The Lands Project is significant because the Tsawout First Nation specifically identifies Abronia latifolia and the sand verbena moth as rare species and recommends habitat be mapped for use in the development of a conservation plan to protect vulnerable ecosystem elements and restore those that have been damaged (Tsawout First Nation 2019, pp. 1, 2).

Habitat Surveys and Condition: We did not receive information from the Canadian government regarding the location of the sand verbena moth or its habitat at Island View Beach or on Cordova Spit but an estimate of the total extent of the area occupied by the sand verbena moth at Island View Beach/Cordova Spit was available online from the British Columbia Conservation Data Centre; the total extent of the area occupied by the sand verbena moth at 31

Island View Beach/Cordova Spit is estimated to be 13.1 ha (32.3 ac) with the caution that “not all of which is used by C. fuscum [the sand verbena moth]” (BCCDC 2014b, p. 3).

Sand Verbena Moth Surveys: The last known formal survey at Island View Beach/Cordova Spit was conducted in 2003, resulting in the capture of four sand verbena moths during a single night of light trapping at Cordova Spit (Page 2001–2007, unpublished data, in Page 2018, in litt.). In 2012 a record from a publicly available website (bugguide.net) catalogs two images of one or more sand verbena moths that were reported to be taken at Island View Beach in 2012; it is unclear whether the images are of the same moth or of two different moths (Avis and Avis 2012).. Additionally, two biologists who routinely visit Island View Beach/Cordova Spit provided images of the sand verbena moth that have been taken there for all years from 2013– 2018 (Gatten 2019, in litt.; McCann 2019, in litt.).

Population Assessment: The detection records and habitat information available for Island View Beach/Cordova Spit provide enough information to suggest that the site may currently support a population of sand verbena moth. James Island Location: James Island is a small (315 ha, 778 ac), privately owned island to the east of Sidney (the town on Vancouver Island, British Columbia), and west of the small island in Haro Strait named Sidney Island (Page et al. 2011, p. 57).

Land Forms: James Island, considered with Sidney Island to the east and the Cordova Shore to the southwest, comprises the largest area of glacially deposited sand in the region (Page et al. 2010, p. 11). James Island has multiple eroding sand bluffs that feed three spits and a large dune field; Village Spit (aka North Spit) at the northern tip of the island, Powder Jetty Spit on the east side of the island, and Melanie Spit on the west side of the island (Hudson 2018, in litt.; Page et al. 2011, p. 56). Powder Jetty Spit protrudes from the north side of a remnant dune system on the southeastern side of James Island (Page et al. 2011, p. 56). Powder Jetty spit is small, runs east-west, and is covered with large woody debris.

Land Ownership and Management: This site is within the traditional territory of the Tsawout First Nation and it also known as ȽEL,TOS by Tsawout peoples (Hudson 2018, in litt.). The Tsawout Nation filed a civil claim with the Federal and provincial governments in January 2018 for ȽEL,TOS to be returned to the Nation so that they may continue to steward their territory (Supreme Court of B.C. 2018). Currently, The Nature Conservancy of Canada monitors and stewards James Island under a Conservation Covenant (Hudson 2018, in litt.).

Habitat Surveys and Conditions: We did not receive information from the Canadian government regarding the location of the sand verbena moth or its habitat at James Island but the total extent of the area occupied by the sand verbena moth at the site was estimated based on habitat polygons downloaded from the British Columbia Conservation Data Centre website (BCCDC 2014c, pp. 5 and 10); the area was estimated to be 1.1 ha (2.8 ac).

There are three areas on the island where the moth has been detected, two areas are along the shoreline and one in the uplands. The small spit at the northern end of the former dune fields located on the east side of James Island (Powder Jetty Spit) was described as supporting a healthy coastal sand ecosystem in a 2011 document evaluating the health of coastal sand ecosystems in British Columbia (Page et al. 2011, p. 56). The same document included information stating that there are populations of Abronia latifolia where the sand verbena moth has been detected (Page et al. 2011, p. 56). Of the three areas on the island where the moth has been detected, two along the shoreline appear to be exposed to routine inundation as evidenced by the presence of large woody debris that has washed over the areas and the clearly visible wrack line when viewing aerial photos. The centrally located site represents a single detection of the sand verbena moth and does not have any host plant associated with it (i.e., polygon 11 in Hudson 2018, in litt.; Hudson and Page 2019, in litt.).

Sand Verbena Moth Surveys: There is a record of a sand verbena moth detection on James Island dating from 1995 in the Nature Conservancy of Canada Land Information System Database (Hudson 2018, in litt.). Additional surveys for the sand verbena moth took place in 2007, 2014, and 2015 (Page 2001–2007, unpublished data in Page 2018, in litt.; Hudson 2018, in litt.). The 2014 and 2015 surveys identified a new detection location in the central part of the island in an upland area where the sand verbena moth had not been reported before (Hudson 2018, in litt.). There are now three areas where the sand verbena moth has been detected on James Island; one is associated with Abronia latifolia on the spit that has accreted from the north end of the island (Village Spit or North Spit), one is associated with A. latifolia in a low- lying area between a lagoon and a small creek on the eastern side of the island (Powder Jetty Spit), and third is in an upland area with no known habitat in the south central portion of the island (Hudson 2018, in litt.; Page 2019a, in litt.). In addition to the areas where the sand verbena moth has been detected, there are large patches of A. latifolia on a spit at the southern end of the island, Melanie Spit, that may harbor undetected sand verbena moths (Page 2019b, in litt.)

Population Assessment: The detection records and habitat information available for James Island suggest that the site may currently support one or more populations of sand verbena moth, all in low-lying areas along the shoreline. Sandy Island Location: Sandy Island Marine Provincial Park is also known as, “Jáji7em and Kw’ulh Marine Provincial Park” and is locally referred to as “Tree Island.” When viewed in aerial photographs, the Park appears to be part of a sandy accretion protruding from the northernmost tip of Denman Island, a part of the Northern Gulf Islands in British Columbia, Canada; the areas that are not submerged during high tide comprise a set of three small sand islands.

Land Forms: Page et al. 2011 (p. 9) refers to the north end of Denman Island as a sand bar, but does not specifically name Sandy Island as part of the sand bar. The sediment for Sandy Island comes from the Komas Bluff on northeast Denman Island (Page et al. 2011, p. 3). The park can 33

be accessed on foot at low tide from the northern tip of Denman Island or by boat. Sandy Island is just south and east of Goose Spit, near Comox.

Land Ownership and Management: Sandy Island has a history of being used for military exercises prior to being designated as a provincial park in 1966. The park currently receives recreational visitation by the public (British Columbia Parks 2018). The Master Plan for the park was completed in 1987 prior to the listing of the sand verbena moth in Canada and makes no mention of the rare species that occupy the park or list specific actions regarding their conservation (British Columbia Parks 1987, p. 34).

Habitat Surveys: We did not receive information from the Canadian government regarding the location of the sand verbena moth or its habitat at Sandy Island but the total extent of the area occupied by the sand verbena moth at the site was estimated based on habitat polygons downloaded from the British Columbia Conservation Data Centre website (BCCDC 2014d, p. 5); the area was estimated to be 4.2 ha (10.3 ac).

Sand Verbena Moth Surveys: There were two detections reported for Sandy Island; the first from 2000 when 11 adults were captured and the last in 2003 when a single moth was detected (Page 2001–2007, unpublished data, in Page 2018, in litt.). No surveys or detections at the site were reported after 2003.

Population Assessment: We do not have enough information to assess whether Sandy island currently supports a population of the sand verbena moth. Wickaninnish Location: Wickaninnish Beach is a non-gazetted site name used to describe the southernmost end of Long Beach, which is located in Pacific Rim National Park Reserve on the west coast of Vancouver Island (Collyer 2018b, in litt.). Wickaninnish Beach extends approximately 3.5 kilometers (km) (2.2 miles (mi)) from the point where Sand Hill Creek meets the Pacific Ocean south to Kwisitis (Quisitis) Point (Beaugrand 2007, p. 5; Page et al. 2011, p. 57; Collyer 2018b, in litt.). Combers Beach adjoins Wickaninnish directly to the north and transitions into Long Beach. All three beaches are collectively referred to under the umbrella of “Long Beach.” (Beaugrand 2007, p. 5; Collyer 2018b, in litt.; Heathfield and Walker 2011, p. 1186). For the purposes of site identification, we will use the name “Wickaninnish.”

Land Forms: The Wickaninnish dune complex is the largest area of active sand dunes on Vancouver Island and supports large and healthy populations of Abronia latifolia (Page et al. 2011, p. 57, Collyer 2018a, unpublished data). Wickaninnish Beach is subject to a seasonally variable, energetic wave regime (Heathfield and Walker 2011, p. 1186). The wind and wave action maintain active dune habitat (Heathfield and Walker 2011, p. 1186; Page et al. 2011, p. 9), a condition that is favorable to maintaining healthy A. latifolia populations. The beach supports a well-developed foredune and a small, stabilizing dune complex with substantial large woody debris accumulation toward the backshore (Beaugrand 2007, p. 4). Beach sediments at Wickaninnish primarily consist of well-sorted fine sands (Beaugrand 2007, p. 5). The foredunes 34

are primarily vegetated with Leymus mollis (dune wildrye) and Ammophila breviligulata (American beachgrass) (Page et al. 2011, p. 57). Over the last century, the overall extent of sparsely vegetated dunes at Wickaninnish has declined from 16.5 hectares (ha) (40.8 acres (ac)) in 1930 to 9.2 ha (22.7 ac) in 2007; a 56 percent decline (Page et. al. 2011, p. 57). The loss of active sand is attributed to stabilization by non-native beachgrass (Heathfield and Walker 2011, p. 1191).

Land Ownership and Management: Wickaninnish occurs within Pacific Rim National Park Preserve and is managed by Parks Canada. Restoration work focusing on the manual removal of beachgrass from the foredune ridge and the removal of tree islands to increase sand movement into the dune complex is ongoing (Beaugrand 2007, p. 22; Heathfield and Walker 2011, p. 1196; Collyer 2018a and 2018b in litt.). In 2017, Parks Canada developed a Multi-species Action Plan for Pacific Rim National Park Reserve that includes specific management actions to be taken to improve and maintain habitat for the sand verbena moth at Wickaninnish (Parks Canada Agency 2016, pp. 11–14, 22–24). Habitat expansion for federally listed species in Canada, and thus the sand verbena moth, is an explicit stated focus of the Multi-species Action Plan for Pacific Rim National Park Reserve of Canada (Parks Canada Agency 2017, p. 1). Ammophila arenaria, (European dune grass), an invasive, non-native, dune-stabilizing grass has been entirely removed from the area where the sand verbena moth was detected (Collyer 2018a, in litt.). Additionally, later successional plants (e.g., woody shrubs and trees) were also removed from the same area (Collyer 2018a, in litt.). A number of spruce tree islands that were formerly found in the lee of the foredune ridge and within the transgressive dune complex have now been successfully removed and restoration for Abronia umbellata (pink sand verbena), a plant closely related to the sand verbena moth host plant, has been outplanted (Collyer 2018a, in litt.). Since restoration efforts were initiated in 2010, the estimated extent of Abronia latifolia at Wickaninnish Beach has increased 220 percent (Collyer 2018a, in litt.).

Habitat Surveys and Habitat Condition: In 2017, Wickaninnish was estimated to have approximately 0.2 ha (0.5 ac) of potential habitat at the site (Collyer 2018a). Habitat for the sand verbena moth occurs in a highly active dune system toward the back dune area of Wickaninnish (Beaugrand 2007, p. 37). The area faces the ocean on the southwest side and is surrounded on the other three sides by trees, potentially offering it some protection from prevailing winter winds. The margins of the complex are colonized predominantly by Arctostaphylos uva‐ursi (kinnikinnick), Gaultheria shallon (salal), Pinus contorta (shore pine), Pseudotsuga menziesii (Douglas fir), and Picea sitchensis (Sitka spruce). Restoration of the coastal sand ecosystem has been a priority in British Columbia for several years now (see Page et al. 2011), and restoration of the dune system at Wickaninnish has been underway since 2010 (Collyer 2018, in litt.). Land managers at the Pacific Rim National Park Reserve have eliminated the non-native plant species that pose the greatest threat to sand verbena moth habitat (Collyer 2018a and 2018b, in litt.).

Sand Verbena Moth Surveys: A single adult sand verbena moth was opportunistically captured, photographed, and released during student research taking place in 2011. No positive detections have been made at Wickaninnish since that time despite additional surveys for the sand verbena moth taking place in 2014 and 2016 (Collyer 2018b, in litt.) Survey effort in 2014 and 2016 was intensive, including 17 separate trap locations along Long Beach with a total of 77 trap nights (1 trap set out for 1 night is a trap night) in 2014 and 95 trap nights in 2016 (Collyer 2018a, in litt.). The site will be surveyed for sand verbena moth again before 2021 (Collyer 2018b, in litt.). There is no additional information regarding occupancy available, so the site is treated as occupied by the Canadian Government (Parks Canada Agency 2017, p. 17). A member of the public who successfully found and photographed the sand verbena moth at another site has provided a credible statement that repeated opportunistic attempts to locate sand verbena moths at the site have also been unsuccessful (Ingram 2019, in litt.).

Population Assessment: The single positive detection in 2011 and negative detections in 2014 and 2016 do not provide enough data to determine whether Wickaninnish ever supported a population of sand verbena moth. The individual moth detected in 2011 could have been a dispersing moth from a different location or it could have been the last individual detected of from a population at Wickaninnish that was later extirpated. Washington State, United States of America American Camp and Cattle Point Location: American Camp and Cattle Point are to the south and east of the Cordova Shore by approximately 30 km (19 mi) across Haro Strait in the State of Washington of the United States. American Camp and Cattle Point are on adjoining parcels located on the south end of San Juan Island. American Camp encompasses approximately 495 ha (1223 ac) and Cattle Point consists of two waterfront parcels totaling approximately 45 ha (112 ac). Here we describe American Camp and Cattle Point separately due to differences in ownership and management, but consider them the same “site” and find that the risk factors at American Camp have broad overlap with those at Cattle Point.

Land Form: The landscape at American Camp and Cattle Point include a broad range of habitats, but is dominated by an open prairie with a centrally located active dune system. The dune system is connected to a 10 km (6 mi) beach known as South Beach that runs east-west along the southern border of the park along the Strait of Juan de Fuca (Graham 2014, p. 1). Where the beach narrows along the south side of American Camp, the feeder bluffs at Cattle Point NRCA develop.

Land Ownership and Management: American Camp is one of two units of San Juan Island National Historical Park, owned and managed by the National Park Service. The eastern border of the American Camp Unit of San Juan Island National Historical Park abuts the western edge of Cattle Point Natural Resource Conservation Area (NRCA, which is owned and managed by the Washington Department of Natural Resources (WDNR)). Natural Resource Conservation Areas

carry a designation intended to protect “outstanding examples of native ecosystems, habitat for endangered, threatened and sensitive plants and animals, and scenic landscapes.” The Cattle Point NRCA contains all three.

Habitat Surveys and Condition: When a survey of Abronia latifolia at American Camp was conducted in 2017, the extent of the area where sand verbena was detected was 23 ha (58 ac) and the estimated leaf cover was 9.3 ha (23 ac) (Fleckenstein et al. 2018b, p. 9); more than double the estimated habitat at any other site in Washington and with an estimated average total leaf cover at the site of 40 percent. The dune system includes habitat at the highest elevation known for the sand verbena moth, with the upper extent of the active dune system being an estimated 40–50 m (131–164 ft) above sea level, while the lower extent is an estimated 3.7 m (12 ft) above sea level, which is just above the wrack line on South Beach. Native plants denoted as present include: Amsinckia menziesii (Menzies’ fiddleneck) and Lupinus latifolius (broadleaf lupine). Non-native plants reported as present include: Holcus lanatus (velvet grass), Erodium cicutarium (common stork’s bill), Hypochaeris radicata (hairy cat’s ear), and Rumex acetosella (sheep’s sorrel). Additionally, these non-native plants were noted as present and identified as “invasive”: Cirsium arvense (Canada thistle), Bromus spp. (cheat grasses). Sand verbena grows gregariously throughout the sandy areas of American Camp, forming a dense flowering carpet across broad swaths of sand between the shore at South Beach and up into the active dune complex above (Fleckenstein et al. 2018b, pp. 9, 16–17) and the upland dune system at American Camp contains the most extensive Abronia latifolia population in Washington (Fleckenstein et al. 2018b, pp. 2, 8, 9), which in turn appears to support the largest population of sand verbena moth in Washington (Fleckenstein et al. 2018b, p. 8). The occupied area at American Camp is high above sea level and set back from the road in an extensive active dune system. Fleckenstein et al. (2018b, p. 9) estimated total cover of Abronia latifolia at Cattle Point to be 0.65 ha (1.6 ac) and leaf cover for sand verbena to be 0.19 ha (0.48 ac). The sand verbena moth habitat at Cattle Point is an estimated 37 m (120 ft) above sea level (Fleckenstein et al. 2018b, p. 19). Sand verbena is found along the eroding edges of the bluffs at Cattle Point, sometimes deeply surrounded by non-native plants, especially grasses.

Sand Verbena Moth Surveys: There have been three formal surveys for sand verbena moth at American Camp; 2002, 2012, and 2017. In 2002, five adults were detected (Page 2001–2007, unpublished data, in Page 2018, in litt.); in 2012, adults were reported as “found” (Gibble and Fleckenstein 2013, p. 9); and in 2017, greater than 54 adult sand verbena moths were detected (Fleckenstein et al. 2018b, p. 16) and 24 sand verbena moth larvae were counted (Fleckenstein et al. 2018b, p. 15). Informal observations of the sand verbena moth have taken place in 2006, 2015, 2016, and 2018. In 2006, adult sand verbena moths were observed to be present in the dunes of American Camp (Miskelly 2019, in litt.); in 2015 and 2016 sand verbena moth larvae

were located in the dunes of American Camp (Reagan 2015 and 2016, field notes). The difference in the number of individuals detected in combination with different reporting methods from year to year should not be interpreted as an increase or decrease in population size or condition; sampling for each study was conducted on a night-by-night basis, weather conditions varied greatly between years, and the dates and the number of sampling iterations varied from year to year. There have been no attempts made by researchers to estimate population size for the sand verbena moth. There have been two formal surveys for sand verbena moth at the Cattle Point NRCA site, one in 2012 and one in -2017. The sand verbena moth was first detected in 2012, but the number of individuals detected was not provided. In 2017, more than 29 adults were detected, but no larvae. The sand verbena moth habitat along the Cattle Point bluff is directly to the east of habitat at American Camp site by 2,200 m (7278 ft) (Fleckenstein et al. 2018b, p. 18) and the space between contains patchy, potentially suitable areas of Abronia latifolia. Because of the two sites’ proximity and similar habitat, the two areas occupied by the sand verbena moth are considered to be functioning as a single population (Page 2018, in litt.), but the habitat types are different. Fleckenstein et al. (2018b, p. 9) described the distribution of sand verbena moth habitat as “nearly contiguous throughout the sites,” referring to American Camp and Cattle Point collectively.

Population Assessment: Based on the information above, the American Camp and Cattle Point site represents the most abundant, largest, and most secure of the known sand verbena moth sites, and appears to currently support a robust, self-sustaining population of sand verbena moths (e.g. recruitment rate at the site appears to consistently meet or exceed the mortality rate on average over time). Deception Pass Location: Deception Pass is located near the northernmost point of Whidbey Island and is within Deception Pass State Park. The type locality for the sand verbena moth, which was collected from the park in May of 1995 and formally described in December of the same year.

Land Ownership and Management: Washington State Parks and Recreation manages the Deception Pass site.

Habitat Surveys and Condition: Abronia latifolia grows along the sandy western-facing edge of the park along the shoreline to the west of Cranberry Lake. In 2018, Fleckenstein et al. described A. latifolia as being in 14 discrete patches, with the total extent of the host plant estimated to be 0.51 ha (1.25 ac) and total leaf cover estimated to be 0.06 ha (0.14 ac), which is just above the 500m2 (5382 ft2) area identified as likely necessary for supporting a healthy sand verbena moth population by Fleckenstein et al. 2018b p. 24 and the Canadian Government (BCIRT 2008, p. v). This may represent poor habitat quality for the sand verbena moth (Fleckenstein et al. 2018b, p. 8). None of the individual host plant patches at Deception Pass exceeded the total leaf cover threshold of 400 m2 (4306 ft2) when the surveys were done in

2017 (Fleckenstein et al. 2018b, p. 25). Individual patches of the host plant, though not meeting the 400 m2 (4306 ft2) total leaf cover closely associated with positive sand verbena moth detections, displayed a range of leaf cover densities from 5–30 percent (Fleckenstein et al. 2018b, p.25). Fleckenstein et al. (2018b, p. 8) state that Abronia latifolia was less abundant at Deception Pass in 2017 than it was in 2012, but suggest that the site has the potential to support a robust population of Abronia latifolia with additional site management (Fleckenstein et al. 2018b p. 24.) Native plants recorded as present include: Lepidium densiflorum (common peppergrass), Oxytropis spp. (locoweed), Cakile edentula (American searocket), Grindelia spp. (gumweed), and Achillea millefolium (common yarrow) (Fleckenstein et al. 2018b, p. 24). Non- native plants reported as present include: European beachgrass (Ammophila arenaria), mouse eared chickweed (Cerastium fontanum), and California poppy (Eschscholiza californica). The estimated elevation of the sand verbena moth habitat at Deception Pass State Park is 3.7 m (12.0 ft) above sea level.

Sand Verbena Moth Surveys: There have been three formal surveys for the sand verbena moth conducted at Deception Pass State Park, including the survey that resulted in the description of the species: 1995, 2012, and 2017. There were 34 adult sand verbena moths collected in 1995 (i.e. the holotype and multiple topotype specimens): a record as “found” in 2012, with “moths” detected at all four trap locations suggesting that eight or more adult moths were detected in 2012 (Gibble and Fleckenstein 2013, p. 9); and at least 5 adult sand verbena moths detected during light trapping in 2017 (Fleckenstein et al. 2018b, p. 24); no larvae were found in the 2017 survey. Fleckenstein et al. (2018b, p. 8) speculate that this population may not be viable long term.

Population Assessment: The detection records and habitat information available for Deception Pass suggest that the site may currently support a population of sand verbena moth. Fort Worden Location: Fort Worden State Park is located just north of Port Townsend, Washington, in Jefferson County.

Land Form: Fort Worden includes a sandy protrudence known as Point Wilson. Sand verbena moth habitat at Point Wilson is comprised of beach deposits (Schasse and Slaughter 2005, entire.)

Land Ownership and Management: Washington State Parks and Recreation manages Fort Worden State Park.

Habitat Surveys and Condition: Abronia latifolia occurs from “just south of the pier at the base of the spit to the point” on the beach southwest of Point Wilson (Gibble and Fleckenstein 2013, p. 9). Fort Worden State Park was estimated to have the second largest extent of Abronia latifolia known in Washington when surveyed in 2017 (Fleckenstein et al. 2018b, p. 9). The 2017 vegetative surveys documented approximately 3.2 ha (7.9 ac) of A. latifolia across 17 patches, but leaf cover was only 5 percent across the site, resulting in a total of 0.5 ha (1.2 ac) 39

of leaf cover (Fleckenstein et al. 2018, p. 22). Of the 17 patches of A. latifolia identified, 3 provided enough total host plant leaf cover to meet or surpass the size that may be required to sustain a sand verbena moth population (400 m2 or 4306 ft 2). Leaf cover in some of the smaller patches was as high as 70 percent, suggesting that a population of sand verbena moth at this site would potentially use not only the larger patches with higher leaf cover, but may be able to use smaller patches as well. Elevation of habitat at Fort Worden ranges from “near sea level” (6.7 m or 12 feet) to approximately 7.6 m (25 ft) (Fleckenstein et al. 2018b, p. 21). Woody debris along the coastline suggests relatively frequent wave action (Fleckenstein et al. 2018b, p. 21).

Sand Verbena Moth Surveys: Surveys for sand verbena moth at Fort Worden have taken place in 2002, 2012, and 2017 (Page 2001–2007, unpublished data in Page 2018, in litt.; Gibble and Fleckenstein 2013, p. 9; Fleckenstein et al. 2018, pp. 20–21). In 2002, 29 adult moths were counted in light traps; in 2012, the sand verbena moth is reported as “found” (3 light traps deployed with “several” in each trap, so at least 9) (Gibble and Fleckenstein 2013, p. 9); in 2017, greater than 25 adult sand verbena moths were reported (Fleckenstein et al. 2018b, p. 21). The 2017 light trapping effort consisted of two events, one on May 30 and one on June 20 (Fleckenstein et al. 2018b, p. 21). The areas where moths were captured shifted from the northern part of the site with a southern aspect in May to a southern part in June (Fleckenstein et al. 2018, p. 21). Fleckenstein et al. suggest that this may be due to changes in solar insolation between the two dates (Fleckenstein et al. 2018b, p. 21).

Population Assessment: The detection records and habitat information available for Fort Worden suggest that the site may currently support a population of sand verbena moth. Graveyard Spit Location: Graveyard Spit is located in the Dungeness National Wildlife Refuge near the town of Sequim in Clallam County, on the Strait of Juan de Fuca. Graveyard Spit is a spur of sand accreting southward from the midpoint of Dungeness Spit on the eastern side.

Land Form: Graveyard Spit generally runs north-south and is approximately 2.3 km (1.4 mi) long, wider at the northern end where it connects to Dungeness Spit and narrowing toward the southern tip. Graveyard Spit has a history of military use and there are defunct structures present on the spit, including a former Navy communications facility and an abandoned cistern at the northern end of the spit. These facilities are close to where large stands of sand verbena are established (Sollmann 2018, pers. comm.). Graveyard Spit is considered a low-energy spit, largely protected from the tidal influences and storms that come from the west by the eastern face of Dungeness Spit, and therefore not exposed to high wind and wave action (Sollmann 2018, pers. comm.). Additionally, the tip of Dungeness spit curves around to the north and west, providing protection to Graveyard Spit from currents flowing out of the Salish Sea from the north and east. The minimal wind and wave exposure Graveyard Spit receives from the west and from the south likely bolsters the sediment supply and contributes to ongoing

accretion. The primary source of sediment supply for Graveyard Spit originates from the feeder bluffs directly to the west.

Land Ownership: The U.S. Fish and Wildlife Service manages the Dungeness National Wildlife Refuge, which is a component of the Washington Maritime National Wildlife Complex. Graveyard Spit is closed to recreation due to the sensitivity of the wildlife habitat located there and sand verbena moth habitat has been delineated and protected from recreational disturbance (Sollmann 2018, pers. comm.).

Habitat Surveys and Condition: In 2012, the estimated area of total leaf cover for Abronia latifolia was between 400 m2 and 500 m2 (0.04–0.05 ha or 0.10–0.12 ac) (Gibble and Fleckenstein 2013, p. 7.).

Sand Verbena Moth Surveys: There have been two formal surveys for sand verbena moth at Graveyard Spit; one in 2002 when a single adult sand verbena moth was detected, and one in 2012 in which no sand verbena moths were detected (Page 2001–2007, unpublished data; Gibble and Fleckenstein 2013, p. 9). The site was proposed to be included in the 2017 survey, but did not take place due to access issues (Fleckenstein et al 2018b, p. 4).

Population Assessment: The single positive detection of an individual moth in 2002 and negative detection in 2012 do not provide enough data to determine whether Graveyard Spit ever supported a population of sand verbena moths. The individual moth detected in 2002 may have been a dispersing individual from a different location, or it could have been the last moth detected of a population at Graveyard Spit that was later extirpated. Kulakala Point (aka Graysmarsh) Location: Kulakala Point is located in Clallam County, Washington, between Dungeness Spit and Washington Harbor. Kulakala Point is also known as Graysmarsh and is a site where a recent Habitat Conservation Plan was formalized for the conservation of Taylor’s checkerspot butterfly.

Land Form: The cape is low-lying (an estimated 2 m (6.5 ft) above sea level) and adjoins a marsh (Graysmarsh) on the landward side.

Land Ownership and Management: Kulakala Point is privately owned. Habitat Condition: The Abronia latifolia at this site is reported to occur in a “thin elevation zone in and above the driftwood zone of the beach” (Gibble and Fleckenstein 2013, p. 11) and existing at the site in “dozens of small patches” “along a quarter mile of beach,” (Radmer 2018, in litt.). The total leaf cover of A. latifolia at Kulakala Point was estimated to exceed 400 m2 (0.04 ha or 4,306 ft2) when surveyed in 2012 (Gibble and Fleckenstein 2013, p. 7).

Sand Verbena Moth Surveys: There has not been a formal survey conducted at Kulakala for the sand verbena moth since 2012, when the sand verbena moth was first detected (Gibble and Fleckenstein 2013, p. 11). While the number of moths detected is not provided by Gibble and

Fleckenstein (2013), there were three light traps deployed and each light trap is reported to have attracted “multiple” moths (p. 11). A USFWS biologist familiar with the sand verbena moth, its habitat, and who has conducted successful larval surveys in the past, conducted an opportunistic survey for the sand verbena moth at Kulakala Point during daylight hours on May 23 and 24, 2018 (Radmer 2018, in litt.). No adult moths, larvae, or pupae of the sand verbena moth were detected at that time.

Population Assessment: Because habitat at the site is in a narrow band above sea level and there is no place for Abronia latifolia to advance up the shore and little, if any, herbivory sign and no adult or immature moths in 2018, it is unlikely that a population persists at Kulakala Point. Though the 2012 detection record indicates this site may have supported a population at some point in the past, this recent search and habitat information does not provide enough information to suggest whether or not Kulakala Point currently supports a population of the species. Rocky Point Location: Rocky Point is south of Deception Pass on the western side of Whidbey Island and is a sandy beach located slightly farther to the south of the geological feature known as Rocky Point.

Land Form: Rocky Point is a sandy beach. Land Ownership and Management: Rocky Point is located at the Whidbey Island Naval Air Station and is managed by the Department of Defense.

Habitat Survey and Condition: In 2012 Rocky Point was estimated to have greater than 400 m2 (0.04 ha or 4,306 ft2) of Abronia latifolia cover (Gibble and Fleckenstein 2013, p. 14), but no estimate of total leaf cover was provided for the 2012 survey. In 2017, 10 patches of A. latifolia sand verbena were described across a 5.1 ha area (12.6 ac) with an estimated 2 percent leaf cover across the entire site (approximately 0.1 ha or 0.25 acres) and 10–40 percent leaf cover within patches (Fleckenstein et al. 2018b, p. 27–28). Total patch size summed for the 10 patches of A. latifolia surveyed in 2017 was 0.54 ha (1.33 ac) while total leaf cover summed for the 10 patches was 0.12 ha (0.30 ac) (Fleckenstein et al. 2018b, p. 27). Abronia latifolia grows along the narrow beach and the estimated elevation of sand verbena moth habitat at Rocky Point is “just above sea level” (Fleckenstein et al. 2018b, p. 27). Large woody debris is spread throughout the site, indicative of routine inundation. A. latifolia was described in ten discrete patches, and five of those patches were described as “stands,” indicating that the other five were clusters of small, diffuse plants (Fleckenstein et al. 2018b, p. 27). Other native species reported as present include: Carex macrocephala (big-head sedge), Glehnia littoralis (beach silvertop), and Elymus mollis (American dunegrass).

Sand Verbena Moth Surveys: There have been three formal surveys for sand verbena moth at Rocky Point; one in 2002 when a single adult sand verbena moth was detected, and one each in 42

2012 and 2017 in which no adults or larvae of the sand verbena moth were detected (Fleckenstein et al. 2018b, pp. 3, 27).

Population Assessment: The single positive detection of an individual moth in 2003 and negative detections in 2012 and 2017 do not provide enough data to determine whether Rocky Point ever supported a population of sand verbena moths. The individual moth detected in 2003 could have been a dispersing moth from a different location or it could have been the last moth detected of a population at Rocky Point that was later extirpated. 2.4.3 Summary of Detections and Potential Populations All the known detection records of sand verbena moths are summarized in Table 2.

• There are six sites where the species has been detected within the last five years: Goose Spit, James Island, and Island View Beach/Cordova Spit in Canada, and American Camp/Cattle Point, Deception Pass, and Fort Worden in the United States. Recurrent and recent detections suggest that populations of the sand verbena moth may persist at these six sites.

• Detection data for Sandy Island in Canada and Kulakala Point in the United States suggest there may have been populations of sand verbena moth at these two sites in the past, but we do not have enough information to determine whether either of the two sites currently supports a population of sand verbena moth.

• Wickaninnish in Canada and Graveyard Spit and Rocky Point in the United States each have a detection record of a single moth sometime in the past 20 years, but we do not have information to determine whether any of the three sites ever supported populations of sand verbena moth.

Therefore, the available detection records and habitat information suggests there are six sites that may currently support populations of sand verbena moth: 1. Goose Spit, 2. James Island, and 3. Island Beach/Cordova in Canada, and 4. American Camp/Cattle Point, 5. Deception Pass, and 6. Fort Worden in the United States.

Table 2. All known detection records for sand verbena moth, including additional data available for each detection site. Notes: The sites that we consider potential populations are highlighted in green. Negative detections are indicated with a 0 in the cell. Grayed out cells indicate no detection record found for that site in that year/s. CANADA UNITED STATES Island View Beach Site Name and James American Camp (AC) Deception Goose Spit Cordova Spit Island Sandy Island Wickaninnish and Cattle Point (CP) Pass Fort Worden Graveyard Spit Kulakala Point Rocky Point Municipality, Tribal, Local, Tribal, or Ownership Type and Federal Regional Private Provincial Federal State and Federal State State Federal Federal Government Government (NGO) Government Government Government Government Government Government Private Government Total Sand 7.0 (17.3 ) Extent 1.1 (2.8) 4.2 (10.3) 0.2 (0.5) AC: 23.4 (57.7) 0.5 (1.3) 3.2 (7.9) >0.04 (0.10) >0.04 (0.10) 5.1 (12.6) Verbena Patch Extent occupied CP: 0.65 (1.6) (2012) (2012) Size (hectares occupied area: (acres)) area: 13.1 (32.3) 3.4 (8.4) Leaf Cover AC: 9.34 (23.07) 0.06 (0.14) 0.49 (1.23) 0.1 (0.25) (hectares CP: 0.19 (0.48) (acres)) Leaf Cover (%) AC: 40 2 5 2 CP: 30 1994 1 34 1995 3 1 1996-1999 2000 11 2001 9 0 2002 1 AC: 5 3 29 1 1 2003 10 4 1 2004 5 2005 2 7 AC: detected adults 2006 (opportunistic) DETECTIONS 2007 15 2008 AC: detected 2009-2010 2011 1 2012 ≥1 AC/CP: ≥20 ≥12 ≥9 0 ≥9 0 2013 2 ≥1 2 found 0 AC: larvae found 2014 (opportunistic) 0 3 found AC: larvae found 2015 (opportunistic) ≥1 0 AC: larvae found 2016 (opportunistic) ≥1 AC: ≥49 ≥5 ≥25 0 2017 CP: ≥19 4 AC: abundant larvae 0 2018 found (opportunistic) (opportunistic)

3.0 SPECIES ECOLOGICAL NEEDS 3.1 Individual Needs As noted above, there is little information available regarding the life history and habitat needs of the sand verbena moth. The details that are known have been derived from observations, comparison with other Copablepharon species, estimates by field biologists and volunteers, and data collected during light trap and larval surveys. The one observation of primary importance is the close association of sand verbena moth with Abronia latifolia. Field biologists report that the sand verbena moth depends entirely on A. latifolia and the sand beneath it during all life phases (adult sheltering, mating, nectaring, egg-laying, larval development and pupation). The sand verbena moth has an obligate mutualist relationship with A. latifolia (i.e., the moth relies exclusively on the plant for egg laying, larval and adult food resources, and shelter and provides pollination services to the plant in its adult phase) (COSEWIC 2003, p. 10). Loose, sandy soil appears to be important to the sand verbena moth, because the larvae burrow in the sand during the day, and adults may deposit eggs in the sand. Finally, based on detection records, the sand verbena moth appears to be primarily associated with the climate created by the rain shadows of the Coastal and Olympic Mountains. 3.1.1 Leaves and flowers of Abronia latifolia Female sand verbena moths lay eggs singly or in groups inside the corolla of the flowers of the Abronia latifolia (Environment Canada 2012, p. 1), but may lay eggs in sand (Crabo 2017, in litt.). Sand verbena moth larvae come to the surface at night to feed on A. latifolia leaves and flowers (COSEWIC 2003, p. 16). Adult sand verbena moths feed on the nectar of the sand- verbena, using their proboscis to reach the interior of the trumpet-shaped flowers (COSEWIC 2003). 3.1.2 Loose sandy soil The sand verbena moth is closely associated with light sandy soils (LaFontaine 2004, pp. 15, 24; COSEWIC 2003, pp. iv, p. 10–11). The larvae of the sand verbena moth live under the surface of the sand at the base of the Abronia latifolia plant (LaFontaine 2004, pp. 174–175). Sand verbena moth larvae burrow into the sand during the day and emerge at night to feed on the leaves and flowers of the plant, and appear to enter a diapause of unknown length in the sand below A. latifolia during the winter months (COSEWIC 2003, pp. 5, 16; Troubridge and Crabo 1995, p. 89; LaFontaine 2004, pp. 174–175; SARA Registry 2011, p. 4; Tatum n.d., entire). It is likely that compacted soil restricts the capacity for larvae to burrow into and move through the sand (Potter 2018b, in litt.). Therefore, compacted sand or soil is not suitable habitat. Loose sandy soil may also factor into reproduction, as it is inferred through comparison with other Copablepharon species that the sand verbena moth may lay eggs in the sand at the base of A. latifolia, in addition to depositing eggs in the plant’s flowers (Crabo 2017, in litt.; Page 2018, in litt.).

3.1.3 Abronia latifolia in open sand areas Abronia latifolia populations are maintained by the natural disturbance regime of coastal areas that sustains open sand areas through wave, tide, and wind disturbance (COSEWIC 2003, p. 11). Abronia latifolia populations occur where coastal erosion and transport of glacially derived sand deposits has created and sustained large enough depositional coastal features, like dunes, and spits. In the 2012 surveys that took place in Washington State, the sand verbena moth was only found at locations that had low cover of woody debris; the presence of woody debris indicates an area receives relatively frequent disturbance from waves and salt spray, which are likely to negatively impact both Abronia latifolia and sand verbena moths (Fleckenstein et al. 2018b, p. 10). Furthermore, while A. latifolia is considered a good competitor in dune systems colonized by other early-seral, native, coastal plant species (Tillett 1967, p. 307), flowering and leaf production is much reduced where it competes with non-native plants generally, and particularly non-native rhizomatous grasses (Fleckenstein et al. 2018b, p. 12; Gibble and Fleckenstein 2013, p. 15). Additionally, in areas where the host plant has been observed competing with non-native forbs and grasses, fewer moths have been detected (Fleckenstein et al. 2018b, p. 12). 3.1.4 Precipitation and temperature limitations While the sand verbena moth is found in the maritime Salish Sea area, some other Copablepharon species are restricted to arid regions (COSEWIC 2003, p. 17). All species of Copablepharon occur in light sandy soils and most are restricted to active dunes (LaFontaine 2004, p. 15). The rain shadows caused by the Coast and the Olympic Mountain Ranges shield portions of the maritime Salish Sea area from some effects of winter storms and artic air moving inland from over the ocean; this results in decreased precipitation and increased temperatures in the rain shadow footprint in comparison to annual precipitation and temperatures in coastal areas (Klock and Mullock 2001, p. 53; WRCC 2019, p. 2). Other than the coastal site at Wickaninnish, a site that has only a single detection of an individual sand verbena moth in 2011, the remaining ten inland sites where the sand verbena moth has been detected report a 30-year normal precipitation below 1950 mm (77 in) (Wang et al. 2016). Furthermore eight of the ten inland sites have 30-year normal precipitation of below 952 mm (37 in), and all six of the Washington are below 641 mm (25 in), much lower precipitation than the west coast areas of Vancouver Island or the Olympic Peninsula. Though there have been no studies regarding moisture limitations in sand verbena moth habitat, it may be that high amounts of precipitation affect the density of the soil, and thereby limit the ability of sand verbena moth larvae to burrow below Abronia latifolia. High levels of precipitation may also temporarily inundate the soil around A. latifolia, causing the mortality of sand verbena moth larvae. The map showing 30-year normal average precipitation levels above 1950 mm (77 In) corresponds well with the distribution of sand verbena moth, suggesting that precipitation may be a useful predictor for where the sand verbena moth occurs.

Temperature may also factor that constrains sand verbena moth distribution to maritime climates. Temperatures in maritime environments undergo less variation throughout the year than upland areas (Sunday et al. 2011, p.1824). The 30-year mean average temperature of coastal areas where sand verbena moth has been detected is between 7.47 °C and 12.1 °C (45 °F to 54 °F) (Wang et al. 2016). Based on this correlation, we surmise that temperatures below 7.47 °C (45 °F) may limit the distribution of sand verbena moth. In summary, we conclude that individual sand verbena moths need (Table 3):

• Flowering populations of Abronia latifolia with high leaf cover; • Loose, open, sandy soils; away from the tidal inundation zone and, • 30-year normal precipitation of less than 1950 mm (77 in) and 30-year normal temperature greater than 7.47 °C (45 °F).

Table 3. Sand verbena moth Summary of Individual Needs Life Stage or Resource Needs Function Biological Process Larvae Protection: Loose, sandy soil around Abronia latifolia for Shelter burrowing; protection from the tidal inundation zone for larval development Food: Leaves of A. latifolia Feeding Larvae and Adult Climate Limitations: 30-year normal average precipitation below 1950 mm (77 in) and 30-year normal average temperatures Survival above 7.47 °C (45 °F). Habitat to support flowering A. latifolia: Open sand (free of Survival invasive grass) Adult Places to deposit eggs: Flowers of A. latifolia and loose sand near Breeding the base of the plant Food: Nectar of A. latifolia flowers Feeding

3.2. Population Needs- Resiliency The ability of a population to withstand stochastic disturbance is positively correlated with population size and growth rate, and may be influenced by connectivity among populations, depending on the species’ population structure. It is not possible to assess population size or growth rate for the sand verbena moth populations. No abundance data are available due to the fact there has been no method developed to collect abundance data for the sand verbena moth. Light trap surveys and field observations only provide presence data. Only patches of flowering Abronia latifolia with total area of leaf cover larger than 400 m2–500 m2 (0.04–0.05 ha or 0.10–0.12 ac) appear to support sand verbena moth populations, and the

quality and density of leaf cover and flower production within those A. latifolia patches appear to be important factors in sustaining sand verbena moth populations (Fleckenstein 2018b, p. 12, COSEWIC 2003, p. 11). Thresholds of resource availability for population persistence have been demonstrated for other insects (Forare and Solbreck, 1997, p. 259; Grez and Gonzalez 1995, p. 473). Data collected from locations where sand verbena moth has been found appears to suggest that the species has a minimum resource threshold or minimum patch size necessary to provide adequate resources to maintain a population. The Committee on the Status of Endangered Wildlife in Canada (COSEWIC) reports that the sand verbena moth has not been collected or observed in A. latifolia patches less than 400 m2–500 m2 (0.04–0.05 ha or 0.10– 0.12 ac) total leaf cover except at large sites where smaller (+/- 50 m2 (538 ft2)) satellite patches occur within approximately 200 m (656 ft) of the larger population (COSEWIC 2003, pp. 9–10); at large sites where there are additional small habitat patches, moths may be found in the smaller patches. The sand verbena moth has also only been captured in patches of A. latifolia with greater than 25 percent leaf cover (Page 2000–2001, unpublished data, in Page 2018, in litt.). The 2012 surveys for the sand verbena moth in Washington focused on areas with an estimated A. latifolia total leaf cover greater than 400 m2 (0.04 ha or 0.10 ac), which included all Washington sites where the sand verbena moth had previously been detected (Gibble and Fleckenstein 2013, p. 2). However, the authors noted that leaf cover estimates were based on surveys conducted by specially trained volunteers, but also suggested that they may not be highly accurate (Gibble and Fleckenstein 2013, p. 2, 14). Due to the rigorous training provided to the volunteers, we are confident that the estimates included in Gibble and Fleckenstein were reasonable and reliable enough to accurately prioritize sites for evaluation and light trapping. Due to the methods used to estimate cover and area and the potential for inconsistency in the reported patch sizes, we do not draw a strong conclusion about the minimum patch size needed to maintain a population of sand verbena moth. However, given the information above, a reasonable working estimate for the purposes of this assessment would be a minimum patch size of A. latifolia with total leaf cover of approximately 400 m2 (0.04 ha or 0.10 ac), with a leaf cover density of greater than 25 percent and high flower production from May to July, is required to support a self-sustaining sand verbena moth population. Connection among populations (meaning that individual populations are no farther apart than the species’ maximum dispersal distance) allows for genetic exchange and for suitable habitat patches to repopulate following local extirpation. Gene flow is crucially important for the maintenance of genetic diversity and the avoidance of inbreeding depression. We do not have adequate information to assess the population structure of the sand verbena moth, so we do not know if the moth exhibits a metapopulation structure where infrequent dispersal among population increases population persistence, or if the sites where the sand verbena moth has been detected are better described as isolated populations without dispersal (COSEWIC 2003, p. 9). If the species has historically exhibited a metapopulation structure, then dispersal is an important feature of population health. Dispersal and colonization abilities of the sand verbena moth have not been assessed (BCIRT 2008, p. 6; Fleckenstein et al. 2018b, p. 1), but several

other species of noctuid moths exhibit the capacity to fly long distances during migration. One study of multiple moth species reported migrations up 32 km (20 mi), although most were between 110 m–2800 m (328 ft–9186 ft) (Nieminen 1996, p. 646). Additionally, some noctuid moths migrate much greater distances, including one species in Australia that has been documented as migrating more than 1200 km (745 mi) (Green 2011, pp. 26, 27). Sand verbena moths have been observed flying strongly in winds between 5 and 15 km (3 and 9 mi) per hour and have been described as capable of evading capture by hand nets through rapid flight (COSEWIC 2003, p. 17), but sand verbena moths have never been documented greater than 100 m (328 ft) from dense patches of Abronia latifolia (BCIRT 2008, p. 6), except where smaller habitat patches are within 200 m (656 ft) of larger occupied host plant patches (COSEWIC 2003, pp. 9–10). This suggests that the species may not possess high dispersal capacity despite its ability to fly well. It is reasonable to infer that sand verbena moths may possess the potential for long-distance dispersal capacity, but there has been no investigation into the average or maximum dispersal distance of the sand verbena moth. The stochastic environmental events that may negatively affect population size, population growth, or connectivity of sand verbena moth populations include powerful winter storms, climatic extremes, wildfire, and strong winds during the flight season (BCIRT 2008, p. 7). Resilient populations (e.g., those that are large, have a growth rate of one or greater, and are well-connected) would help reduce the risk associated with these events. The sand verbena moth has several natural and introduced predators that could affect population size and/or growth rate and therefore affect resiliency. These include, but are not limited to: bats, tiger beetles, and red fox and are not consistent across all sites (e.g. red foxes are not common at Canadian sites). The effect of predation on populations of sand verbena moth has not been investigated, so while predation is likely common, its population effects are unknown. For a more detailed discussion of predation see the Predation section below. A summary of the sand verbena moth’s population needs is provided below in Table 4.

Table 4. Summary of sand verbena moth population needs.

Population Fitness Importance Element Healthy demography Maintain a self-sustaining group of Sufficiently large population size sand verbena moths with reduced (unknown at present) chance of inbreeding and capable of withstanding stochastic events Habitat to support healthy Provide resources to support (1) At least 400 m2 (0.04 ha or demography enough individuals to persist as a 0.10 ac) total leaf cover per site population with dense patches of Abronia latifolia (>25 percent leaf cover per patch) in loose, open sand, with high flower production from May-July; (2) 30-year normal precipitation below 1950 mm (77 in) and 30- year normal temperatures above 7.47 °C (45 °F). Connection to other Ensure the maintenance of gene Distance to other populations populations flow and provide demographic limited to maximum dispersal support to nearby populations. distance of sand verbena moth (unknown at present) Competition and predation at Reduce risk of extirpation of Sufficiently large population size levels that maintain populations with a stable or increasing population persistence population trend so that predation does not lead to population declines.

3.3 Species Needs- Representation and Redundancy

Representation: The ability of a species to adapt to physical (e.g., climate conditions, habitat conditions, or structure across large areas) and biological (e.g., novel diseases, pathogens, predators) changes in its environment presently and into the future is its adaptive capacity; it is the evolutionary capacity or flexibility of the species. Representation is the range of variation found in a species, and this variation--called adaptive diversity--is the source of species’ adaptive capabilities. Genetic diversity is the primary basis for the capacity to adapt to changing environmental conditions (Hendry et al. 2011, pp. 164-165); for adaptation to occur, there must be genetic variation upon which to draw (Lankau et al. 2011, p. 320). Gene flow is influenced by the degree of connectivity between populations and landscape permeability for any given species (Lankau et al. 2011, p. 320). To preserve the breadth of genetic diversity, it is important to maintain gene flow among populations. Phenotypic diversity (e.g., the physiological, ecological, and behavioral variation expressed by a species) is also important for adapting to changes in environmental conditions. Phenotypic variation dictates how organisms interact with their environment and how they respond to selective pressures (Hendry et al. 50

2011, p. 161). The degree of phenotypic variation is determined by the diversity of physical and biological pressures to which organisms are exposed, which vary across spatial and temporal scales. As such, species that span broad environmental gradients are considered most likely to harbor the greatest phenotypic and genetic variation (Lankau et al. 2011, p. 320). There is little ecological variation (e.g. temperature, moisture, habitat type, host plant, etc.) reflected across the sites where the sand verbena moth has been detected suggesting that the genotypic diversity for the species is likely low. Put another way, because we only find the sand verbena moth in narrow range of ecological conditions, the species is not likely to have the capacity to adapt to a broader range of ecotypes. Redundancy: The ability of a species to persist in the face of catastrophic events is reflected in sufficient number and distribution of large, stable, and connected (resilient) populations. Because the sand verbena moth was only recently described as a species (Troubridge 1995, entire), we have no information regarding its historical distribution, dispersal, or abundance. Redundancy spreads risk among multiple populations or across areas to minimize the risk due to large-scale, high-impact (i.e., catastrophic) events (Smith et al. 2018, p. 306). We can assume therefore that many populations distributed throughout the range of a species, and within its dispersal distance, would provide for more secure populations than would fewer populations restricted to only certain areas of the range (Hanski 1982, entire). Catastrophic events that could reasonably occur within the range of sand verbena moth could include extreme weather events associated with climate change, earthquakes, and tsunamis. A summary of the sand verbena moth’s species needs is provided below in Table 5.

Table 5. Summary table of the species level needs of sand verbena moth.

3Rs Needs for long-term-viability Description

Resiliency Interconnected healthy populations Populations with (1) Sufficiently large with habitat that provides for population size (unknown at present); (2) feeding, sheltering, and protection At least 400 m2 (0.10 ac) total leaf cover of from predators Abronia latifolia in dense patches (>25 percent leaf cover) in loose, open sand with high flower production from May-July; (3) Sand verbena moth populations within maximum dispersal distance of each other (unknown at present); and (4) 30-year normal precipitation below 1950 mm (77 in) and 30-year normal temperatures above 7.47 °C (45 °F)

Representation Maintain genetic diversity Not enough information to understand species needs for representation at present

Redundancy Sufficient distribution of healthy Sufficient distribution across the range to populations guard against catastrophic events

Sufficient number of healthy Sufficient number of healthy populations to populations buffer against catastrophic losses

Healthy populations of sufficient Sufficient population size corresponding to size (in population number and area the scale of the catastrophic event to occupied) maximize the opportunity for individuals to persist in an area post-disturbance

4.0 CURRENT CONDITIONS

To assess the biological status of the sand verbena moth across its range, we used the best available information. This included peer reviewed scientific literature, survey data provided by state agencies and federal contractors, and information received from land managers where the species has been detected. We drew heavily upon reports issued by the Canadian entities and the Canadian government regarding the status and recovery of the sand verbena moth in British Columbia. We additionally consulted with species experts who provided important information regarding the sand verbena moth. Here we present the current condition of each site based on each identified risk factor (e.g., stressor or potential threat) that may be

influencing the viability of the sand verbena moth at each site. Each risk factor is discussed site by site and we provide a summary by site at the end of this section. 4.1 Factors Influencing Viability In our 90-day finding (76 FR 9309) we found that the petition to list the sand verbena moth as threated or endangered (Petition 2010) presented substantial scientific or commercial information indicating that listing may be warranted based on potential threats from dune stabilization and habitat conversion throughout all or a significant portion of its range. We found that information on other noted factors (recreation, coastal erosion, climate change, overutilization, disease and predations, pesticides and herbicides, and inherent biological vulnerability) failed to meet our standard for substantial scientific or commercial information. We noted that although the petitioners presented little evidence for dune stabilization and habitat conversion beyond the opinion of the Committee on the Status of Endangered Wildlife in Canada, in cases where we have no information in our files that would contradict the opinion of a credible expert on the species, we defer to that expert’s opinion for purposes of a 90-day finding. For this assessment, we analyzed the available information on dune stabilization and habitat conversion as well as new information obtained since 2011. Sites visits and data from the 11 sites with positive detections of sand verbena moths have provided more information on effects to sand verbena moth and its habitat from coastal erosion, inundation from sea water and debris, recreational use, development, invasive plants and animals, and predation. Below, we assess risk factors for the sand verbena moth in both Canada and the United States based on the most current information we could obtain. 4.1.1 Habitat Loss, Modification, and Fragmentation The sand verbena moth is inextricably tied to the occurrence and condition of its host plant, Abronia latifolia. Abronia latifolia is a long-lived perennial that is dependent on active sand dunes and endemic to the Pacific coast (Tillett 1967, pp. 299–300). The current information available suggests that A. latifolia must persist in large patches (i.e., approximately 400 m2 (0.10 ac) total leaf cover of high enough quality (e.g., extensive flowering and leaf cover denser than 25 percent) to ensure that the adult and larval forms of the sand verbena moth have sufficient resources to feed, shelter, and reproduce. Abronia latifolia is found in areas with soils that are primarily made up of sand (e.g., dunes, eroding bluffs, shorelines) and is an early seral species, meaning that it thrives at the leading edge of the coastal plant community (Cooper 1922, p. 86 ; Kumler 1969, p. 702; McBride and Stone 1976, p. 119). Because A. latifolia thrives in well- drained shifting sand, large populations of the plant are closely associated with nearshore beaches, spits, eroding bluffs, and active sand dunes where intermittent disturbance creates open sand for recruitment and establishment of new plants. 4.1.1.1 Erosion Erosion is when a net loss of material, usually sediment, occurs from a beach, bluff, or dune system over a defined time period. Sediment transport, in itself, is not erosion unless there is a net sediment loss. In response to erosion, a shoreline may retreat landward (Page et al. 2011,

p. 12). Sediment transport and deposition can balance the net loss of material. When there is no net loss of material due to the balance of erosion and accretion, the shoreline is said to be stable. Sources for accreted materials are key components for stable shorelines. Here we specifically identify the source for the accreted materials for each site, if it is known. Currently, all identified feeder bluffs are unarmored, suggesting that accretion will likely continue to balance out loss of sediment. This could change if regulations protecting shorelines and beaches are modified to allow the armoring of bluffs. Due to the preference of Abronia latifolia for loose, sandy soils, the soil where the plant establishes and grows has a propensity to move over time if not anchored by other plants. The most expansive patches of A. latifolia usually occur within 100 m (328 ft) of the shoreline (25 m (82 ft) in most cases), which makes sand verbena moth habitat susceptible to coastal erosion and natural or human-induced changes to sand transport (BCIRT 2008, p. 5). Erosion can occur through wave action, high winds, or may be exacerbated by soil-disturbing animals (see discussion of European rabbits below). Goose Spit: Coastal armoring of the Willamar Bluffs at Comox, the feeder bluffs that provide sediment to Goose Spit, appear to have reduced sand supply at Goose Spit (Page et al. 2011, p. 49), and winter storms in 2005–2006 caused 2–10 m of the dune front at Goose Spit to erode along a 200 m stretch of beach, resulting in the loss of occupied Abronia latifolia plants (BCIRT 2008, p. 7). The British Columbia Invertebrate Recovery Team concludes that “The construction of erosion barriers to prevent/minimize further erosion of Comox bluffs has decreased sand transport to Goose Spit. This human-induced change has likely impacted the natural dynamics of sand movement within the dune ecosystem and may lead to vegetation stabilization.” (BCIRT 2008, p. 7). In 2013 the Committee on the Status of Endangered Wildlife in Canada determined that ongoing sand deposition and/or erosion of the ecosystem, especially during winter months when storm surges impact the beach areas with logs and erosion, is a threat at Goose Spit (COSEWIC 2013, p. ix). Additional shoreline stabilization projects have continued on some parts of Goose Spit (Page 2019, in litt.). Island View Beach and Cordova Spit: Page et al. 2011 reports that there has been some armoring of the feeder bluffs at Cowichan Head that supply sediment to Island View Beach and Cordova Spit (p. 49), implying that the site may be at risk of erosion. Further, the shoreline of Island View Beach is described as “active” and as a “dynamic bluff/dune/spit complex” (Capital Regional District Parks 2017, p. 24). Specifically, “the exact boundaries of the park have changed over time due to changes in the location of the normal high tide line, which forms the seaward boundary of the park. The normal high tide line is dynamic and can shift, resulting in either an eroded shoreline or a built up shoreline that starts to differ from the legal surveyed boundaries over time” (Capital Regional District 2012, p. 23). It is unclear as to whether a net loss of sediment is occurring, but considering the armoring of the feeder bluffs and the changing shoreline, we can infer that Abronia latifolia, which grows close to sea level, is likely negatively affected by erosion. However, the tip of Cordova Spit is actively accreting (Page

2019b, in litt.). In 2013 the Committee on the Status of Endangered Wildlife in Canada determined that ongoing sand deposition and/or erosion of the ecosystem, especially during winter months when storm surges impact the beach areas with logs and erosion, is a threat at Island View Beach/Cordova Spit (COSEWIC 2013, p. ix). American Camp and Cattle Point: The upland dune system at American Camp (where Abronia latifolia grows in a dense carpet and the detections of the sand verbena moth are most common) is exposed to strong winds nearly year round. Movement of sand in active dunes is an ongoing risk factor for A. latifolia at American Camp (Figure 14 below). Wind-mediated transport of sand exposes the roots of A. latifolia in portions of the dunes, increasing plant morbidity and mortality.

Figure 14. Extensive erosion of a dune at American Camp showing exposed Abronia latifolia roots. Photo credit K. Reagan/USFWS.

Erosion is affecting sand verbena moth habitat at both American Camp in the dunes (see Figure 14) and at Cattle Point Natural Resource Conservation Area where the Abronia latifolia is established at the leading edge of a feeder bluff that is undercut by unrelenting wind and wave action (see Figures 15 and 16) (Graham 2014, p. 19). The wave-cutting processes are most intense in winter when large storm waves and high tides coincide and cut steep scarps in the toe of the bluff, which initiates slope failure (Graham 2014, p. 19). Human foot traffic has also contributed to slope instability at the top of the bluff (Western Federal Lands Highway Division, Federal Highway Administration (WFLHDFHA) 2012 in Graham 2014, p. 19). The rate of bluff erosion at the Cattle Point site is estimated to average approximately 0.4 m (1.3 ft) per year, but the rate of erosion is not consistent over time or evenly dispersed spatially and a major storm event could cause larger portions of the bluff to fail rapidly in the future (WFLHDFHA 2012 in Graham 2014, p. 19). Light trapping for the sand verbena moth at Cattle Point took place within 15 m (49 ft) of the eroding edge and the trap with the greatest number of detections was sited on an area of the bluff that had already begun to slip (Fleckenstein 2019, in litt.)

Figure 15. Bluff erosion at Cattle Point Natural Resource Conservation Area showing exposed roots of Abronia latifolia. Also note the dense mat of invasive grasses. Photo credit: K. Reagan/USFWS

Figure 16. Bluff erosion at Cattle Point Natural Resource Conservation Area showing exposed roots of Abronia latifolia. Photo credit: K. Reagan/USFWS

Other sites: In active dune systems, wind from powerful storms can move vast amounts of sand, exposing the roots of Abronia latifolia, increasing morbidity and mortality for established plants; movement of sand in active dunes is an ongoing risk factor for A. latifolia at Wickaninnish. In 2013 the Committee on the Status of Endangered Wildlife in Canada determined that ongoing sand deposition and/or erosion of the ecosystem, especially during winter months when storm surges impact the beach areas with logs and erosion, is a threat at Sandy Island and James Island (COSEWIC 2013, p. ix). Wickaninnish is highlighted as being subject to large storms that impact the beach and COSEWIC states that erosion at Wickaninnish is likely larger than at the other sites in Canada where the sand verbena moth has been detected (COSEWIC 2013, p. ix). We have no information to suggest that erosion is currently affecting habitat at Deception Pass, Rocky Point, Graveyard Spit, Kulakala Point, and Fort Worden. 4.1.1.2 Inundation by sea water and deposition of debris Inundation of sand verbena moth habitat is presumed to be detrimental to both the sand verbena moth and the Abronia latifolia. Wilson (1972) notes that Abronia species, including A. latifolia, are not true halophytes (salt-loving plants), but tend to occur in areas of lower salt content that are adjacent to saline environments (p. 425), and ultimately describes Abronia

species as “nonsaline” (p. 435). The roots of A. latifolia may grow as deep as 4.25 m (14 ft) (Wilson 1972, p. 427), suggesting that a rising water table in association with sea level rise may also increase morbidity and mortality for the plant. Areas currently supporting A. latifolia that will experience a high frequency of inundation with salt water in the future may no longer be able to support a strong and healthy population of A. latifolia. The sand verbena moth is known only from dense, vigorous, flowering stands of A. latifolia (NatureServe 2009, online database), and therefore even if a A. latifolia population was able to withstand inundation by salt water, it may decrease in quality to the point where it could not support the sand verbena moth. Goose Spit: Sand verbena moth habitat at Goose Spit is estimated to be 3–5 m (10–16 ft) above sea level (Goulden 2018, in litt.) and while the Abronia latifolia may not currently be subjected to complete inundation, the roots of older plants may be increasingly exposed to sea water as the water table rises concurrently with sea level rise and storm surges. James Island: The low-lying areas of James Island show signs of routine inundation in the form of large woody debris and wrack deposition across areas we have identified as likely occupied by the sand verbena moth (Page et al. 2011, p. 56). The exception is a confined inland area set above sea level. Island View Beach and Cordova Spit: Sand verbena occurs in the foredunes right above the tideline at Island View Beach (Capital Regional District Parks 2017, p. 25). The shoreline of Island View Beach is described as “active” and as a “dynamic bluff/dune/spit complex” (Capital Regional District Parks 2017, p. 24). Specifically, “the exact boundaries of the park have changed over time due to changes in the location of the normal high tide line, which forms the seaward boundary of the park. The normal high tide line is dynamic and can shift, resulting in either an eroded shoreline or a built up shoreline that starts to differ from the legal surveyed boundaries over time” (Capital Regional District Parks 2017, p. 23). The complex of wetlands, mature dunes, and old fields are regularly flooded during the wetter seasons (Capital Regional District Parks 2017, p. 25). It is then reasonable to conclude that Abronia latifolia at Island View Beach and Cordova Spit located “right above the tideline” is likely currently exposed to inundation, erosion, and or deposition of wrack or large woody debris. Fort Worden: The long roots of Abronia latifolia may be exposed to salt water in the areas closest to sea level. Other sites: Abronia latifolia occurs very close to sea level at Sandy Island and may already be subject to inundation as evidenced by the presence of large woody debris across much of the area identified as having sand verbena moth habitat (McClaren 2018, in litt.), though this debris appears old and may reflect wood that was deposited when the shoreline location was different (Page 2019, in litt.). Graveyard Spit is actively accreting and does not appear to have large woody debris across the area of suitable habitat for the sand verbena moth, but the saline water table may be high enough to reach the roots of A. latifolia, increasing the likelihood of

stressing established plants. It is likely that some or all of the potential habitat at Kulakala Point is currently affected by salt water, either through intermittent inundation or because the water table reaches the deep roots of the plants; we surmise this through examination of publicly available imagery (Google 2019) and height above sea level, which is less than 1.5 m (4.9 ft). Large woody debris is present across much of the Rocky Point site where A. latifolia has been mapped and Fleckenstein et al. 2018b states that the site appears to receive relatively frequent disturbance from waves (p. 13). 4.1.1.3 Recreation and human use Recreation, particularly from footpaths or trails (both developed and undeveloped) (Fleckenstein et al. 2018b, pp. 36–37), can affect sand verbena moth through trampling and damaging of the host plant, and crushing of eggs, larvae, and/or adult moths that are sheltering in habitat patches. Additionally, foot traffic and other types of trampling may compact the sand around the host plant making it vertically impenetrable and therefore inaccessible to larvae (Potter 2018b, in litt.). In 2010, Page and Harcombe wrote, “intensive recreation use … has degraded most coastal sand ecosystems in the Strait of Georgia through trampling, development, fires, and other activities.” (p. 6). Many of the sites where sand verbena moth has been detected receive “significant human use” in the form of disturbance by foot or vehicular traffic (Gibble and Fleckenstein 2013, p. 15); there are no known restrictions in place in Washington to protect these areas from human use. Goose Spit: A portion of Goose Spit is a well-used regional park and the remainder is owned and managed by either the Canadian Department of Defense or the K’ómoks First Nation. Public access for the narrow neck of the spit is administered by the Comox Valley Regional District as a regional park (CVRD 2018, website). The Canadian Department of Defense cites pedestrian trampling by recreational visitors as a threat to sand verbena moth habitat (Goulden 2018, in litt.). Island View Beach and Cordova Spit: Island View Beach Regional Park is a popular area for recreation with an estimated 407,000 visitors in 2016 alone (Capital Regional District Parks 2017, p. 2) and was described as the third most-visited regional park in the Capital Regional District in 2015 (Capital Regional District Parks 2016, p. 2). The Draft Management Plan for Island View Beach (Capital Regional District Parks 2017) identifies and acknowledges the need for habitat protection and restoration for the sand verbena moth, which is a federally listed species in Canada, but it does not outline any current protections that are planned for the park. Outreach to the staff at Island View Regional Park did not result in additional information that would contribute to this assessment, leading us to conclude that recreational trampling of sand verbena moth and its habitat is likely high and ongoing at Island View Beach Regional Park. Fairbarns 2007 states that the area is exceptionally attractive and heavily used for a variety of recreational purposes, including walking trails and dog-walking (p. 9). Fairbarns goes on to state that this recreational activity has a major impact on some rare plants (Fairbarns 2007, p. 10). “Beaches and dunes on the Central Saanich Tsawout Indian Reserve and Cordova Spit

Municipal Park receive heavy vehicle use and many sandy areas are heavily rutted. The lower portion of the [T�IX̱EṈ] spit, within the Indian Reserve, hosts a variety of other uses. A substantial portion of this area was cleared and used for camping at a special event in 2007.” (Fairbarns 2007, p. 10). Off-leash exercise of dogs is a common occurrence at Island View Beach and Cordova Spit and continues to be a contentious issue for land managers working to conserve fragile habitat (Capital Regional District Parks 2017, p. 14). James Island: Page and Harcombe 2010 write, “The isolation and private ownership of James Island has precluded intensive recreational use which has degraded most coastal sand ecosystems in the Strait of Georgia…” (p. 6). Under the covenant provisions for the island, many activities are prohibited in conservation areas, such as horseback riding, pedestrian access, or other non-motorized recreation activity (Page and Harcombe 2010, p. 6). Recreational trampling and damage to sensitive sites on James Island are presumed to be substantially lower relative to other sites where the sand verbena moth has been detected due to the private ownership of the island and the James Island Conservation Areas Management Plan, but disturbance impacts from recreational activities was specifically described as a risk factor for the sand verbena moth by the land management organization (Hudson 2018, in litt.). American Camp: Recreational trampling of sand verbena moth habitat at American Camp is likely high. San Juan Island National Historical Park receives approximately 250,000 visitors annually, with a peak of 316,000 in 2016 (NPS 2018). Additionally, surveys for the island marble butterfly take place in the dunes from April through June. While surveyors tend to stay on designated transects, the transects run through known occupied sand verbena moth habitat, leading to compaction of sand around host plants, a condition suspected of being incompatible with larval survival (Potter 2018b, in litt.). Recreational trampling is also likely high for the Cattle Point Natural Resource Conservation Area. Visitors to the American Camp unit of San Juan Island National Historical Park frequently trek from the park through the site to reach the Cattle Point light house. Deception Pass: Habitat for the sand verbena moth at Deception Pass State Park is in an area of high foot traffic close to a campground and an area with access to Cranberry Lake. In 2012, the sand verbena moth was attracted to four light traps distributed throughout the habitat, but in 2017, moths were only found in traps at the southern end of the site away from the area with developed lake access (Fleckenstein et al. 2018b, p. 8). Habitat at this site was specifically identified by Gibble and Fleckenstein in 2012 as likely to be negatively affected by foot or vehicular traffic (p. 15). Fort Worden: Gibble and Fleckenstein 2013 stated that the habitat of the sand verbena moth at Fort Worden was affected by significant human use and is likely to be affected through disturbance by foot or vehicular traffic (p. 15). Fleckenstein et al. states that the back beach at Fort Worden receives “heavy human activity” (2018b, p. 36) and describes trails that occur throughout the site (p. 21). “High levels of human activity may inhibit C. fuscum activity and trample Abronia latifolia.” (Fleckenstein et al. 2018a, p. 21). In 2019, Fort Worden State Park 59

made public plans to redevelop the boat ramp, pier, and science center at the park within the area where the sand verbena moth has been most recently detected at the site (Potter 2019, in litt.)

Other sites: Sandy Island receives substantial recreational use from boaters who may also camp at the park in non-designated camping areas (McClaren 2018, in litt.). The British Columbia Parks website for Sandy Island highlights issues related to recreation, including recreational fires, accumulation of trash, damage to trees and vegetation, and loose dogs, stating that these factors are “putting this small and fragile park at risk.” (British Columbia Parks 2018). Recreational trampling at Wickaninnish is presumed to be high, considering the popularity of Pacific Rim National Park Reserve, with annual visitation to the Long Beach Unit estimated to be 750,000 in 2009 (Parks Canada 2010). Graveyard Spit receives low foot traffic due to being closed to the public. Additionally, areas with Abronia latifolia have been identified to all individuals authorized to conduct activities in the area (Sollmann 2018, in litt.). Finally, Rocky Point was identified as receiving significant human use in Gibble and Fleckenstein 2013 (p. 15) and is a popular recreation site that includes a state park. We do not have information regarding the impact of recreation at Kulakala Point which is under private ownership, but we presume recreational pressure on the site to be low by virtue of extremely limited access. 4.1.1.4 Development Formal surveys conducted by the Washington Department of Natural Resources Natural Heritage Program indicate that large areas of potential sand verbena moth habitat in Washington have been permanently converted to incompatible use by residential, commercial, recreational, and military development, including paved roads and parking lots, all of which has led to substantial habitat fragmentation (Gibble and Fleckenstein 2013, p. 15; Fleckenstein et al. 2018b, p. 36). Fleckenstein et al. (2018b, p 36) state that, based on the biology and ecology of the sand verbena moth and its host plant, Abronia latifolia, a large portion of formerly suitable habitat for sand verbena moth has been developed; the remaining areas of habitat, particularly those currently occupied by the sand verbena moth, are still vulnerable to small- scale recreational development, such as official and unofficial trails, picnic tables and shelter pads, and associated trampling. No state-wide protections are in place to prevent this type of development where it is currently allowed. Paved roads and parking lots are specifically cited as contributing to habitat destruction in the past (Gibble and Fleckenstein 2013, p. 15), though there is no measure of how much potential sand verbena moth habitat has been affected. Goose Spit: Goose Spit has a high level of development due to the main body of the spit being used for military training. Approximately 6.6 ha (16.3 ac) are occupied by DND buildings, roads, and training infrastructure growing from 0.2 ha (0.5 ac) to encompass 25 percent of the total area of the spit (Page et al. 2011, p. 56). Public access for the narrow neck of the spit is administered by the Comox Valley Regional District as a regional park (CVRD 2018, website). Island View Beach and Cordova Spit: Development of an RV Park at Island View Beach is documented as a direct loss of coastal sand ecosystem at Island View Beach (Page et al. 2011, 60

p. 52). It is unclear whether or not this development directly or indirectly affected Abronia latifolia or the sand verbena moth, but the conversion of this coastal sand to incompatible uses may have inadvertently restricted the amount of suitable habitat for A. latifolia and thus the sand verbena moth. Aerial photographs of Cordova Spit reveal what appears to be a parking lot, an outbuilding, and several roads and trails. We do not know the distribution of habitat for the sand verbena moth at Cordova Spit, but we presume the spit represents potential habitat in its entirety due to the sandy nature of the accretion. James Island: Conversion of sand dunes to incompatible uses has severely restricted the amount of habitat available for the sand verbena moth on the southeastern portion of James Island (Page et al. 2011, p. 56). James Island has a history of military use, modified in the 1920’s for the development of munitions manufacture (Page et al. 2011, p. 56). From 1926 to 2007 there was a reduction of approximately 67 percent of open sandy-dune habitat on the island, and much of what remained in 2007 has now been graded and developed into a golf course, with only 8.5 ha (21.0 ac) of 25.5 ha (63.0 ac) of previously undeveloped dunes remaining (Page et al. 2011, p. 56). When James Island was listed for sale, the following description of the development was provided, “Improved with a magnificent 18-hole Jack Nicklaus Signature golf course…a wide range of improvements complement the island including a masterpiece owner’s residence of 5,000 square feet, 6 beautifully appointed guest cottages, private docks and airstrip, pool house, managers residence, a western village and much more.” (Scott Piercy- James LeBlanc, n.d.). Deception Pass: Deception Pass is directly referenced in Fleckenstein et al. 2018b at the beginning of the discussion of development as representative of habitat loss through development and subsequent fragmentation attributable to “residential, commercial, recreational, and military development that has destroyed large areas of habitat and fragmented the remaining pieces” (p. 36). Fleckenstein et al. go on to say, “The remaining areas of habitat, particularly those currently occupied by C. fuscum, are still vulnerable to small- scale recreational development… Trails (developed and undeveloped), picnic table and shelter pads, and associated trampling are potential threats at all four [American] sites where C. fuscum was observed in 2017.” Fort Worden: The sandy spit at Fort Worden State Park has been developed into a campground with beach access. There are myriad roads and trails (both official and unofficial) interspersed with clumps of suitable sand verbena moth habitat where positive detections occurred (Fleckenstein et al. 2018a, p. 21). Other sites: Rocky Point is directly south of Deception Pass and is hemmed in by development. It should be considered similarly to Deception Pass. Wickaninnish, Sandy Island, American Camp and Cattle Point, Graveyard Spit, and Kulakala Point are not currently affected by development.

4.1.1.5 Invasive Species The introduction of dune stabilizing plant species coincides with the arrival of European settlers who brought a number of species of rhizomatous pasture grasses with them as forage for their livestock and to prevent soil erosion (D’Antonio and Vitousek 1994, p. 66; Dennehy et al. 2011, p. 1; Duer 2013, p. 113). Other plants were later introduced for the specific purpose of stabilizing dune habitat (Buell et al. 1995, entire; Carson et al. 1991, entire; McLaughlin and Brown 1942, entire). While Abronia latifolia is considered a good competitor in dune systems stabilized by other early-seral, native, coastal plant species (Tillett 1967, p. 307), flowering and leaf production is much reduced where it competes with non-native plants, specifically non- native rhizomatous grasses and non-native forbs such as Cirsium arvense (Fleckenstein et al. 2018, p. 12). Abronia latifolia does not persist long in the secondary successional plant community (Kumler 1969, p. 702); therefore, it is reasonable to conclude that the stabilizing effect of competing vegetation that leads to a reduction in A. latifolia negatively affects the sand verbena moth through the reduction of nectar availability for adults and food resources for immature moths. Sand verbena moth surveys conducted in contiguous habitat where a portion is in open, sandy soil, versus heavily invaded stabilized soils highlighted the preference of the sand verbena moth for open, uninvaded habitat (Fleckenstein et al. 2018b, p. 36). “At least 17 moths were seen at the trap located in open sandy habitat at Cattle Point, far fewer, possibly only one, were seen at the trap location less than 20 m away where A. latifolia was growing in a dense patch of Bromus and none were found at trap locations east of that point where the host plant stand was still relatively dense but surrounded by a dense stand of Bromus” (Fleckenstein et al. 2018b, p. 36). Invasive grasses are reported as being common in all Georgia Basin coastal sand ecosystems (Page et al. 2011, p. 49) and Rocky Point is the only surveyed detection site in Washington that does not include a report of invasive grasses (Fleckenstein et al. 2018b, p. 11). Page et al. 2011 listed the most important invasive plants in the coastal sand ecosystems of Georgia Basin as: Scot’s broom (Cytisus scoparius), non-native grasses (e.g., bromes, including soft brome (Bromus hodeaceus), cheat grass (B. tectorum), and ripgut brome (B. rigidus), sweet vernal grass (Anthoxanthum ordoratum), gorse (Ulex europaeus), tree lupine (Lupinus arboreus), and sheep sorrel (Rumex acetosella) (p. 47). Scot’s broom is described as present in most coastal sand ecosystems, including feeder bluffs, in the Georgia Basin (Page et al. 2011, p. 47). Scot’s broom is a nitrogen-fixer in nutrient-poor soils (such as sand) which facilitates invasion by non- native grasses, is tolerant of summer drought, forms dense stands that compete with native plants for moisture and light (Page et al. 2011, p. 47), and establishes a long-lived seed bank (WSNWCB 2014, p. 2, unnumbered). Scot’s broom accelerates succession by stabilizing the surface of the sand and increasing soil fertility (Page et al. 2011, p. 47). Canada thistle (Cirsium arvense), which reproduces both rhizomatously and by seed, is well established at American Camp and may soon spread to Cattle Point (Vernon 2018, in litt.). Goose Spit: Invasive plant species are a risk factor for Abronia latifolia at Goose Spit, with Scot’s broom forming the dominant ecological community (Page et al. 2011, p. 47; Page 2019, 62

in litt.). Much of the landscape is covered with non-native Scot’s broom, which increased from less than 0.4 ha (1.0 ac) in 2005 to 9.6 ha (23.7 ac) in 2010 (Page et al. 2011, p. 56). Invasive grasses are also a risk factor at Goose Spit and invasive plant management is ongoing, but portions of the site continue to be affected by non-native species (Goulden 2018, in litt.). There is potential for future management changes to sand verbena moth habitat on Goose Spit if property ownership is transferred to the First Nations (transfer of ownership is currently pending) (Goulden 2018, in litt.). Island View Beach and Cordova Spit: Fairbarns 2007 asserts that exotic invasive [plant] species present one of the most serious threats to populations of rare [native] plants at Island View Beach and Cordova Spit (p. 10). Comparison of aerial photographs taken since the 1930s documents an increase in forest and shrub cover at Island View Beach with non-native vegetation dominating the landscape toward the south end of the site, while more native species are present to the north (Capital Regional District Parks 2016, p. 22). European beach grass is reported from Island View Beach and tree lupine is found on Cordova Spit, but in small and stable populations (Page et al. 2011, p. 47; Page 2019, in litt.). James Island: Scot’s broom, field garlic (Allium vineale), Armenian blackberry (Rubus armeniacus), gorse, rattail fescue (Vulpia myuros), red fescue (Festuca rubra), and European beachgrass are all documented from James Island (Page and Harcombe 2010, pp. 15–16, 23–24; Page et al. 2011, p. 47). Invasive plant species are identified as having a negative effect on the northern spit (North Spit or Village Spit) of James Island where the sand verbena moth has been detected (Page and Harcombe 2010, p. 16). Specifically, in 2010, Scot’s broom and gorse were reported as forming dense patches near the tip of the spit, European beachgrass occurring along the spit’s northern edge, field garlic being locally abundant along the north side of the access road, and “small patches” of Armenian blackberry observed (Page and Harcombe 2010, p. 16). The Nature Conservancy of Canada currently manages the conservation areas on James Island and have successfully controlled Scot’s broom and gorse in some areas but they stated that invasive vegetation remains continues to affect sand verbena moth habitat on the island (Hudson 2018, in litt.; Page 2019, in litt.). American Camp and Cattle Point: At American Camp, dune stabilization by invasive plant species is a substantial risk factor for Abronia latifolia (Vernon 2018, in litt.). While there are myriad soil stabilizing invasive plant species in the dunes of American Camp, two are particularly prevalent; tumble mustard (Sisymbrium altissimum) and Canada thistle (Cirsium arvense) (Vernon 2018, in litt.). Canada thistle establishes easily in open sand, reproduces both rhizomatously and by seed, and occurs in dense stands in sand verbena moth habitat (Figures 17 and 18) (WSNWCB 2018, online resource). Sand verbena moths appear to avoid stands of dense Canada thistle (Fleckenstein et al. 2018b, pp. 9–10). Canada thistle is classified as a Class C noxious weed in Washington and is considered widespread throughout the state (WSNWCB 2018, online resource).

Invasive plant species, especially grasses, are prevalent at the Cattle Point Natural Resource Conservation Area (Fleckenstein et al. 2018b, pp. 9–11). This site had the highest percentage of both non-native and invasive plant cover, which has been observed to reduce flowering of sand verbena and may make it more difficult for adults to locate the host plants (Fleckenstein et al. 2018b, p.12). During light trapping conducted at the Cattle Point Natural Resource Conservation Area in 2017, adults were only detected in traps where invasive species were less dense (i.e., on the eastern bluff edge) (Fleckenstein et al. 2018b, p.9). The stand of Canada thistle present at American Camp is reported to be approaching the Cattle Point Natural Resource Conservation Area (Fleckenstein et al. 2018b, p. 10; Vernon 2018, in litt.).

Figure 17. Canada thistle blooming in the dunes at Figure 18. Abronia latifolia covered in the thistle down American Camp. Photo credit: S. Vernon from the dense stand of Canada thistle. Photo credit: S. Vernon Deception Pass: Percent cover of non-native and invasive plant species in plots at Deception Pass was reported as one and seven percent, respectively, with Ammophila arenaria (European beach grass) being the sole invasive plant listed, implying that sand stabilization may be a risk factor for sand verbena moth habitat there (Fleckenstein et al. 2018a, pp. 11, 24). Fort Worden: Fleckenstein et al. 2018a states bluntly that “Invasive species, especially grasses, are overtopping Abronia latifolia at many locations throughout the site.” (p. 20).

Other sites: Wickaninnish has undergone extensive habitat restoration to remove dune stabilizing plants and return the beach and dune areas to their more natural shifting state; future objectives for this site consist of maintaining the currently open area and allowing the enhanced native plant community to continue to develop (Collyer 2018, in litt.). Invasive plant species are reported from Sandy Island (McClaren 2018, in litt.). Taylor’s checkerspot butterfly habitat surveys at Kulakala Point in 2018 indicate that Vicia sativa (common vetch), Vicia hirsute (tiny vetch), and Taraxacum officinale (dandelion) were interspersed with Abronia latifolia there. None of these plants were identified as dominating the site, but we note here that they are present (Radmer2018, in litt.). Invasive plants are not believed to have a negative impact on A. latifolia at Graveyard Spit (Sollmann 2018, in litt.) and were not reported from the 2017 surveys at Rocky Point (Fleckenstein et al. 2018b, p. 11). 64

Animals Goose Spit: Eastern cottontail rabbits (Sylvilagus floridanus) have been documented as heavy browsers on sand verbena and they occur at Goose Spit (Page et al. 2011, pp. 32, 54). Eastern cottontail rabbits do not burrow, but rely on shrubs and tall grasses for cover (Page et al. 2011, p. 54). Sites, such as Goose Spit, where Scot’s broom is present appears to be correlated with higher numbers of Eastern cottontail rabbits (Page et al. 2011, p. 54). Deer, while not invasive or non-native, have been observed browsing on sand verbena at Goose Spit when other plants have senesced (Page et al. 2011, p. 32). James Island: Fallow deer (Dama dama), a non-native ungulate was introduced to James Island and has been reported browsing on vegetation in coastal sand ecosystems on the island (Page et al. 2011, p. 54). American Camp and Cattle Point: European rabbits (Oryctolagus cuniculus) are widespread in some areas at American Camp where the sand verbena moth is found (Potter 2018b, in litt.). European rabbits construct burrow systems, unlike other rabbits (Potter 2018b, in litt.). Sand dunes are often unable to provide suitable substrate to support European rabbit burrows, which then collapse when burrowing is attempted, exposing the roots of the Abronia latifolia and leading to plant mortality. Some of these dune slope collapses regularly reach 5–10 m2, disturbing soil in the area of host plants and larvae (Potter 2018b, in litt.). Additionally, the areas surrounding European rabbit burrows become devoid of plant life, presumably attributable to the European rabbits feeding (Potter 2018b, in litt.). The Washington Department of Fish and Wildlife Invertebrate Conservation Specialist states that European rabbits, when present, are “a consistent threat to Abronia and [sand verbena moth] larval habitat…” (Potter 2018b, in litt.). 4.1.1.6 Habitat Fragmentation and Lack of Connectivity Erosion, recreation, development, and invasive species have all contributed to the fragmentation of sand verbena moth habitat. On the large scale, remnant deposits of sand are relicts of a glacial past, the vast majority having eroded over the last 10,000 years (Wilson et al. 2009, p. 54), leaving suitable sites for the sand verbena moth great distances apart. On a small scale, habitat is fragmented by shoreline development (e.g., residential, commercial, military, roads, recreation [parks, campgrounds, and trails]), and invasive plant species. Most sites where the sand verbena moth has been detected are isolated from each other by at least several kilometers and there have been few detections of sand verbena moths more than 25 m (82 ft) from their host plant habitat (COSEWIC 2003, p. 10). Due to the highly fragmented nature of Abronia latifolia habitat, it is reasonable to assume that the sand verbena moth as a species suffers from a lack of connectivity attributable to both large- and small-scale processes.

4.1.1.7 Conservation Measures to Limit Effects to Habitat The Washington State Department of Fish and Wildlife currently lists the sand verbena moth as a ‘Candidate’ for listing under the state Endangered Species program and it receives state support for recovery efforts for at-risk species (WDFW 2019, entire). The Washington Natural Heritage Program has conducted several years of surveys for sand verbena moth and Abronia latifolia (Gibble and Fleckenstein 2013, entire; Fleckenstein et al. 2018a, entire). Because most of the sites where sand verbena moths have been detected are located in the state are located on public land, some habitat conservation measures do occur, particularly management of invasive species and prohibition of certain activities. However many of these areas are also open to the public and therefore have a lot of recreational use. American Camp/Cattle Point are part of San Juan Island National Historic Park and Cattle Point is a Natural Resource Conservation Area. Deception Pass, Fort Worden and Rocky Point are part of the Washington State Parks system.

In Canada, the sand verbena moth was listed as endangered under SARA in 2005 based on a 2003 assessment by COSEWIC that determined the species was likely in decline due to small population size and habitat-related impacts (COSEWIC 2003, p. 23). The species was re- examined and confirmed to be endangered in 2013 (COSEWIC 2013, entire). A recovery strategy was published for the sand verbena moth in 2012 that also identified critical habitat for the species at each of the five detection sites (Environment Canada 2012, entire). As part of its recovery strategy Canada has conducted surveys of the sand verbena moth; conducted surveys for, propagated, and transplanted Abronia latifolia; conducted educational outreach; conducted some invasive species management; created management plans that prohibit certain activates in sand verbena moth habitat (Environment Canada 2012, p. 8-9). Most sand verbena moth detection sites are also on public land and some of the sites have conservation management plans. The Draft Management Plan for Island View Beach (Capital Regional District Parks 2017) identifies and acknowledges the need for habitat protection and restoration for the sand verbena moth, but it does not outline any current protections that are planned for the park. The Nature Conservancy of Canada currently manages the conservation areas on the privately owned James Island and under the covenant provisions for James Island, many activities are prohibited in conservation areas, such as horseback riding, pedestrian access, or other non-motorized recreation activity (Page and Harcombe 2010, p. 6; Hudson 2018, in litt.). In 2016, Parks Canada developed a Multi-species Action Plan for Pacific Rim National Park Reserve that includes specific management actions to be taken to improve and maintain habitat for the sand verbena moth at Wickaninnish (Parks Canada Agency 2016, pp. 11–14, 22–24). 4.1.2 Predation Moths in the tribe Agrotini, the group that includes the genus Copablepharon, exhibit behavioral adaptations, such as larvae that burrow into the sand during the day, that facilitate the escape of sharp-eyed diurnal predators such as birds, wasps, and spiders (Lafontaine 2004, p. 15). As a result of these adaptations, nocturnal and crepuscular predators may be more likely to prey upon the sand verbena moth adults and larvae. The predators of greatest concern

include the tiger beetles (belonging to the family Cicindelidae), red fox (Vulpes vulpes), rodents, and various species of bats. 4.1.2.1 Tiger Beetles Tiger beetles often inhabit sandy soils such as dune systems and beaches (Pearson et al. 2006, pp. 177–188) and their immature and adult forms are known generalist predators of invertebrate species (Pearson et al. 2006, p. 186). Tiger beetles are documented predators of the larval stage of other cutworm species (Hong et al. 2011, p. 715) and, while tiger beetles have not been observed preying on sand verbena moth or their larvae, they represent a likely risk factor. 4.1.2.2 Red Fox Foxes are omnivorous and their diets vary broadly, depending on what resources are available (Contesse et al. 2004, entire; Doncaster et al. 1990, entire; Green and Osborne 1981, entire; Richards 1977, entire; Robertson and Whelan 1987, entire). Their diets are primarily composed of vertebrates, but one study of more than 400 foxes in Switzerland indicated that approximately thirty-two percent of the foxes sampled had invertebrates in their stomachs (Contesse et al. 2004, p. 83). Records of invertebrates in the diet of foxes are closely tied to seasonal availability, peaking when prey were most abundant and present in stomach contents or scat when available in the environment (Doncaster et al. 1990, pp. 190–191; Green 2003, entire; Green and Osborne 1981, entire). Foxes are well-documented predators of moths, their larvae, and specifically Noctuid moths, the group to which the sand verbena moth belongs (Green 2003, pp. 248, 250; Green 2011, p. 32; Richards 1977, p. 502; Robertson and Whelan 1987, p. 742). One study of fox diet indicated that where Noctuid moths were abundant, they composed up to 68 percent of the foxes’ scat by volume, with invertebrates in general sometimes reaching 81 percent by volume (Green 2003, p. 248). Richards (1977, p. 497) found that lepidopteran larvae were detected in red fox diet approximately nine percent of the time, while Green (2002, p. 248) found Noctuid moths represented in the scat samples of foxes year round, when they were present in the environment (i.e., represented in one hundred percent of the samples for a three year period in places where moths congregate). In June of 2016, individuals surveying for sand verbena moths observed foxes digging in the sand in and around sand verbena, presumably for the late-stage larvae or pupae of sand verbena moths (Reagan 2018, personal observation). No data are available from American Camp that describe the effect of fox predation on sand verbena moth mortality. However, due to the extended period of time larvae are present in the environment, documented evidence of red fox dietary preferences, and the constant presence of red foxes in areas known to be occupied by the sand verbena moth, it is possible that fox predation on sand verbena moth may be high. While fox predation on sand verbena moths is highly likely, it is not known if it occurs at a level detrimental to the long-term sustainability of any specific local population group or the species as a whole.

4.1.2.3 Bats There is no question regarding the extreme predation pressure that bats exert on the order Lepidoptera (Ratcliffe and Nydam 2008, p. 96), with some researchers even suggesting that previously nocturnal lepidopteran lineages have been driven to a diurnal state to escape bat predation (Yack and Fullard 2008, p. 266). Many of the physical characteristics of moths (e.g., hair, scales, fringed wings) may be driven by the need to escape detection by sharp-eared predators (Barber et al. 2015, entire). The selective pressure bats exert on moths may also influence the flight season of the sand verbena moth. One study conducted at or near the same latitude of sand verbena moths sites states that bat foraging in early May is only at 15 percent of its peak, reaching 50 percent by late June and peaking from early July to late August (Ratcliffe and Nydam 2008, p. 96). Various detection methods for bat surveys have been used to generate records of bats in Washington State; they include mist netting and high-frequency audio recording. Investigations into the diets of bats in Washington State are ongoing, but data are sparse. Some bat monitoring efforts have been conducted in conjunction with invertebrate sampling using light trapping, but those data are not available. The counties in Washington State where the sand verbena moth occurs have occurrence records for all eight species of bats that occur in western Washington: Corynorhinus townsendii, Eptesicus fuscus, Lasiurus cinereus, Lasionycteris noctivagans, Myotis californicus, M. evotis, M. lucifugus, and M. volans (M. keenii has been recently determined to be undifferentiated from M. evotis.) (Milner 2018, in litt.). Of these species, three commonly forage in more open habitats, like those where the sand verbena moth is found: E. fuscus, Lasionycteris noctivagans, and Lasiurus cinereus (Kelly 2017, p. 7). All known detection sites for sand verbena moth are presumed to overlap with the occurrence of bats. The extent of predation pressure on the sand verbena moth by bats is unknown, but presumed to be both likely and common. However, it is not known if predation on the sand verbena moth by bats occurs at a level detrimental to the long-term sustainability of any specific local population or to the species as a whole.

American Camp and Cattle Point: Tiger beetles, red foxes, and bats are all known to overlap with the sand verbena moth at American Camp and presumably Cattle Point. Tiger beetles (possibly, Cicindela oregona, the Western tiger beetle) (Pearson et al. 2006, p. 69); but also possibly C. depressula, the dispirited tiger beetle), (Pearson et al. 2006, p. 70) are present in the dunes at American Camp (Reagan, personal observation) and several species of tiger beetles have ranges that encompass all known sand verbena moth occurrences (e.g. C. oregona, C. depressula, and Omus spp.) (Pearson et al. 2006, pp. 52–53). Habitat descriptions for the dispirited tiger beetle encompass “a broad range of habitats from coastal sandy beaches to alpine meadows, and for Omus spp. include “Pacific coastal lowlands” (Pearson et al. 2006, p. 52).

The red fox, Vulpes, was introduced to San Juan Island at least twice; a pair in 1947 and undefined numbers in subsequent years (Schoen 1972 in Aubry 1984, pp. 72–73). The foxes of San Juan Island have sometimes been misidentified as the Washington native, Vulpes vulpes cascadensis, but due to mountainous habitat requirements and the rarity of V. v. cascadensis, the lineage found on San Juan Island is likely derived from the non-native red fox population that naturalized in the lowlands of Washington, V. v. fulva (Aubry 1984, p. 72). There are no census numbers available to estimate the abundance of red foxes at American Camp (Figure 19), SJINHP, but they are a ubiquitous presence there and have been observed digging in the area occupied by the sand verbena moth (personal observation).

Figure 19. Introduced red fox at American Camp above the active dune system where the sand verbena moth occurs. Please note dense cover of invasive grasses and forbs, including Eschscholzia californica (California poppy). Photo credit: K. Reagan/USFWS

Predation on individual sand verbena moths by foxes is likely reduced at Cattle Point due to the lack of open sand available for digging, though it is possible that foxes prey on adult sand verbena moths harboring in the leaves of the Abronia latifolia. Fort Worden: Tiger beetles, red foxes, and bats are all presumed to overlap with the sand verbena moth at Fort Worden. An informal wildlife viewing website records foxes as being observed at Fort Worden (ohranger.com 2018), but no images of foxes were publically available through an internet search, leading one to conclude that they may not be a ubiquitous presence at this popular tourist site. We have no specific information regarding the potential for predation on the sand verbena moth at any sites other than American Camp and Cattle Point.

4.1.3 Influence Diagram of Current Risk Factors

Figure 20. Influence diagram of known risk factors for the sand verbena moth

4.1.4 Summary of habitat risk factors and overall site vulnerability To assess overall site vulnerability we looked at the risk factors affecting habitat at each site, and the estimated magnitude of impact of each of those risk factors (Table 6). We did not consider the risk factor of predation and its direct effects on the moth in overall site vulnerability; while individual moths are likely impacted by predation across the species range, we do not have any information regarding whether or not there are population-level effects from predation on sand verbena moth at any of the detection sites. The five categories we used to assess level of magnitude of risk factors at each site are listed below: • Unlikely (data suggests it is not occurring, or it is not suspected to occur); • Likely (data suggests it is occurring but we have no direct evidence); • Low (data confirms minimal current impact, or past impact); • Moderate (data confirms ongoing regular current impact); and, • High (data confirms ongoing high impact).

We further categorized the overall site vulnerability using the following categories: • Low (habitat at site maybe be affected by a risk factor but is currently considered stable and well protected); • Moderate (habitat at site is affected by several risk factors on a regular basis likely degrading the suitability of habitat over time); and, • High (habitat at the site receives on-going high impact from several risk factors putting the suitability of habitat at high risk of decline).

Table 6. Summary of Overall Site Vulnerability

Habitat Risk Factors and their Magnitude Site Name Erosion Inundation Recreation/ Development Invasive Overall Site Human Use Species Vulnerability CANADA Goose Spit Moderate Moderate High High Moderate High to High Island View Beach and Moderate Moderate High Low Moderate Moderate Cordova Spit James Island Moderate Moderate Low Low Moderate Moderate Sandy Island Moderate Moderate Moderate Unlikely Moderate Moderate

Wickaninnish High Unlikely High Unlikely Low Moderate UNITED STATES American Camp (AC) Moderate Unlikely/Low High Unlikely High High and Cattle Point (CP) to High Deception Pass State Unlikely Unlikely High Low Moderate Moderate Park to High Fort Worden State Unlikely Likely High Moderate Moderate Moderate Park Graveyard Spit Unlikely Likely Low Unlikely Unlikely Low Kulakala Point Unlikely Likely Low Unlikely Low Low Rocky Point Unlikely High High Low Unlikely High

4.2 Current Conditions Site Summary

4.2.1 Sites with potential populations Below we provide a summary of the current condition of habitat for all 11 sites where the sand verbena moth has been detected. To assess each site’s condition we looked at (1) the patch size; (2) the percent leaf cover of Abronia latifolia and general level of flower production from May-July; (3) whether or not it meets the precipitation and temperature limitations identified as species needs; and, (4) the overall site vulnerability from the number and magnitude of habitat risk factors at that location. We did not include any moth abundance information in our site condition analysis; we could not create any reasonable demographic metrics for the model due to the lack of consistent defection data both among the sites and through time.

Table 2 provides a summary of the current condition rating criteria. The potential criteria that can apply to each rating category are listed in the first column. The rating categories are each defined by the specific set of criteria (as shown by ‘x’ under the rating) that constitute that category. Three of the rating categories (Somewhat Compromised, Compromised, and Highly Compromised) have more than one possible set of criteria that meet the rating category.

Table 7. Summary of site condition rating categories Rating Categories Mostly Somewhat Compromised Higly Criteria Stable Stable Compromised Compromised ≥ 400 m2 (0.04 ha or 4,306 ft2) total leaf cover of Abronia X X X X X X X X latifolia Patch density ≥ 25 percent leaf cover of Abronia latifolia, high X X X X flower production May –July Both 30-year normal precipitation below 1950 mm (77 in) and 30-year normal X X X X X temperatures above 7.47 °C (45 °F) Low X Moderate X Low OR X X Site Moderate Vulnerability High X X X X

Low OR Moderate OR X High

4.2.1.1 Canada

Goose Spit The estimated area of Abronia latifolia at Goose Spit is reported as 7.0 ha (17.3 ac), but not all of this area is used by the sand verbena moth and we have no information regarding the total leaf cover of A. latifolia or its density, or flower production for this site. Goose Spit has both a 30-year normal precipitation below 1950 mm (77 in) and a 30-year normal temperatures above 7.47 °C (45 °F). The site is affected by a high level of recreation/human use and development, a moderate to high level of invasive species, and moderate levels of inundation and development. Its overall site vulnerability is ‘High.’ The site condition of Goose Spit is unknown due to the lack of confirmed information on total leaf cover and density of Abronia latifolia at the site. If total leaf cover is greater than 400 m2 and the patch density is ≥ 25 percent with high flower production, then the site would meet the site condition criteria for a rating of ‘Somewhat Compromised.’

Island View Beach and Cordova Spit The total extent of Abronia latifolia at Island View Beach/Cordova Spit is reported as 13.1 ha (32.3 ac), but not all of this area is used by the sand verbena moth and we have no information regarding the total leaf cover of A. latifolia, its density, or flower production for this site. Island View Beach and Cordova Spit has both a 30-year normal precipitation below 1950 mm (77 in) and a 30-year normal temperatures above 7.47 °C (45 °F). The site is affected a high level of recreation/human use, a moderate level of invasive species, and a low level of development. Erosion and inundation are likely at this site. Island View Beach and Cordova Spit’s overall site vulnerability is ‘Moderate.’ The site condition Island View Beach/Cordova Spit is unknown due to the lack of confirmed information on habitat quality for Abronia latifolia at the site. If there is greater than 400 m2 (0.04 ha or 4,306 ft2) total leaf cover of Abronia latifolia with patch density of greater than 25 percent and high flower production, then the site would meet the site condition criteria for a rating of ‘Mostly Stable.’ James Island Based on the estimated area of habitat polygons downloaded from the British Columbia Conservation Data Centre website, James Island has 1.1 ha (2.8 ac) of sand verbena moth habitat. We have no information regarding host plant leaf cover, density, or flower production for James Island. James Island has both a 30-year normal precipitation below 1950 mm (77 in) and a 30-year normal temperatures above 7.47 °C (45 °F). The site is affected by moderate levels of inundation and invasive species, and low levels of recreation/human use and development. Its overall site vulnerability is ‘Moderate.’ The site condition of James Island is unknown due to the lack of confirmed information on total leaf cover and density for Abronia latifolia at the site. If total leaf cover was determined to be greater than 400 m2 at the site with a density greater than 25 percent and high flower production, then the site would meet the condition criteria for a rating of ‘Mostly Stable.’ 4.2.1.2 Washington

American Camp and Cattle Point American Camp represents the most expansive, healthiest, and secure population of A. latifolia in Washington and appears to support the best documented and potentially the largest sand verbena moth population known. The population at this site is potentially self-sustaining (e.g. recruitment rate at the site appears to consistently meet or exceed the mortality rate on average over time).

The total patch size of Abronia latifolia at American Camp is 23.4 ha (57.7 ac); the patch size at Cattle Point is 0.65 ha (1.6 ac). Combined, these are well above the 400 m2 (0.04 ha or 4,306 ft2) minimum for our model. The percent leaf cover for A. latifolia at this site is between 30 and 40 percent, well above the minimum density 25 percent for our model, with high flower production. American Camp/Cattle Point has both a 30-year normal precipitation below 1950 mm (77 in) and a 30-year normal temperatures above 7.47 °C (45 °F). The site is affected by high levels of recreation/human use and invasive species, moderate to high erosion, and low levels of development and inundation. Its overall site vulnerability is ‘High.’ Although the detection data and habitat condition indicate the site supports the most secure known potential population of sand-verbena moth, the site vulnerability rating at American Camp/Cattle Point means the site meets the condition criteria for a rating of ‘Somewhat Compromised,’ Deception Pass The total leaf cover of Abronia latifolia at Deception Pass is 0.06 ha (0.14 ac), just above the 400 m2 (0.04 ha or 4,306 ft2) minimum for our model. The percent leaf cover for A. latifolia across the entire site is 2 percent, well below the minimum density of 25 percent for our model and none of the individual patches of A. latifolia had total leaf cover greater than 400 m2 (0.04 ha or 4,306 ft2). Of the 14 individual patches, 11 were 50 m2 (538 ft2) or smaller, 2 were 75 m2 (807 ft2), and 1 was 225 m2 (2422 ft2). Of these, only 3 patches had leaf cover densities greater than 25 percent, and those three were all estimated to have densities of 30 percent leaf cover. Deception Pass has both a 30-year normal precipitation below 1950 mm (77 in) and a 30-year normal temperatures above 7.47 °C (45 °F). Inundation and erosion are not problems at the site. Deception Pass is affected by a high level of recreation/human use, moderate to high pressure from invasive species, and low levels of development. Its overall site vulnerability is ‘Moderate.’ Deception Pass meets the site condition criteria for a rating of ‘Somewhat Compromised.’ Fort Worden The patch size of Abronia latifolia at Fort Worden is 9.3 ha (23.0 ac), well above the 400 m2 (0.04 ha or 4,306 ft2) minimum for our assessment. The percent leaf cover for A. latifolia at this site is 5 percent, well below the minimum 25 percent for our assessment. Fort Worden has both a 30-year normal average precipitation below 1950 mm (77 in) and a 30- year normal average temperatures above 7.47 °C (45 °F). The site is affected by a high level of recreation/human use and moderate levels of development. Inundation is likely at this site. Fort Worden’s overall site vulnerability is ‘Moderate.’

Fort Worden meets the overall site condition criteria for a rating of ‘Somewhat Compromised.’ A summary of the current condition of all sites with potential populations is provided below (Table 8a).

Table 8a. Summary of site condition for sites with potential populations.

Patch density Both 30-year ≥ 25 percent leaf normal ≥ 400 m2 cover of Abronia precipitation below total leaf latifolia, high 1950 mm (77 in) Overall site condition cover of flower and 30-year normal Abronia production May temperatures above Site Site Name latifolia –July 7.47 °C (45 °F) Vulnerability

CANADA Unknown Goose Spit no data no data yes High (missing data) Island View Unknown Beach and no data no data yes Moderate (missing data) Cordova Spit Unknown James Island no data no data yes Moderate (missing data) UNITED STATES American Camp (AC) and Cattle yes yes yes High Somewhat Compromised Point (CP) Deception Pass Moderate to yes no yes Somewhat Compromised State Park High Fort Worden yes no yes Moderate Somewhat Compromised State Park

4.2.2 Sites with potential historic but unknown current populations

Sandy Island - Canada Based on the estimated area of habitat polygons downloaded from the British Columbia Conservation Data Centre website, Sandy Island has 4.2 ha (10.3 ac) of sand verbena moth habitat. We have no information regarding host plant leaf cover, density, or flower production for Sandy Island. Sandy Island has both a 30-year normal precipitation below 1950 mm (77 in) and a 30-year normal average temperatures above 7.47 °C (45 °F). The site is affected by moderate levels of recreation/human use and inundation, and low levels of invasive species. Its overall site vulnerability is ‘Moderate.’ The overall site condition for Sandy Island is unknown because we have no data on the amount and quality of habitat at the site.

Kulakala Point (aka Graysmarsh)- United States The patch size, percent leaf cover, and flower production of Abronia latifolia at Kulakala is unknown at this site. The privately owned Kulakala Point has both a 30-year normal average precipitation below 1950 mm (77 in) and a 30-year normal average temperatures above 7.47 °C (45 °F). The site is affected by moderate levels of erosion, and low levels of recreation/human use and invasive species. Inundation is likely at this site. Its overall site vulnerability ‘Moderate.’ The overall site condition for Kulakala Point is unknown because we have no data on the amount and quality of habitat at the site. A summary of the current condition at Sandy Island Marine Provincial Park and Kulakala Point is provided below (Table 8b).

Table 8b. Summary of current condition at sites with potential historic populations, but not enough information to indicate whether or not they support current populations of sand verbena moth. Site Name ≥400 m2 Patch density ≥ 25 Both 30-year normal Site total leaf percent leaf cover precipitation below Vulnerability cover of of Abronia latifolia, 1950 mm (77 in) and Overall site Abronia with high flower 30-year normal condition latifolia production from temperatures above May-July 7.47 °C (45 °F) Sandy Island Marine Unknown no data no data yes Moderate Provincial Park- Canada (missing data) Kulakala Point Unknown (Graysmarsh)- United no data no data yes Low (missing data) States

4.2.3 Sites with unknown historic or current populations

Wickaninnish- Canada Abronia latifolia cover at Wickaninnish was estimated to be 0.2 ha (0.5 ac) in 2017. We have no information regarding the total host plant leaf cover, density, or flower production at this site. Wickaninnish does not have a 30-year normal precipitation below 1950 mm (77 in) but does have a 30-year normal temperatures above 7.47 °C (45 °F). The site is affected by high levels of recreation/human use, moderate erosion, and a low level of invasive species. Its overall site vulnerability is ‘Moderate.’

The site condition of Wickaninnish is unknown due to the lack of information on habitat quantity or quality.

Graveyard Spit- United States

Total host plant leaf cover, density, or flower production for Graveyard Spit is unknown, but the total extent of the habitat patch for the sand verbena moth was estimated to be greater than 400 m2 (4306 ft2) in 2012. Graveyard Spit has both a 30-year normal precipitation below 1950 mm (77 in) and a 30-year normal temperatures above 7.47 °C (45 °F). The site is affected by moderate erosion, and low levels of recreation/human use and development. Inundation is likely at this site.

The site condition of Graveyard Spit is unknown due to the lack of information on habitat quality.

Rocky Point- United States The total foliar cover of Abronia latifolia at Rocky Point is 0.10 ha (0.25 ac), but the overall density of the leaf cover for the site is 2 percent well below the minimum 25 percent for our model. No individual host plant patch at Rocky Point met or exceeded the minimum 0.04 ha (0.10 ac) total host plant leaf cover with leaf density greater than 25 percent thresholds required by the model used for site assessment. Regardless, total leaf cover for three host plant patches measuring 0.02 ha, 0.03 ha, and 0.01 ha (0.05 ac, 0.08 ac, and 0.02 ac, respectively) were reported as having host plant leaf densities between 30 and 40 percent. Additionally, these three patches appear to be located relatively close to each other (e.g. less than 200 m (656 ft) apart) and may represent an alternative configuration of suitable habitat for the sand verbena moth (COSEWIC 2003, pp. 9–10). Rocky Point has both a 30-year normal precipitation below 1950 mm (77 in) and a 30-year normal temperatures above 7.47 °C (45 °F). The site is affected by a high levels of recreation/human use and inundation, and a low level of development. Its overall site vulnerability is ‘Moderate.’

Rocky Point meets the site condition criteria for a rating of ‘Compromised.’ A summary of the current condition at Wickanninish, Graveyard Spit, and Rocky Point is provided below (Table 8c).

Table 8c. Summary of current condition at sites without enough information to indicate whether or not they ever supported a population of sand verbena moth. Site Name ≥400 m2 Density ≥ 25 % leaf Both 30-year normal Site total leaf cover of Abronia precipitation below 1950 mm Vulnerability Overall site cover of latifolia, with high (77 in) and 30-year normal condition Abronia flower production temperatures above 7.47 °C latifolia from May-July (45 °F) Wickaninnish - Unknown no data no data no Moderate Canada (missing data) Graveyard Spit- Unknown yes no data yes Low United States (missing data Rocky Point- (conditional) no yes High Compromised United States yes

4.3 Current Condition 3Rs Summary

As noted in section 3.0, the sand verbena moth needs interconnected healthy populations with habitat that provides for feeding, sheltering, and protection from predators. Resilient populations of sand verbena moth should have (1) sufficiently large size; (2) at least 400 m2 (0.04 ha or 4,306 ft2) total leaf cover of Abronia latifolia in dense patches (leaf cover density of greater than25 percent) with high flower production form May-July in loose, open sand; (3) be within maximum dispersal distance of each other; and (4) have 30-year normal average precipitation below 1950 mm (77 in) and 30-year normal average temperatures above 7.47 °C (45 °F). 4.3.1 Resiliency Though we have records of detection for sand verbena moth, we have no data regarding population size, population structure, dispersal distance, genetic exchange, or reproductive capacity for the sand verbena moth at any site where the species has been detected across its range. Therefore we rely on observational and anecdotal data for sand verbena moth detections and habitat availability and condition where it is available. There are six sites where the sand verbena moth has been detected within the last five years; three in British Columbia, Canada (Goose Spit, Island View Beach/Cordova Spit, and Goose Spit) and three in Washington in the United States (American Camp/Cattle Point, Deception Pass, and Fort Worden State Park). All of these sites may currently maintain populations. All six of these sites have 30-year normal precipitation below 1950 mm (77 in) and 30-year normal temperatures above 7.47 °C (45 °F) (see discussion in Section 3.0). All six sites have overall vulnerability ratings of moderate or high, meaning the habitat at sites are affected by several risk factors on a regular basis likely degrading the suitability of habitat over time. These habitat risk factors include erosion, inundation by sea water and debris, recreation and human use, development, and invasive plant and animal species. Sand verbena moths at all of these sites also likely experience some level of predation by species including red fox, tiger beetles, and bats, or other effects by invasive animals, however we have no information on whether or not these two factors cause any population level effects at any of the sites. American Camp/Cattle Point has an overall site condition rating of ‘Somewhat Compromised’ due to habitat risk factors, however the site currently contains well over 400 m2 (0.04 ha or 4,306 ft2) total leaf cover of Abronia latifolia with leaf density greater than 25 percent and high flower production from May to July. Additionally, the record of sand verbena moth detections at the site indicate it has the most robust and secure population that we are aware of. Two of the remaining five sites with potential populations also have overall site condition ratings of ‘Somewhat Compromised.’ Deception Pass reports approximately 600 m2 (0.06 ha or 0.14 ac) total host plant leaf cover while Fort Worden reports 4900 m2 (0.49 ha or 1.23 ac), but neither

site exceeds the leaf density threshold of greater than 25 percent leaf cover identified by the model.

Goose Spit, James Island, and Island View Beach/ Cordova Spit report that the extent of sand verbena moth habitat exceeds 400 m2 (0.04 ha or 4,306 ft2), but total host plant leaf cover and density at these sites is unknown, resulting in unknown site condition. We could find no information indicating the suggested levels of the host plant at each site represent total leaf cover; in fact the levels of Abronia latifolia reported for Goose Spit and Island View Beach/Cordova Spit include the caution that not all of the area reported is used by the sand verbena moth. If total leaf cover is determined to be greater than 400 m2 with a density greater than 25 percent and high flower production at these sites, then the sites would meet the condition criteria for a rating of either ‘Mostly Stable’ or ‘Somewhat Compromised.’

4.3.2 Redundancy Redundancy for the sand verbena moth appears to be limited to six potential populations, although our lack of information regarding historical redundancy and any trends in occupancy and abundance over the known range of the species make it difficult to judge whether or not this current low redundancy is a concern. Specifically, there has been inconsistent or little monitoring of sites where the sand verbena moth has been detected over the past 24 years. Although we have evidence to suggest that sand verbena moth populations may occur at six sites range-wide, without recent surveys for almost half the sites where the sand verbena moth was previously detected, our estimate of redundancy is very uncertain. 4.3.3 Representation The measure of adaptive capacity, or representation, draws on the known breadth of genetic, ecological, morphological, and behavioral diversity within and among populations across the species range. The best available information does not suggest the existence of morphological or behavioral differences between sand verbena moth populations throughout the range of the species. There is no evidence to indicate that the sand verbena moth can use any other plant as an adult or larval food resource aside from Abronia latifolia (COSEWIC 2003, p. 18), which itself is constrained to a narrow set of defined resources (BCIRT 2008, p. 1). Furthermore, the sand verbena moth has only been detected in areas with open sand, such as spits, beaches, active dunes, and other sand-dominated coastal sites despite extensive moth surveys, indicating that the species inhabits a narrow ecological range (COSEWIC 2003, pp. iv, p. 10–11). There has been a single genetic investigation that included samples of the sand verbena moth. Samples from three individuals were submitted to a genetic “barcoding” study of owlet moths (Noctuoidea; the group to which Copablepharon belongs) in Canada. The analysis was unable to differentiate between the species Copablepharon fuscum and C. absidum, the Columbia dune moth (Zahiri et al. 2014, table S1, tree S5.), but no revision to the taxonomy has taken place and the taxon is still considered a valid species. No other studies were identified that could be used to characterize the genetic representation of the species range wide. Additionally, we have no information regarding the dispersal distance of the sand verbena

moth aside from its ability to use habitat patches within 200m of larger occupied areas (COSEWIC 2003, pp. 9–10). The sand verbena moth has been observed flying strongly in winds between 5 and 15 km per hour (COSEWIC 2003, p. 17) and while some related moth species have been documented to fly great distances, the sand verbena moth has rarely been detected greater than 25 m (82 ft) from Abronia latifolia. The sites where the sand verbena moth has been detected are separated by distances that may be greater than the sand verbena moth can disperse, suggesting that most sites have low connectivity that promotes genetic exchange, and are therefore likely to exhibit low genetic diversity. The available information does not allow us to assess with certainty the adaptive capacity of the sand verbena moth (representation), but we presume adaptive capacity to be low based on the information provided above.

5.0 FUTURE CONDITIONS

In this section, we forecast future conditions for the eleven sites where the sand verbena moth has been detected. While there are multiple potential risk factors for the sand verbena moth, we chose to focus on the variables we felt we could most accurately forecast based on the data and models available and our knowledge of management at each of the sites. We include four potential scenarios based on climate change and conservation efforts. This analysis will help inform the potential risk of extinction for the sand verbena moth at each site in the future. 5.1 Climate Change Greenhouse gas emissions have increased at an unprecedented rate during the 20th century, resulting in global climate change. These changes have been characterized by warming atmospheric and ocean temperatures, diminishing snow and ice, and rising sea levels (Intergovernmental Panel on Climate Change (IPCC) 2014, pp. 2-3). Scientists use a variety of climate models, which include consideration of natural processes and variability, as well as various scenarios of potential levels and timing of greenhouse gas (GHG) emissions, to evaluate the causes of changes already observed and to project future changes in temperature and other climate conditions (e.g., Meehl et al. 2007, entire; Ganguly et al. 2009, pp. 11555, 15558; Prinn et al. 2011, pp. 527, 529). Combinations of models and emissions scenarios yield similar projections of increases in the most common measure of climate change, average global surface temperature (commonly known as global warming), until about 2030. Although projections of the magnitude and rate of warming differ after about 2030, the overall trajectory of all the projections is one of increased global warming through the end of this century, even for the projections based on scenarios that assume that greenhouse gas emissions will stabilize or decline. There is strong scientific support that warming will continue through the 21st century, and that the magnitude and rate of this change will be influenced substantially by the

extent of greenhouse gas emissions (IPCC 2014, p. 8; Meehl et al. 2007, pp. 760–764 and 797- 811; Ganguly et al. 2009, pp. 15555–15558; Prinn et al. 2011, pp. 527, 529). Between 1880 and 2012 the Earth warmed by 0.8 °Celsius (C) (1.5 °Fahrenheit (F)). This warming also includes ocean temperatures, with ocean surface waters (i.e., the top 76 m or 250 ft) experiencing a 0.3 to 0.5 °C (0.6 to 0.9°F) warming from 1970 to 2009 (CIG 2018, website). In addition to changes in temperature and precipitation, global sea level continues to rise 3.1 (± 0.2) mm (0.1 in ±0.01 in) per year, and in 2017 became the highest annual average in the satellite altimetry record (since 1993) (Thompson et al. 2018, p. S84). The two main factors contributing to sea level rise are: (1) water from melting glaciers and ice sheets, and (2) increased ocean volume due to warming of the water. These two factors were contributing approximately equally to sea level rise through the 1970s. However, melting of ice sheets and glaciers has accelerated since that time and the amount of sea level rise due to melting is now twice the amount due to thermal expansion (Thompson et al. 2018, p. S84-85). The current state of knowledge regarding the observed climate trends and likely future climate scenarios within the range of the sand verbena moth has been summarized in State of Knowledge: Climate Change in Puget Sound (Mauger et al. 2015). Although anthropogenic climate change will have large impacts on the Pacific Northwest, seasonal, annual, and longer- term variations in weather (ENSO or El Niño/La Niña and the Pacific Decadal Oscillation (PDO)) and climate in the region may amplify or counteract the long-term climate patterns caused by rising greenhouse gas emissions (Mauger et al. 2015, p.ES-3). Temperature in lowland areas of the Puget Sound area warmed approximately +0.72° C (+1.3°F) (0.39 to 1.06°C or +0.7 to +1.9°F) between 1895–2014 (Vose et al. 2014 in Mauger et al. 2015, pp. 2–1). All emissions scenarios project that warming will continue throughout the 21st century, both globally and locally in southwest British Columbia and in northwest Washington, and in all seasons, although increases in summer temperatures will be greater than for other seasons (Mauger et al. 2015, pp. 2–6). The projected increase in air temperatures through 2050 is approximately the same for all emissions scenarios because past emissions are a key driver. Much higher warming is possible after 2050 and the level of warming will depend on the amount of greenhouse gases emitted globally (Mauger et al. 2015. pp. 2–5). Under all emissions scenarios, heat waves are projected to intensify, while cold snaps are projected to become less severe (Mauger et al. 2015, pp. 2–5). Interannual and decadal variations in precipitation are expected to be larger than the long-term projected changes in precipitation for the 21st century (Mauger et al. 2015, p. ES-2). Although total precipitation is not projected to change greatly, the wettest days (99th percentile or 24- hour precipitation totals) are expected to increase by +22percent (range +5 to +34 percent) under a high emissions scenario (RCP 8.5) compared to 1970-1999 (Warner et al. 2015 in Mauger et al. 2015 p. ES-5). Although projected changes in precipitation are small relative to year-to-year variability, most models project increases in winter, spring, and fall precipitation

and all models predict decreases in summer precipitation for the Puget Sound area (Mauger et al. 2015, pp. 2–15). Sea level in the Puget Sound region is projected to continue to rise (from 2000 levels) anywhere from +35.6 cm to + 137.2 cm (+14 to +54 in) over the 21st century. Global sea level is projected to increase from 1986–2005 levels by +27.9 cm to + 96.5 cm (+11 inches to +38) inches by 2100 (Mauger et al. 2015, p. 4–3). More frequent coastal flooding and increased erosion are also projected to occur (Mauger et al. 2015. p. ES-6). Sea level rise will result in permanent inundation of low lying areas and coastal flood events will increase in frequency, depth, and duration (Mauger et al. 2015, p.4-1, 4–6); will exacerbate coastal river flooding; and increase the frequency of coastal flood events (Mauger et al. 2015, p. 4-6). Some tidal wetlands will expand while others will be reduced. Salt marsh is expected to increase while tidal freshwater marshes are expected to decrease (Mauger et al. 2015, p. ES-6). Shorelines that are not armored (e.g. having engineered structure to prevent erosion) will experience increased erosion; however, effects will depend on exposure and geology of sites. Coastal bluffs are projected to be heavily impacted by increased erosion (Mauger et al. 2015, p. 4–6). Local variation in sea level rise will be influenced by global, regional, and local factors. Land elevations in the region continue to change because of the active tectonics of the Pacific Northwest. Although global sea level and sea level in most of Puget Sound is rising, records show a decline in sea level for the northwest Olympic Peninsula, which is experiencing uplift (Mauger et al. 2015, p. 4–2). In addition, sea level change resulting from an earthquake could be substantial; however, it is not possible to predict these events (Mauger et al. 2015, p. 4–5). Research on changes in wave height, wind speed, and storm surge is currently lacking. There is no evidence of a long-term trend in storm surge (Mauger et al. 2015, p. ES-2); however, sea level rise will cause storm surge events to have greater impacts (Mauger et al. 2015, p. ES-5). It is important for us to acknowledge any potential effects of climate change in our analysis of the future condition of the sand verbena moth. While changes in precipitation and temperature may impact the sand verbena moth, it is unclear based on our present knowledge of the species how these changes would affect the sand verbena moth and how we would predict the impact of these effects on the populations into the future. There are some basic facts about the interactions between arthropods and temperature, though, which may inform our understanding of the influence climate change may have on the sand verbena moth. There are many variables that may influence the development of arthropods, but none is more important than temperature (Wagner 1991, p. 253). Other biotic and abiotic factors include food resource quantity and quality, insect density, humidity, rainfall, pH, and photoperiod (Wagner 1991, p. 253). Please note that temperature is given as the strongest influence on development, but both humidity and rainfall are listed as additional factors. Experimental work on another species of Noctuid moth (Copitarsia decolora) identified a near- linear relationship between the inverse of development time and temperature for larval development (e.g., the as temperature increases, development time decreases), with an upper 82 limit of 34.5 °C (94.1oF), a lethal temperature (Gould et al. 2005, pp. 549, 553). If we can extrapolate from this study to the sand verbena moth, we might conclude that increasing temperatures may lead to a shortened larval development period. If Abronia latifolia does not respond similarly by advancing its growth and flowering, it is possible that a phenological asynchrony between the sand verbena moth and its host plant could develop, though A. latifolia’s long flowering season may reduce this risk. We have no information regarding the effects of drought on the sand verbena moth. Presumably the species acquires all or most of its required moisture from the succulent leaves of its host plant, which may have the capacity to persist without fresh water for extended periods of time due to its deep tuberous roots. The effects of changing temperature and precipitation are likely to have an effect on the sand verbena moth that may influence the species’ resilience, as a whole. Temperature and precipitation levels could exceed the range of the species tolerance, or they could lead to the development of a phenological asynchrony between the moth and its host plant. Alternatively, many species in the genus Copablepharon are associated with hot arid environments. If the host plant performs similarly under increased temperatures and an asynchronous phenology does not develop between the two species, it is possible that warmer temperatures could have a positive effect on the sand verbena moth. Climate changes could also potentially result in shifts in El Niño/La Niña cycles, hurricanes, storms, and coastal ocean currents (Burkett and Davidson 2012, p. 141), but the nature of these shifts is difficult to predict and currently we have no evidence for long-term trends in storm surge (Mauger et al. 2015, p. ES-2). However, coastal flooding and erosion attributable to rising sea levels will generate higher storm surges even from minor storms (Burkett and Davidson 2012, p. 141). While it seems likely that coastal erosion will increase overall, and coastal erosion is a potential risk factor for the sand verbena moth because it can displace habitat, it is not possible to predict the location and extent of coastal erosion for all sites where positive detections have occurred. Furthermore, erosion is a complex phenomenon, and may not necessarily result in a net loss of habitat for the sand verbena moth and other coastal organisms. Page et al. (2011, pp. 12–13) describes how beaches often erode when subjected to waves and storm surge, and sediment is moved offshore but is may be stored in nearshore bars and only to be returned to the beach during calmer periods (e.g. summer accretion). We presume that sites where armoring of the feeder bluffs have taken place will experience a net loss of sediment, but we cannot state this definitively because we do not know the rate at which those sites were accreting, if at all. Goose Spit and Island View Beach/Cordova Spit have had portions of their feeder bluffs altered and may exhibit erosion in the future. At Wickaninnish and American Camp/Cattle Point, high winds have the capacity to remove large amounts of sand, exposing the roots of the Abronia latifolia. Erosion by wind and waves is most evident along the bluffs at American Camp/Cattle Point, as the A. latifolia grows along the top of feeder bluffs that nourish the adjoining beaches.

Thus, we acknowledge there are other potential impacts to the sand verbena moth attributed to climate change, but for the purposes of analyzing future conditions, we will focus on aspects of climate change that have clear and reasonably predictable impacts on the habitat of sand verbena moth. Sea level rise is fairly predictable using climate models and will have a direct impact on the sand verbena moth through long-term loss of habitat. In order to incorporate the effects of sea level rise into future conditions for the sand verbena moth, we analyzed predictions of two IPCC greenhouse gas emissions scenarios. The IPCC identifies various greenhouse gas Representative Concentration Pathways (RCPs) which take into account different scenarios of greenhouse gas emissions, atmospheric concentrations, and land use, which are likely to unfold in the 21st century. The IPCC characterizes four potential scenarios: RCP 2.6 is the scenario that assumes stringent mitigation where warming does not exceed 2°C (3.6°F) above preindustrial temperatures. RCP 4.5 is an intermediate emissions scenario where atmospheric CO2 concentrations are expected to equal approximately 650 ppm after the year 2100. Baseline scenarios where no further efforts are made to curb emissions include scenario RCP8.5, where emissions aggressively increase to approximately 1370 ppm CO2 after the year 2100. For comparison, current atmospheric CO2 concentrations are around 400 ppm (IPCC 2014, p. 57). For the purposes of analyzing future conditions for the sand verbena moth, we considered one intermediate scenario that assumes moderate cuts are made to emissions (RCP 4.5), and one high emissions scenario that assumes no deviation from the current emissions trajectory (RCP 8.5). These emissions scenarios were chosen because they frame the most likely high and low boundaries of the possible future in regard to greenhouse gas emissions. We consider future scenarios to a future time period of the present to mid-century (approximately 30 years) as well as to the year 2100 (approximately 80 years),. We analyzed sea level rise and associated coastal flooding in areas that overlap with known sand verbena moth populations through the end of the century using Climate Central’s Surging Seas: Risk Zone Map (Surging Seas, 2018, website). Climate Central is an independent organization of climate scientists and journalists (Climate Central, 2018, website). Their Surging Seas: Risk Zone Map climate modeling tool maps areas vulnerable to flooding from the combined effects of storm surge, tides, and permanent submergence by long-term sea level rise. The Surging Seas tool models data on the effects of potential degrees of greenhouse gas emissions reported by the IPCC (IPCC, 2014, entire). Within the U.S, the Surging Seas tool incorporates the latest high-resolution Lidar elevation data from NOAA, while outside the U.S., satellite-based elevation data from NASA and Climate Central’s Coastal DEM data are used. Elevations are transformed so they are expressed relative to local high tide lines (Mean Higher High Water) (Climate Central 2018, entire). The Surging Seas tool uses over 1,000 global tide gauges to give local projections for sea level rise through the year 2200, based on two recent publications (Kopp et al., 2014, entire; Kopp et al. 2017, entire), which build off IPCC global

projections and include new data on the contribution of the melting Antarctic ice sheets to sea level rise (DeConto and Pollard, 2016, entire). Flood risk projections which integrate sea level rise using methods described in Tebaldi et al. 2012 (entire) and Buchanan et al. 2012 (entire) are provided using data from selected tide gauges within the U.S. where at least 30 years of hourly water level data were available. For Canadian sites, flood risk projections are based on integrating sea level projections with flood risk statistics from the Global Tide and Surge Reanalysis (Muis et al. 2016, entire). We suggest the reader note that sand habitats are dynamic and that the shoreline and elevations fluctuate slightly from year to year based on storms and currents, leading to sand deposition (i.e. accretion) or removal (erosion). The tool provides an estimate of potential future conditions, but may not be entirely accurate for any given site or year. 5.2 Analysis of Future Condition

5.2.1 Risk factors Potential risk factors for sand verbena moth have been identified in this report. For the purposes of analyzing future conditions, we considered only those risk factors for which there is enough information to reasonably predict the severity or presence of the risk factor into the future, and how changes in that severity or presence will impact sand verbena moth habitat. For example, there is inadequate data available to determine how predation (e.g., by fox, tiger beetle, or bats) or habitat destruction by rabbits, is impacting sand verbena moth occurrences presently, let alone how that those impacts will change into the future when secondary factors, such as those affecting predator and rabbit populations, may also change. Likewise it is not possible to predict changes overtime to sand verbena moth habitat resulting from plate tectonics. Regarding the effects of climate change, though it appears that sand verbena moth have annual average precipitation and temperature limitations, it is difficult to predict what the effects of climate change on those limitations will mean for the species. We know that seasonal changes to precipitation are projected in the range of sand verbena moth, but we don’t know what the average annual change will be and how that will affect the species. We know that temperature is projected to increase in the area of sand verbena moth distribution but we don’t know whether that will be detrimental or beneficial to the species. However, we do know sand verbena moths are obligate mutualists of the host plant, Abronia latifolia, upon which it depends during all stages of its life cycle (COSEWIC 2003, p. 10). Further, patches of A. latifolia must be large, dense, and be in good enough condition to produce abundant flowers, in order to sustain sand verbena moth populations. The sand verbena moth has only been found in A. latifolia patches that are dense and have greater than 400 m2 (0.04 ha or 4,306 ft2) total leaf cover (COSEWIC 2003, p. 10-11; Fleckenstein 2018b, p. 9). It appears that the sand verbena moth requires a certain threshold of resource availability, because isolated, small, sparse, or non-flowering populations of A. latifolia do not appear to support the sand verbena moth (NatureServe 2009 (online database); Fleckenstein et al. 2018b,

p. 36). For example, light-trapping in a grass-dominated sand verbena patch at Cattle Point did not result in capture of sand verbena moth despite its presence in nearby habitat patches (Fleckenstein et al. 2018b, p. 36). As such, any factor that could reduce the abundance or vigor of A. latifolia populations, especially those that are currently occupied by the sand verbena moth, could be a risk factor for the sand verbena moth in the future. Therefore, we evaluate future conditions based on the effects of inundation from seal level rise and coastal flooding on sand verbena moth habitat, and the effects of potential management actions on controlling invasive plant species that degrade habitat. 5.2.1.1 Inundation caused by sea level rise and coastal flooding Abronia latifolia is restricted to coastal beaches, sandy spits and islands, and open, unstable dunes and can be considered either a beach or dune obligate found near sea-level (LaFontaine 2004, pp. 174–175; Tillet, 1967, p. 320). Abronia latifolia is an early seral species, thriving at the leading edge of the coastal plant community (Cooper 1922, p. 86; Kumler 1969, p. 702; McBride and Stone 1976, p. 119). The Abronia latifolia’s close proximity to the shoreline makes it vulnerable to the effects of climate change, which is a risk factor for which adequate data exists in order to make future predictions. Specifically, sea level rise can lead to the direct loss of habitat currently occupied by the sand verbena moth, and we can use models to predict where sea level rise will inundate coastal areas that currently support sand verbena moth habitat. In addition, we can identify areas that currently support sand verbena moth habitat and project whether or not they are likely to be regularly inundated by coastal flooding. 5.2.1.2 Invasive plants Competing vegetation that leads to a reduction in Abronia latifolia negatively affects the sand verbena moth through the reduction of nectar availability for adults and food resources for immature moths. For example, in areas where A. latifolia has been observed competing with non-native grasses, no moths have been detected, despite being directly adjacent to other patches occupied by the sand verbena moth (Fleckenstein et al. 2018b, p. 9). Habitat encroachment by invasive or non-native dune-stabilizing plants is therefore a risk factor of the sand verbena moth, and one that can be curtailed by active habitat management. We consider the effects of habitat management efforts aimed at limiting encroachment by non-native plants on sand verbena moth populations into the future reasonably predictable, and therefore include this risk factor in our future conditions analysis

5.2.2 Influence Diagram of Future Risk Factors

Figure 21. Influence diagram of future risk factors for the sand verbena moth 5.2.3 Descriptions of Future Scenarios For our analysis of the sand verbena moth’s future condition, we constructed four future scenarios focused on effects of sea level rise and levels habitat management (Table 9). These scenarios are meant to cover a large breadth of future conditions that could occur in sand verbena moth populations, and all scenarios may not be equally plausible. To analyze future condition, we projected each scenario to a future time period of the present to 2100, corresponding to climate modeling data. The global emissions scenarios, RCP scenarios, were developed to predict upper and lower bounds of warming based on (as yet unknown) scenarios of future emissions. In other words, the climate models are all in agreement until about mid-century because the warming that will occur until mid-century is based on emissions that have already occurred (and therefore the resulting warming through that time frame is now unavoidable no matter what course of action we take, so all models predict the same effects through this period of time). The higher uncertainty levels in projecting out beyond mid-century relates to the fact that the amount of warming past mid-century depends on emissions that occur in the next few decades (IPCC 2014, p. 59). RCP 4.5 is the scenario of future (beyond mid-century) warming, given significant cuts to emissions whereby emissions sharply decrease starting mid-century. RCP 8.5 represents no change in current course (highest emissions scenario, "business as usual"). So the uncertainty isn't so much in the models themselves as it is in predicting what the input to the

models should be (the amount of emissions yet to come or what steps the world will take in the next few decades to cut emissions, based most likely on political decisions that are made). This is why we include future scenarios ranging from the best case (RCP 4.5) to the worst case (RCP 8.5) out to the year 2100, when looking at projected effects to sand verbena moth habitat.

Table 9. The four future scenarios used to estimate future conditions at each site. Scenario #1 Scenario #2 Scenario #3 Scenario #4 Moderate carbon Moderate carbon Unchecked emissions Unchecked emissions cuts (RCP4.5) cuts (RCP4.5) (RCP8.5) (RCP8.5) Invasive Invasive Invasive Invasive management management management management (+) (=) (+) (=)

Scenario 1 The first scenario should be considered a best-case scenario for the future conditions of sand verbena moth, whereby moderate cuts to GHG emissions (represented by RCP 4.5) result in smaller degrees of sea level rise, and management for invasive plant species in sand verbena moth habitat increases. In this scenario smaller degrees of sea level rise lead to less loss of suitable or occupied habitat for the sand verbena moth. Increased habitat management in this scenario would reduce the amount of habitat loss due to establishment of invasive plants such as thistle or beachgrass in sand verbena moth habitat, and thereby reducing the potential for dune stabilization in managed areas. Scenario 2 In the second scenario, moderate cuts to GHG emissions (RCP 4.5) are identical to those in the best-case (first) scenario, leading to lesser degrees of sea level rise that result in habitat loss for the sand verbena moth. In this scenario however, we assume no change in the extent or type of habitat management from that which is practiced under current conditions. We expect in this scenario that there is future potential for encroachment by invasive plants on sand verbena moth habitat. The spread of invasive plants into sand verbena patches could result in the displacement or the host plant being out competed, therefore resulting in habitat loss for the sand verbena moth. Colonization of invasive plants in sand verbena moth habitat may also lead to an acceleration in dune stabilization, making the soils unsuitable for the moth. Scenario 3 The third scenario assumes that invasive species management in sand verbena moth habitat increases, but that emissions continue unchecked (RCP 8.5). This scenario would see habitat loss for the sand verbena moth due to higher degrees of sea level rise. However, active management of invasive beach grass and thistle in sand verbena moth habitat would increase, thereby minimizing further dune stabilization and invasive takeover of sand verbena patches.

Scenario 4 The fourth scenario would be the worst-case scenario in our analysis, whereby GHG emissions continue unchecked (RCP 8.5) and the degree and extent of active management for invasive plants in sand verbena moth habitat remains unchanged from current levels. In this scenario higher levels of sea level rise would lead to more habitat loss for the sand verbena moth. In addition, the potential for encroachment by invasive plants into sand verbena moth habitat would remain at the same levels as current conditions, leading to the possibility of additional habitat loss due to invasive plant colonization and dune stabilization. 5.2.4 Assumptions of Future Conditions In our future analysis we are considering various scenarios of climate change and invasive plant management, but are assuming that all other variables that could impact sites occupied by the sand verbena moth remain equal throughout future scenarios. For the purposes of our future condition analysis, we assume that the sand verbena moth’s host plant, Abronia latifolia, will be unable to tolerate inundation by salt water caused by coastal flooding occurring with an average frequency of once every other year. The climate modeling tool we used (Surging Seas Risk Zone Map, Climate Central) is an interactive data toolkit that produces maps showing future projections for sea level rise under various greenhouse gas emissions scenarios. It also provides projections for coastal flood risk. Flood risk can be analyzed by 10 percent, 20 percent, and 50 percent accrued or annual probability of flooding. Accrued flood risk is the multi-year risk of flooding between the present and the future year shown on the map while annual risk is the single-year risk of flooding within the specified future year. Alongside predicted sea level rise, we consider that an annual flooding probability of 50 percent in areas that currently support the sand verbena moth would negatively impact the sand verbena moth population, based on our assumption of the host plant’s low level of inundation tolerance. For the purposes of our analysis, we assume that this frequency of flooding would negatively impact the sand verbena moth by causing direct mortality to or loss of vigor of A. latifolia due to inundation by salt water. Wilson (1972) notes that A. latifolia and other Abronia spp. are not true halophytes (salt-loving plants), but rather tend to occur in areas of lower salt content that are adjacent to saline environments (p. 425), and ultimately describes Abronia species as “nonsaline” (p. 435). We assume that areas currently supporting A. latifolia that will experience an annual inundation probability of 50 percent with salt water in the future would no longer be able to support a strong and healthy population of A. latifolia. The sand verbena moth is known only from dense, vigorous, flowering stands of A. latifolia (NatureServe 2009, online database), and therefore our analysis assumes that even if a A. latifolia population was able to sustain inundation by salt water, it would not likely be healthy enough to support the sand verbena moth. The probability of less frequent flooding modeled by the tool, such as 10 percent or 20 percent flood risk, or 50 percent accrued flood risk, may also have negative impacts to sand verbena moth habitat and would occur in a shorter time frame than the same flood heights modeled at 89

a 50 percent annual probability. For example, a 20 percent flood risk would equate to an area experiencing flooding once every five years on average, which may be enough saltwater exposure to hinder growth and flowering, or even cause mortality, of Abronia latifolia, thereby impacting its ability to support the sand verbena moth. However, for the purposes of predicting the viability of the sand verbena moth into the future at a particular site, we consider the highest frequency of flooding (50 percent annual probability) as that which we can be reasonably certain would compromise the host plant enough to preclude its ability to support the sand verbena moth in the future. It is also possible that A. latifolia growing in close proximity to inundated areas could be compromised. The taproot of A. latifolia can be up to four and a quarter meters (14 ft) long (Wilson 1972, p. 427), suggesting that these plants could be impacted by changes to the water table even in areas that are not inundated. One climate change report notes that “sea-level rise, changing ocean currents, increased wave heights, and intensification of coastal storms interact with the shoreline to exacerbate coastal erosion, flooding, and saltwater intrusion” (Burkett and Davidson 2012, p. xxvi) and “rising sea levels contribute to increased salinities within the coastal zone”(Burkett and Davidson 2012, p. 21). However, because we can’t predict where and to what extent changes in groundwater salinity may occur, and how these changes will affect A. latifolia, we do not include this potential impact in the analysis of future scenarios. 5.2.5 Acknowledgement of Uncertainty Variation in global temperatures is influenced by changes in solar radiation, volcanic eruptions, and greenhouse gas emissions (Mote et al. 2013, p.25). The extent and speed at which both global and regional climate will change depends on both the amount of future carbon emissions and how climate changes in response to those emissions. Projections of future climate conditions are developed by making assumptions about future greenhouse gas emissions and then modeling how climate changes in response to those emissions. Because there is uncertainty about both future emissions scenarios and how climate will respond, projections of future climate always include a range of scenarios. Climate models have great utility because they allow us to make predictions of how climate may change in the future, but their results should be interpreted cautiously. Models are mathematical representations of what can happen, but they do not always accurately predict future events. For our analysis of the sand verbena moth’s future condition, we acknowledge the innate uncertainty associated with climate modeling, particularly given the dynamic nature of the active dune system and shoreline areas where sand verbena moths have been detected. We also recognize that these models represent some of the best available scientific data we can utilize for predicting the future condition of the species’ habitat. 5.3 Results of Future Condition Analysis In this section, we present the results of our future conditions analysis for each known sand verbena moth detection location under four possible future scenarios in the time period spanning the present to the year 2100. For narrative descriptions of future conditions at each

site and accompanying maps showing projected sea level rise, please see Appendix B. Future Conditions. 5.3.1 Future Conditions Summary We analyzed how the effects of the future scenarios changed the site condition rating for the locations with detections of the sand verbena moth. We created three condition categories to characterize future site condition as described below:

• Status Quo: Habitat for the species at the site is likely to persist in a condition similar to its current condition, or not deteriorate significantly. Due to the very limited demographic data for sand verbena moth at most of these sites, this evaluation does not necessarily mean that the sand verbena moth will actually exist in good condition at the site in the future scenario, but that the current condition of the habitat at the site is not likely to decrease significantly in quantity or quality into the future.

• Decreased: Some habitat may persist into the future at the site, but it would be in poorer condition than it currently is.

• Imperiled: Significant loss of habitat is projected and that extirpation of the sand verbena moth at the site, if it currently exists there, is likely in the timeframe of the future scenarios considered (by 2100).

Detailed effects of future scenarios are outlined in Table 10a for sites with potential populations of sand verbena moth. Table 10b outlines the effects of future scenarios for sites that may have had historic populations of sand verbena moth, but without enough information to indicate whether or not they currently support a population of sand verbena moth. Finally, Table 10c outlines the effects of future scenarios for sites without enough information to indicate whether or not they ever supported a population of sand verbena moth.

Table 10a: Detailed effects of future scenarios for sites with potential populations of sand verbena moth. Note: SVM=sand verbena moth. Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Goose Spit Sea level 0.3 m (1 ft) (by 2100) 0.3 m (1 ft) (by 2100) 0.9 m (3 ft) (by 0.9 m (3 ft) (by 2100) rise 2100) Potential 1.8 m (5.9 ft) (by 2100) 1.8 m (5.9 ft) (by 2.4 m (7.9 ft) (by 2.4 m (7.9 ft) (by flooding 2100) 2100) 2100) height Invasive decreased increased decreased increased species Effects • substantial habitat loss • substantial habitat • 90% habitat loss • 90% habitat loss by 2100 • restoration could lead loss • SVM unlikely to • SVM unlikely to to new habitat where • SVM unlikely to persist persist SVM could persist persist

Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Site Decreased Imperiled Imperiled Imperiled condition Island view Beach/ Cordova Sea level 0.3 m (1 ft) (mid-century) 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- rise 0.6 m (2 ft) (2100) century) century) century) 0.6 m (2 ft) (2100) 1.2 m (3.9 ft) (2100) 1.2 m (3.9 ft) (2100) Potential 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- flooding century) century) century) century) height 2.4 m (7.9 ft) (2100) 2.4 m (7.9 ft) (2100) 2.7 m (8.9 ft) (2100) 2.7 m (8.9 ft) (2100) Invasive decreased increased likely inundated likely inundated species Effects • Vast majority of habitat • Vast majority of • Vast majority of • Vast majority of by 2100 will be inundated habitat will be habitat will be habitat will be • SVM could persist in inundated inundated inundated some areas • SVM unlikely to • SVM unlikely to • SVM unlikely to persist persist persist

Site Decreased Imperiled Imperiled Imperiled condition James Island Sea level 0.3 m (1 ft) (mid-century) 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- rise 0.6 m (2100) century) century) century) 0.6 m (2100) 1.2 m (3.9 ft) (2100) 1.2 m (3.9 ft) (2100) Potential 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- flooding century) century) century) century) height 2.4 m (7.9 ft) (2100) 2.4 m (7.9 ft) (2100) 2.7 m (8.9 ft) (2100) 2.7 m (8.9 ft) (2100) Invasive • Shoreline inundated • Shoreline inundated • Shoreline • Shoreline inundated species inundated

Effects • Most habitat lost • Most habitat lost • Most habitat lost • Most habitat lost by 2100 • SVM unlikely to persist • SVM unlikely to • SVM unlikely to • SVM unlikely to persist persist persist

Site Imperiled Imperiled Imperiled Imperiled condition American Camp/ Cattle Point Sea level 0.3 m (1 ft) (mid-century) 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- rise 0.6 m (2 ft) (2100) century) century) century) 0.6 m (2 ft) (2100) 1.2 m (3.9 ft) (2100) 1.2 m (3.9 ft) (2100) Potential 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- flooding century) century) century) century) height 2.4 m (7.9 ft) (2100) 2.4 m (7.9 ft) (2100) 2.7 m (8.9 ft) (2100) 2.7 m (8.9 ft) (2100) Invasive decreased continued decreased continued species Effects • habitat persists • Some habitat loss • habitat persists • Some habitat loss by 2100 • SVM persist • SVM persist • SVM persist • SVM persist Site Status Quo Decreased Status Quo Decreased condition

Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Deception Pass Sea level 0.3 m (1 ft) (mid-century) 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- rise 0.6 m (2 ft) (2100) century) century) century) 0.6 m (2 ft) (2100) 1.2 m (3.9 ft) (2100) 1.2 m (3.9 ft) (2100) Potential 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- flooding century) century) century) century) height 2.4 m (7.9 ft) (2100) 2.4 m (7.9 ft) (2100) 2.7 m (8.9 ft) (2100) 2.7 m (8.9 ft) (2100) Invasive Decreased Increased Mostly inundated Likely inundated species Effects • restoration could lead • significant habitat • significant habitat • significant habitat by 2100 to new habitat where loss loss loss SVM could persist • SVM unlikely to • SVM unlikely to • SVM unlikely to persist persist persist Site Decreased Imperiled Imperiled Imperiled condition Fort Worden Sea level 0.3 m (1 ft) (mid- century) 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- rise 0.6 m (2 ft) (2100) century) century) century) 0.6 m (2 ft) (2100) 1.2 m (3.9 ft) (2100) 1.2 m (3.9 ft) (2100) Potential 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- flooding century) century) century) century) height 2.1 m (6.9 ft) (2100) 2.1 m (6.9 ft) (2100) 2.7 m (8.9 ft) (2100) 2.7 m (8.9 ft) (2100) Invasive Decreased Increased Decreased Increased species Effects • 50 % habitat loss • 50 % habitat loss • Over 50 % habitat • Over 50 % habitat by 2100 • SVM may persist • SVM may still persist loss loss • SVM may persist • SVM unlikely to persist Site Decreased Decreased Decreased Decreased condition

Table 10b. Detailed effects of future scenarios for sites that may have had historic populations of sand verbena moth, but without enough information to indicate whether or not they currently support a population of sand verbena moth. Note: SVM=sand verbena moth. Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Sandy Island Sea level rise 0.3 m (1 ft) (by 2100) 0.3 m (1 ft) (by 0.9 m (3 ft) (by 2100) 0.9 m (3 ft) (by 2100) 2100) Potential 1.8 m (5.9 ft) (by 2100) 1.8 m (5.9 ft) (by 2.4 m (7.9 ft) (by 2100) 2.4 m (7.9 ft) (by flooding 2100) 2100) height Invasive Decreased Continued Decreased Continued species

Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Effects by • Up to 80% habitat loss • At least 80% • Up to 80% habitat loss • At least 80% 2100 • Management could habitat loss • Management could habitat loss allow for SVM to • SVM unlikely to allow for SVM to • SVM unlikely to persist persist persist persist

Site condition Decreased Imperiled Decreased Imperiled Kulakala Point Sea level rise 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- century) century) century) century) 0.6 m (2 ft) (2100) 0.6 m (2 ft) (2100) 1.2 m (3.9 ft) (2100) 1.2 m (3.9 ft) (2100) Potential 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- flooding century) century) century) century) height 2.1 m (6.9 ft) (2100) 2.1 m (6.9 ft) 2.7 m (8.9 ft) (2100) 2.7 m (8.9 ft) (2100) (2100) Invasive Likely inundated Likely inundated Likely inundated Likely inundated species Effects by SVM unlikely to persist SVM unlikely to SVM unlikely to persist SVM unlikely to 2100 due to inundation persist due to due to inundation persist due to inundation inundation Site condition Imperiled Imperiled Imperiled Imperiled

Table 10c. Detailed effects of future scenarios for sites that do not have enough information to indicate whether or not they ever supported a population of sand verbena moth. Note: SVM=sand verbena moth. Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Wickaninnish Sea level rise none none none none Potential none none none none flooding height Invasive decreased continued decreased continued species Effects by • habitat persists • habitat persists • habitat persists • habitat persists 2100 SVM persist SVM persist SVM persist SVM persist Site condition Status Quo Status Quo Status Quo Status Quo Graveyard Spit Sea level rise 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- century) century) century) century) 0.6 m (2 ft) (2100) 0.6 m (2 ft) (2100) 1.2 m (3.9 ft) (2100) 1.2 m (3.9 ft) (2100) Potential 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- flooding century) century) century) century) height 2.1 m (6.9 ft) (2100) 2.1 m (6.9 ft) (2100) 2.7 m (8.9 ft) (2100) 2.7 m (8.9 ft) (2100)

Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Invasive Likely inundated Likely inundated Likely inundated Likely inundated species Effects by SVM unlikely to SVM unlikely to SVM unlikely to SVM unlikely to 2100 persist due to persist due to persist due to persist due to inundation inundation inundation inundation Site condition Imperiled Imperiled Imperiled Imperiled Rocky Point Sea level rise 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- 0.3 m (1 ft) (mid- century) century) century) century) 0.6 m (2 ft) (2100) 0.6 m (2 ft) (2100) 1.2 m (3.9 ft) (2100) 1.2 m (3.9 ft) (2100) Potential 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- 1.8 m (5.9 ft) (mid- flooding century) century) century) century) height 2.4 m (7.9 ft) (2100) 2.4 m (7.9 ft) (2100) 2.7 m (8.9 ft) (2100) 2.7 m (8.9 ft) (2100) Invasive Likely inundated Likely inundated Likely inundated Likely inundated species Effects by • significant habitat • significant habitat • significant habitat • significant habitat 2100 loss loss loss loss • SVM unlikely to • SVM unlikely to • SVM unlikely to • SVM unlikely to persist persist persist persist Site condition Imperiled Imperiled Imperiled Imperiled

Of the sites with potential populations, American Camp/Cattle Point will be in ‘Status Quo’ condition under the first, best-case scenario of reduced greenhouse gas emissions (RCP 4.5) and an increase in invasive plant management. The condition of four other sites will be ‘Decreased,’ (Goose Spit, Island View Beach/Cordova Spit, Deception Pass, and Fort Worden) indicating that the sand verbena moth may persist at these locations, but likely with less available habitat. James Island is likely to be ‘Imperiled’ under this scenario. Two of the sites with potential populations (American Camp/Cattle point and Fort Worden) are projected to be in ‘Decreased’ condition under the second scenario. The remaining four sites (Goose Spit, Island View Beach/ Cordova Spit, James Island, and Deception Pass) are projected to be ‘Imperiled’ and unlikely to maintain enough habitat for the sand verbena moth to persist under the second scenario, one that assumes RCP 4.5 climate conditions and no change in current habitat management practices. The third scenario assumes higher greenhouse gas emissions (RCP 8.5) but also includes an increase in habitat management, making the condition results slightly better than in the second scenario despite higher degrees of sea level rise. Under this scenario American Camp/Cattle Point would remain in ‘Status Quo’ condition. Fort Worden would be in ‘Decreased’ condition but would maintain some habitat. Under this scenario Goose Spit, Island View Beach/ Cordova Spit, and James Island in Canada and Deception Pass in the United States are projected to suffer significant loss of suitable habitat making their condition ‘Imperiled.’

The fourth scenario assumes higher greenhouse gas emissions (RCP 8.5) and no change in current habitat management practices; this scenario yields the worst condition results, with only one site, American Camp/Cattle Point in the United States, in ‘Decreased’ condition with the retention of some suitable habitat. The other five sites are forecasted to suffer significant loss of suitable habitat and be ‘Imperiled.’ Future conditions based on the four scenarios at the six sites with potential populations of sand verbena moth are summarized below in Table 11a. We also display future conditions for sites with potential historic populations but not enough information to indicate whether or not they support current populations in Table 11b, and sites without enough information to indicate whether or not they ever supported a population in Table 11c.

Table 11a. Summary of future conditions at sites where the sand verbena moth may currently persist. Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Goose Spit Decreased Imperiled Imperiled Imperiled Island View Imperiled Imperiled Imperiled Beach/ Decreased Cordova Spit James Island Imperiled Imperiled Imperiled Imperiled American Camp/Cattle Status Quo Decreased Status Quo Decreased Point Deception Imperiled Imperiled Imperiled Decreased Pass Fort Imperiled Decreased Decreased Decreased Worden

Table 11b. Summary of future conditions at sites with potential historical populations but not enough information to indicate whether or not they currently support populations of sand verbena moth. Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Sandy Island Decreased Imperiled Decreased Imperiled Kulakala Point Imperiled Imperiled Imperiled Imperiled

Table 11c. Summary of future conditions at sites without enough information to indicate whether they ever supported a population of sand verbena moth.

Site Scenario 1 Scenario 2 Scenario 3 Scenario 4

(- CO2, + mgmt) (- CO2, = mgmt) (+ CO2, + mgmt) (+ CO2, = mgmt) Wickaninnish Status Quo Status Quo Status Quo Status Quo Rocky Point Imperiled Imperiled Imperiled Imperiled Graveyard Spit Imperiled Imperiled Imperiled Imperiled

5.3.2 Resiliency Goose Spit, Island View Beach/Cordova Spit, and Deception Pass are in ‘Decreased’ condition under the first scenario only, though sand verbena moth may not persist at all areas of the sites. Under all other scenarios, the sites are categorized as ‘Imperiled.’ James Island is ‘Imperiled’ under all scenarios due to the projections for inundation at this low lying site. American Camp/Cattle Point will be ‘Decreased’ in Scenarios 2 and 4 due to some loss of habitat, but in the increased management scenarios (Scenario 1 and 3) the site maintains good suitable habitat and ‘Status Quo’ condition; the sand verbena moth is expected to persist at this site into the future. The majority of the suitable habitat at American Camp is expected to be unaffected by strong storm surges and inundation associated with sea level rise, but may continue to be strongly affected by invasive plant species. Cattle Point, though not expected to be inundated, is likely to experience an increased rate of erosion driven by fierce winter storms and increasing wind and wave energy. Fort Worden is likely to be in ‘Decreased’ condition but maintain enough habitat for sand verbena moth for the species to persist in all but the worst case scenario (4), where the site will be ‘Imperiled’ from a significant decrease in habitat resulting from the combination of all three risk factors.

5.3.3 Redundancy Redundancy for the sand verbena moth appears to be limited to six potential populations, although the lack of information regarding presence/absence at other sites, trends in occupancy and abundance over the known range of the species, and historical redundancy make it difficult to judge whether our current estimate of low redundancy is a concern. In our future condition analysis, only one of these six sites, American Camp/Cattle Point, is projected to maintain enough suitable habitat for sand verbena moth to persist in all four scenarios. Fort Worden maintains enough suitable habitat for sand verbena moth to persist in at least three future scenarios. Goose Spit, Island Beach/ Cordova Spit, James Island, and Deception Pass are only likely to maintain enough suitable habitat for sand verbena moth to persist in the best case scenario. The current level of redundancy for sand verbena moth is projected to decrease in the future based on our modeled scenarios. Five of the six sites with potential populations (Island View Beach/Cordova Spit and James Island in Canada, and American Camp/Cattle Point, Deception Pass, and Fort Worden in the United States) are clustered at the southern end of the known range of the species. The outlier is Goose Spit at the northern end of the range. If Goose Spit were to become extirpated, there would be a significant reduction in the distribution of these potential populations and therefore the species would be at greater risk from catastrophic events.

5.3.4 Representation The best available information does not indicate any behavioral or morphological diversity in the sand verbena moth. There has been scant genetic analysis conducted for the sand verbena moth, so the level of genetic diversity is uncertain. Additionally, we see little ecological diversity across the species known range. Based on the information we have, it appears that representation is low for sand verbena moth. If future conditions result in extirpation of some populations, any diversity that may exist range-wide will be reduced. Therefore, future representation is expected to decrease in parallel with decreased redundancy.

6.0 SYNTHESIS

While we have some understanding of the ecological needs of the sand verbena moth and factors likely influencing species viability, we are lacking substantial information regarding the life history and ecology of the species. We suspect that the sand verbena moth has lost historical species-level viability primarily due to development, habitat fragmentation, recreation, and encroachment of non-native species into its habitat. We anticipate that continued effects of climate change, primarily inundation from sea level rise and increased flooding events, and effects from invasive species will impact the species and its habitat into the future. Because a large proportion of known occupied habitat is publicly owned and managed, there is potential for cooperative, collaborative conservation planning, and decision making despite conditions of environmental uncertainty.

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Combs, J. C. 2019. In litteris. Email response from Julie Combs PhD, Affiliate Assistant Professor University of Washington, to Rebecca Migala, Endangered Species Biologist, U. S. Fish and Wildlife Service, regarding concerns of Jim Troubridge on the taxonomy of Copablepharon fuscum that were shared via email on May 30, 2019. Crabo, L. 2019. In litteris. Email response from Lars Crabo, M.D., Mt. Baker Imaging, to Rebecca Migala, Endangered Species Biologist, U. S. Fish and Wildlife Service, regarding concerns of Jim Troubridge on the taxonomy of Copablepharon fuscum that were shared via email on May 16, 2019. Crabo, L., J. Combs, J. Fleckenstein, and S. Vernon. 2017. In litteris. Email correspondence between S. Vernon, independent author and naturalist, L. Crabo, sand verbena moth species expert, J. Combs, contract botanist, J. Fleckenstein, Rare Species Zoologist, Washington Department of Natural Resources, Natural Heritage Program, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding placement of sand verbena moth eggs. Fleckenstein, J. 2019. In litteris. Peer review comment received regarding proximity of light traps to the edge of the bluffs at Cattle Point. Fleckenstein, J., A. Thorpe, and T. Kaye. 2019. In litteris. Email correspondence between J. Fleckenstein, retired rare species zoologist for the Washington Department of Natural Resources Natural Heritage Program, A. Thorpe, Natural Heritage Program Manager, T. Kaye, Executive Director at the Institute for Applied Ecology, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding informal surveys for the sand verbena moth on the Oregon coast in conjunction with monitoring of pink sand verbena. Gatten, J. 2019. In litteris. Email correspondence between J. Gatten, Wildlife Biologist, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding a 2013 blog post with an image of the sand verbena moth at Island View Beach/Cordova Spit. Goulden, M. 2018. In litteris. Email correspondence between M. Goulden, Department of National Defense, Canada, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding the status of the sand verbena moth and its habitat at Goose Spit. Hammond, P. 2019. In litteris. Email response from Paul Hammond, Ph.D., research biologist, Pacific Northwest Moths, to Rebecca Migala, Endangered Species Biologist, U. S. Fish and Wildlife Service, regarding concerns of Jim Troubridge on the taxonomy of Copablepharon fuscum that were shared via email on May 16, 2019. Henderson, D. 2018. In litteris. Email correspondence between D. Henderson, Acting Head of Conservation Planning Unit, Canadian Wildlife Service, Pacific Region, Environment and 109

Climate Change Canada, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding a formal request for information and data pertaining to the status of the sand verbena moth in Canada. Hudson, V. 2018. In litteris. Email correspondence between V. Hudson, West Coast Stewardship Coordinator for British Columbia, Nature Conservancy of Canada, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding sand verbena moth detections and habitat on James Island. Hudson, V. and N. Page. 2019. In litteris. Email correspondence between V. Hudson, West Coast Stewardship Coordinator for British Columbia, Nature Conservancy of Canada, N. Page, Proprietor of and Biologist for Raincoast Applied Ecology, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding sand verbena moth detections and habitat in the upland area of James Island. Ingram, D. 2019. In litteris. Email correspondence between D. Ingram, Canadian citizen, naturalist, and photographer, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding his personal sand verbena moth positive and negative detections at Goose Spit (2014 and 2015) and negative detections at Wickaninnish Beach. McCann, S. 2019. In litteris. Email correspondence between Dr. McCann, Scientific Researcher, Department of Biological Sciences, Simon Fraser University, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding positive detections for the sand verbena moth at Island View Beach/Cordova Spit in 2016 and 2017. McClaren, E. 2018. In litteris. Email correspondence between E. McClaren, Conservation Specialist, West Coast Region, Vancouver Island, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding current and ongoing threats to the sand verbena moth at Sandy Island, Canada. Milner, R. 2018. In litteris. Email correspondence between R. Milner, District Wildlife Biologist for San Juan County, Washington Department of Fish and Wildlife, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding species of bats known to co-occur with the sand verbena moth in Washington. Miskelly, J.W. 2018. In litteris. Email correspondence between J. Miskelly, Canadian citizen and naturalist, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding his personal detection of the sand verbena moth at American Camp in June of 2006. Page, N.A. 2018. In litteris. Email correspondence between N. Page, Proprietor of and Biologist for Raincoast Applied Ecology, and Karen Reagan, Endangered Species Biologist, United

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States Fish and Wildlife Service, regarding previous work on the sand verbena moth (Copablepharon fuscum). Page, N.A. 2019a. In litteris. Email correspondence between N. Page, Proprietor of and Biologist for Raincoast Applied Ecology, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding detection of the sand verbena moth in an upland area on James Island. Page, N.A. 2019b. In litteris. Peer review comments received from N. Page, Proprietor of and Biologist for Raincoast Applied Ecology, on the draft Species Status Assessment for the sand verbena moth. Potter, A. 2018a. In litteris. Email correspondence between A. Potter, Conservation Biologist and Insect Specialist, Washington Department of Fish and Wildlife, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service. Regarding the distinct appearance of the sand verbena moth. Potter, A. 2018b. In litteris. Email correspondence between A. Potter, Conservation Biologist and Insect Specialist, Washington Department of Fish and Wildlife, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service. Regarding the habitat requirements for the sand verbena moth. Potter, A. 2019. In litteris. Email correspondence between A. Potter, Conservation Biologist and Insect Specialist, Washington Department of Fish and Wildlife, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service. Regarding proposed redevelopment of the boat ramp, pier, and marine science center at Fort Worden within an area where the sand verbena moth detections occur. Radmer, Z. 2018. In litteris. Email correspondence between Zach Radmer, Fish and Wildlife Biologist, United States Fish and Wildlife Service, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service. Schmidt, B.C. 2019. In litteris. Email response from B. Christian Schmidt, Ph.D., research scientist, Agriculture and Agri-food Canada, to Rebecca Migala, Endangered Species Biologist, U. S. Fish and Wildlife Service, regarding concerns of Jim Troubridge on the taxonomy of Copablepharon fuscum that were shared via email on May 16, 2019. Tatum, J. 2018. In litteris. Email correspondence between J. Tatum, amateur lepidopterist, and Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding the availability of additional life history information or observations of the development of the sand verbena moth. Troubridge, J. 2019. In litteris. Email correspondence between J. Troubridge, species expert, and Rebecca Migala, Endangered Species Biologist, United Fish and Wildlife Service, regarding peer review comments on the sand verbena moth species status assessment.

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Vernon, S. 2018. In litteris. Email correspondence between S. Vernon, independent author and naturalist in the San Juan Islands, and Karen Reagan, Endangered Species Biologist, United Fish and Wildlife Service, regarding her observations of the sand verbena moth, the state of sand verbena moth habitat at American Camp, and the potential for conflicting habitat management actions for the sand verbena moth and the island marble butterfly since they co-occur at American Camp.

PERSONAL COMMUNICATIONS

Sollmann, L. 2018. Personal communication. Phone conversation between Lorenz Sollmann, Deputy Project Leader, Washington Maritime National Wildlife Refuge Complex, with Karen Reagan, Endangered Species Biologist, United States Fish and Wildlife Service, regarding the status of the sand verbena moth and sand verbena moth habitat at Graveyard Spit, Dungeness National Wildlife Refuge.

8.0 APPENDICES Appendix A. Additional Maps

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Appendix B. Future Conditions Site-by-Site

Narrative with Maps of Projected Sea Level Rise British Columbia, Canada Goose Spit and Sandy Island Marine Provincial Park Projections of sea level rise and annual flood risk to the north and south of Goose Spit and Sandy Island (at Campbell River and Fulford Harbor, respectively), predict 0.3 m (1 ft) of sea level rise between 2070 to 2080 for RCP 8.5, and between 2070 and 2100 for RCP 4.5. Additionally, temporal projections for a 50 percent probability of annual flood risk of over 1.8 m (5.9 ft) for the areas north and south of Goose Spit and Sandy Island are between 2060 and 2090 for RCP 8.5, and between 2060 and 2110 for RCP 4.5.

Goose Spit Abronia latifolia is currently found in three main areas on Goose Spit: one narrow strip along the shoreline on the western side, one long narrow strip along the shoreline on the eastern side, and one large backbeach area in the center of the spit (Figure 2). The two narrow strips of habitat on the eastern and western sides of the spit will be under water with as little as 0.3 m (1 ft) of sea level rise, and the majority of the larger backbeach area in the center of the spit will be almost completely inundated by flooding of 1.8 m (5.9 ft). These conditions will arise on Goose Spit between 2060 and 2100 under either climate change scenario considered (Figure 2). Sea levels may rise up to 0.9 m (3 ft), with flooding of up to 2.4 m (7.9 ft), by 2100 under RCP 8.5, but associated conditions of inundation and coastal flooding on Goose Spit will differ very little from those shown for 0.3 m (1 ft) of sea level rise and 1.8 m (5.9 ft) of flooding (Figure 2). For that reason, impacts to the sand verbena moth at Goose Spit from RCP 8.5 conditions are considered to be essentially the same as those from RCP 4.5 conditions, and will be treated as such in the analysis of future conditions.

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The habitat required by the sand verbena moth and its host plant (open beach with sparse to no vegetation) diminished at Goose Spit significantly between 1930-2004 due to encroachment by forest and shrubs. Invasive Scot’s broom cover increased at Goose Spit by a factor of more than 23 from 2005 to 2010, and dune habitat overall declined by nearly 80 percent (Page et al. 2011, p. 56). As such, it seems likely that the sand verbena moth on Goose Spit will continue to be impacted by habitat loss via invasive plant colonization and dune stabilization in the next 80 years. The loss of habitat to invasive plant species is likely to occur under the status quo scenario of invasive plant management, and may possibly occur even with increased management efforts, given that encroachment of invasive plants appears to be occurring rapidly here. Under the first and third future scenarios, an increase in habitat management would be paired with similar impacts to sand verbena moth habitat under either RCP 4.5 or RCP 8.5, respectively. With moderate cuts to greenhouse gas emissions under RCP 4.5, impacts of sea level rise and coastal flooding would still result in two of the Abronia latifolia areas being completely inundated by 0.3 – 0.9 m (2–3 ft) of sea level rise between 2070 and 2100, and the largest A. latifolia area being mostly inundated from flooding of 1.8 – 2.4 m (5.9–7.9 ft) between 2060 and 2110. Increased habitat management under these scenarios could curb invasive plant encroachment and potentially restore currently unavailable habitat contiguous with currently occupied habitat. There are only two areas of Goose Spit that will be above 1.8 – 2.4 m (7.9 ft) floods: one area of approximately 30,000 m2 (322,917 ft2) that is contiguous with currently occupied habitat on the west side of the spit; and one larger area on the eastern side of the spit that is completely developed with a military installation (Figure 2). The high area to the east is unlikely to be restored for sand verbena moth habitat due to its current use, but the area on the west side could be managed to support at least part of any displaced sand verbena moth population. Under the first and third scenarios, despite the loss of most current habitat to impacts of climate change, the sand verbena moth could potentially persist on Goose Spit into the next century. Under the second and fourth scenarios, climate change conditions under either RCP 4.5 or RCP 8.5 would lead to the same proportion of current sand verbena moth habitat being lost to impacts in the same timeframe as in the first and third scenarios (approximately 90 percent of current habitat). Habitat loss due to invasive plants without additional management under these scenarios would likely be extensive given the current rate of encroachment by invasive plants. Under these scenarios, most existing habitat would be lost to impacts of climate change, and invasive plant expansion would make it unlikely that the remaining habitat would be sufficient to support sand verbena moth into the future. Sandy Island Marine Provincial Park Approximately 50 percent of the current sand verbena moth habitat at Sandy Island will be lost to sea level rise of only 0.3 m (1 ft), and approximately 80 percent will be subjected to flooding of at least 1.8 m (5.9 ft), by 2070 – 2100 under RCP 4.5 conditions (Figure 3). Sea level rise 126

could reach 0.9 m (3 ft) and coastal flooding could surpass 2.4 m (7.9 ft) by the end of the century under RCP 8.5, in which case even more habitat would be submerged by sea level rise (approximately 75 percent, Figure 3, center), but flooding of 2.4 m (7.9 ft) would impact the same amount of habitat as flooding of 1.8 m (5.9 ft) (approximately 80 percent, Figure 3, right). As such, the overall proportion of current sand verbena moth habitat at Sandy Island impacted by effects of climate change by 2100 is virtually the same with RCP 8.5 as it is with RCP 4.5, and so all future scenarios considered here are similar in regard to climate change.

0.3 m 0.6 – 0.9 m 1.8 – 2.4

Figure 3. Sea level rise projection of 0.3 m (1 ft) (left) and 0.6 – 0.9 m (2–3 ft) (middle), and a 1.8 – 2.4 m (5.9–7.9 ft) coastal flood projection (right) at Sandy Island Marine Provincial Park. The approximate extent of sand verbena moth

We did not receive information about current habitat management practices for the sand verbena moth at Sandy Island. The Park’s Master Plan, published in 1987 before the sand verbena moth was listed, does not acknowledge the presence of the sand verbena moth or any management associated with its presence at the Park (B.C. Parks 1987, p. 34). We have no information regarding invasive plant species as a risk factor for the sand verbena moth at Sandy Island, and cannot project how the continuation of current management would affect sand verbena moths in the future scenarios. However, an increase in habitat management could potentially result in some high-lying areas on the island being restored to a condition that could support the sand verbena moth. High-lying areas on the eastern side of the island that are contiguous with current sand verbena moth habitat are not currently forested and would not be submerged by 1.8 m (5.9 ft) floods and could potentially support sand verbena moths in the future if properly managed (Figure 3). Under the first and third scenarios, approximately 80 percent of what is currently available as sand verbena moth habitat would be lost to a combination of sea level rise and coastal floods by the end of the century and as early as 2060–2070. However, increased habitat management in high-lying areas could mitigate for at least some of the habitat lost to climate change, allowing for a fair chance of the sand verbena moth persisting at this site into the next century under the first and third scenarios. Under the second and fourth scenarios, at least 80 percent of the current sand verbena moth habitat would be lost impacts of climate change by 2100 and as early as 2060 – 2070. In

127 addition, without increased habitat management, even more habitat could potentially be lost due to encroachment by invasive plants. While we don’t have information regarding the impact of invasive plants at Sandy Island, we know that Abronia latifolia habitat has been rapidly disappearing on neighboring Goose Spit, which is only approximately 6 km (3.7 mi) to the north, due to encroachment by Scot’s broom, forest, and shrubs (Page et al. 2011, p. 56). Therefore it is reasonable to assume that there may be at least some degree of sand verbena moth habitat loss occurring for similar reasons on Sandy Islands well. In summary, we know that at least 80 percent of the existing sand verbena moth habitat will be lost due to climate change, and likely even more due to habitat encroachment, and therefore it seems unlikely that the sand verbena moth will persist at Sandy Island into the future under the second and fourth scenarios. Island View Beach and Cordova Spit Located just southwest of James Island, Island View Beach and Cordova Spit have the same sea level rise and coastal flood temporal projections that James Island has, because they are based on those of nearby locations Patricia Bay (to the north) and Victoria (to the south). Sea level rise at these sites will reach 0.3 m (1 ft) by 2070, with 50 percent chance of annual flooding that could reach 1.8 m (5.9 ft) by 2060, under either the RCP 4.5 or RCP 8.5 greenhouse gas emissions scenarios. By the end of the century, sea levels will have risen by 0.6 m (RCP 4.5) to 1.2 m (3.9 ft) (RCP 8.5), and will be accompanied by 50 percent chance of annual flooding that could reach 2.4 m (7.9 ft) (RCP 4.5) to 2.7 m (8.9 ft) (RCP 8.5). Regardless of greenhouse gas emissions scenario, by 2100, three of the four sand verbena moth habitat locations on Island View Beach/Cordova Spit will be inundated by either sea level rise or by coastal flooding (Figure 5, right).

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0.3 – 0.6 1.2 – 1.8 2.1 – 2.7

Figure 5. Sea level rise and annual flood projections of 0.3 to 0.6 m (left), 1.2 to 1.8 m (5.9 ft) (center), and 2.1 to 2.7 m (6.9–8.9 ft) (right), at Island View Beach and Cordova Spit. The approximate extents of sand verbena moth habitat are

We received data indicating the locations of Abronia latifolia patches at this site (Figure 5), as well and moth light trap data from 2002–2003. While light traps were placed in A. latifolia patches on both the eastern and western sides of the spit, as well as at the patch at the southernmost part of the site, sand verbena moths were only captured in the A. latifolia patch on the western side of the spit. We did not receive information regarding current management practices for sand verbena moth habitat at this site. However, the draft management plan for Island View Beach Regional Park (Capital Regional Parks 2017) states that ecological restoration and targeted management of invasive species will be a focus of environmental management at the Park (p.15), and that priority areas for restoration are based on Critical Habitat of species at risk such as the sand verbena moth (p. 30). Therefore we assume that invasive plants could be a risk factor of sand verbena moth at this site, and there may be management currently underway to control them. Under the first, best-case scenario, with moderate cuts to greenhouse gas emissions, sea level rise of 0.3 m (1 ft) by 2070 will inundate the entirety of the sand verbena moth habitat patch on the western side of the spit, the only habitat patch where sand verbena moth was detected, and all but a small part of the southernmost patch of sand verbena moth habitat (Figure 5, left). However, 50 percent chance of annual flooding that could reach 1.8 m (5.9 ft) will completely inundate the southernmost habitat patch by 2060 (Figure 5, center). By 2100 under this scenario, 50 percent chance of annual flooding that could reach 2.4 m (7.9 ft) will inundate all but one currently-existing patch of sand verbena moth habitat, located at Island View Beach (Figure 5, right). With an increase in management, it is possible that the remaining patch of habitat may be able to support the sand verbena moth into the future, although there is no

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evidence that this habitat patch currently supports moths. Therefore it is reasonable to predict that the sand verbena moth could persist at Island View Beach under the first scenario. Under the second scenario, climate change would result in the same amount of habitat loss for the sand verbena moth. Further, without an increase in habitat management it is likely that additional habitat would be lost or compromised due to encroachment by invasive plant species. Under these circumstances, we expect the sand verbena moth’s chance of persisting at this site to be poor. Under the third and fourth scenarios, sea levels would rise up to 1.2 m (3.9 ft) by the end of the century (Figure 5, center) and coastal flooding of 2.7 m (8.9 ft) would further inundate the edges of the remaining patch of sand verbena moth habitat (Figure 5, right). We suspect that regardless of habitat management efforts, given the extent of sea level rise isolating this remaining patch of habitat coupled with its close proximity to flood waters, it is unlikely to sustain a Abronia latifolia patch robust enough to support a sand verbena moth population into the future. Therefore, we do not expect the sand verbena moth to persist at Island View Beach into the future under the third or fourth scenarios.

James Island

0.3 – 0.6 1.2 – 1.8

Figure 4. Sea level rise of 0.3 – 0.6 m (1–2 ft) (left) and 1.2 – 1.8 m (5.9 ft) on James Island. Orange stars indicate the approximate locations of the three known sand verbena moth populations. Based on temporal projections from nearby locations Patricia Bay (to the north) and Victoria (to the south), sea level rise at James Island will reach 0.3 m (1 ft) by 2070, with 50 percent chance of annual flooding that could reach 1.8 m (5.9 ft) by 2060, under either the RCP 4.5 or RCP 8.5 greenhouse gas emissions scenarios. By the end of the century, sea levels will have risen by 0.6

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m (RCP 4.5) to 1.2 m (3.9 ft) (RCP 8.5), and will be accompanied by 50 percent chance of annual flooding that could reach 2.4 m (7.9 ft) (RCP 4.5) to 2.7 m (8.9 ft) (RCP 8.5). We are aware of two sand verbena moth detection locations on James Island where habitat exists and one upland detection that is not associated with habitat: one on Village Spit on the north side of the island, one on Powder Jetty Spit on the east side of the island, and one located on the interior of the east side of the island (NCC Land Information System Database, 2018) (Figure 4). The Village Spit and the Powder Jetty Spit detections are currently located on land that will be completely inundated by 0.3 m (1 ft) of sea level rise expected by 2070 under either RCP 4.5 or RCP 8.5 (Figure 4, left). In addition, the 50 percent chance of annual flooding that could reach 1.8 m (5.9 ft) expected by 2060 under either climate change scenario will further inundate the habitat in the surrounding areas of these sites, making the potential for sand verbena moths to retreat into contiguous, currently unoccupied areas, much less likely (Figure 4, right). Therefore efforts to manage habitat for invasive species at Powder Jetty Spit and Village Spit are unlikey to be effective in sustaining the sand verbena moth at these sites, given that most of the habitat with the potential for restoration in the surrounding area will be lost to the impacts of climate change along with the currently occupied habitat. As such, we do not expect populations of sand verbena moth to persist at Powder Jetty Spit or Village Spit beyond 2070 in any of the future scenarios. Wickaninnish Beach The beach at Wickaninnish supports a well-developed foredune and a small, stabilizing dune complex with an accumulation of large woody debris toward the backshore. The foredune is also stabilized by communities of dune wildrye and American and European beachgrass, which provide a buffer between the wind and wave energy of the shoreline and the beach behind the foredune. The patch of sand verbena where the sand verbena moth was found at Wickaninnish Beach is located in an active dune system set back behind the foredune and small incipient dunes on the ocean-facing side. Because the site location lies behind the partially-stabilized foredune, it is presumably sheltered to a degree from wave energy, storm surge, and sea level rise. Even under the most extreme scenario of greenhouse gas emissions modeled by the IPCC, RCP 8.5, sea level rise projections don’t appear to inundate the location of the sand verbena moth capture at Wickaninnish in the next 80 years. Rather, it appears that a one m rise in sea level (predicted by 2100 under RCP 8.5) may begin to inundate the area that currently supports the foredune and possibly part of the stabilizing dune. However, the sand verbena population behind this complex would likely be sheltered from the destructive shoreline impacts caused by this degree of sea level rise (Figure 1). Under the best-case scenario, active management of invasive plants in sand verbena moth habitat would also increase. Currently, Parks Canada conducts restoration work focusing on the manual removal of invasive beachgrass from the foredune ridge, and removal of spruce tree

131 islands that form in the lee of the foredune ridge, in order to increase the movement of sand into the dune complex (Beaugrand 2007, p. 22; Heathfield and Walker 2011, p. 1196). Wickaninnish supports a large and healthy population of Abronia latifolia (Page et al. 2011, p. 57). It is therefore likely that the continued management of invasive plants assumed in scenarios two and four would be adequate to sustain this population of sand verbena moth that currently exists at Wickaninnish. Furthermore, bolstering management efforts (as assumed in the first and third scenarios) could create additional habitat by opening up areas of the backdune that are currently stabilized by invasive beachgrass or tree islands that inhibit sand movement required to maintain an active dune.

It should be noted that some authors have noted the potential for increases in erosion at Wickaninnish Beach due to shifts in climatic variables such as El Niño/La Niña and the Pacific Decadal Oscillation (Heathfield and Walker 2011, p. 1188). While others suggest that the foredunes at Wickaninnish Beach will buffer the shoreline against flooding due to storm surge and gradual sea level rise (Page et al. 2011, p. 12). Still another author noted that an earthquake of significant magnitude would

Figure 1. Sea level rise projection of 1 m (3.3 ft) at Wickaninnish Beach. The result in rapid regional orange star indicates the approximate location of the sand verbena moth subsidence and shoreline retreat capture. Sea level rise is expected to reach 1 m (3.3 ft) by 2100 under RCP (Beaugrand 2007, p. 11). But as 8.5. Lesser degrees of sea level rise than those shown here can be expected before 2100 under both RCP 8.5 and 4.5. previously described, these potential risk factors are unpredictable and therefore not included in our future conditions analysis. As such, based on predictions of sea level rise and invasive plant management under any of the four scenarios, it appears that the habitat for sand verbena moth at Wickaninnish will persist. Washington, United States American Camp/Cattle Point Based on climate change projections for Friday Harbor (to the north) and Port Townsend (to the south), American Camp and Cattle Point will experience sea level rise of 0.3 m (1 ft) by 2070 132

and 0.6 m by 2090 under RCP 4.5. There will also be a 50 percent probability of 1.8 m (5.9 ft) floods between 2050 to 2070, 2.1 m (6.9 ft) floods between 2080 and 2090, and 2.4 m (7.9 ft) floods between 2100 and 2110. Under greenhouse gas emissions scenario 8.5, American Camp and Cattle Point will undergo sea level rise of 0.3 m (1 ft) by 2060, 0.6 m by 2080, 0.9 m (3 ft) by 2090, and 1.2 m (3.9 ft) by 2100. The site will also be exposed to flooding of over 1.8 m (5.9 ft) between 2050 to 2060, 2.1 m (6.9 ft) floods between 2070 and 2080, 2.4 m (7.9 ft) floods from 2080 to 2090, and 2.7 m (8.9 ft) floods by 2100.

American Camp

0.3 0.6

1.8 2.7

Figure 6. Sea level rise of 0.3 m (1 ft) (upper left), 0.6 m (2 ft) (upper right), 1.8 m (5.9 ft) (lower left), and 2.7 m (8.9 ft) (lower right), and approximate location of sand verbena moth habitat (outlined in red) at American

Sand verbena moth habitat at American Camp spans a wide range of elevation, with habitat starting just above the wrack line at about 4 m (13.1 ft) elevation, and rising into a dune system up to 40–50 m (131–164 ft) above sea level (Fleckenstein et al. 2018b, p. 17). A significant proportion of the area occupied by the sand verbena moth at American Camp is located in the 133

dune system at higher elevations, and thus will be relatively immune to the impacts of sea level rise and coastal flooding projected into the next century. Even under the status quo scenario of greenhouse gas emissions (RCP 8.5) in which sea level in the area will rise up to 1.2 m (3.9 ft) and flooding will reach 2.7 m (8.9 ft), only about a quarter or less of the habitat currently occupied by the moth would be affected (Figure 6). While adult sand verbena moths have been found throughout this site, larvae have only been found using the elevated portion of the site (Fleckenstein et al. 2018b, p. 17). This could indicate that the low-lying areas are unsuitable for larval development and survival, and may act as an ecological trap, attracting adults to deposit their eggs but not supporting the survival of the offspring. Fleckenstein et al. (2018b) and Vernon (2018, entire) noted that cheat grasses (Bromus spp.) and Canada thistle (Cirsium arvense) (p. 17) are invading the American Camp site, and are competing with Abronia latifolia by stabilizing the dunes and may interfere with the use of the host plant by the sand verbena moth (p. 15). They also noted that management for invasive plants is complicated at American Camp due to the co-occurrence of the island marble butterfly (Euchloe ausonides insulanus). However, the available habitat for the sand verbena moth at American Camp is more than double that available at any other known population site in Washington (Fleckenstein et al. 2018b, p. 9). Therefore, it is reasonable to expect that even with no increase in invasive species management at this site, and inundation from sea level rise and coastal flooding being limited to a small portion of the site, that the sand verbena moth has a fair chance of persisting here into the next century. Cattle Point The sand verbena moth habitat at Cattle Point is located directly along the edge of a shoreline bluff that currently stands approximately 40 m (131 ft) high, but is constantly under threat of erosion (Fleckenstein et al. 2018b, pp. 18-19). Given its location at high elevation, the current location of the sand verbena moth population is removed from the projected impacts of sea level rise and annual flooding that are expected under either greenhouse gas emissions scenario in the next century (Figure 7). However, though we cannot reasonably predict how the climate change factors (e.g., increase in frequency and magnitude of storm surge events) will impact the sand verbena moth populations, it is possible that a considerable proportion of the population at Cattle Point could be lost to erosion due to the combination of rising seas and powerful storms.

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Figure 7. Current coastline (left), and annual flooding of 2.7 m (8.9 ft) (right) at Cattle Point. The approximate location of the sand verbena moth population is outlined in red.

As with American Camp, invasive grasses (Bromus spp.) dominate this site and are competing with A. latifolia, negatively impacting its abundance and ability to flower (Fleckenstein et al. 2018b, p. 19), and in turn may be having impacts on the sand verbena moth here. Although the current extent of sand verbena moth habitat at Cattle Point covers much less area than at American Camp (0.6 ha compared with 23 ha, respectively) (1.5 ac and 57 ac, respectively), the surrounding area is mostly undeveloped and could likely support more suitable habitat if managed properly (Figure 8).

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We suspect that with an increase in management for invasive species, the sand verbena moth population is likely to persist into the next century, regardless of emissions scenarios (in the first and third scenario). With no change from current levels of invasive species management, at least some portion of the currently occupied sand verbena moth habitat would likely be lost to takeover by invasive grasses into the future. However, it still seems reasonable to predict, due to its elevation and relative removal from the impacts of sea level rise and coastal flooding, that the sand verbena moth population could persist into the next century under the second and fourth scenarios.

Figure 8. Approximate location (outlined in white) of the sand verbena moth population at Cattle Point.

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Deception Pass and Rocky Point Deception Pass and Rocky Point are located in close proximity on Whidbey Island, and therefore temporal projections of sea level rise and flooding events are based on the same nearby locations at Friday Harbor to the north and Port Townsend to the south. Under RCP 4.5 Deception Pass and Rocky Point will experience 0.3 m (1 ft) of sea level rise by 2070, and 0.6 m by 2090. In addition, there will be a 50 percent annual probability of flooding of 1.8 m (5.9 ft) by 2050 to 2070, 2.1 m (6.9 ft) floods by 2080 to 2090, and 2.4 m (7.9 ft) floods by 2100 to 2110. Under RCP 8.5, sea level at Deception Pass and Rocky Point will rise by 0.3 m (1 ft) by 2060, 0.6 m by 2080, 0.9 m (3 ft) by 2090, and 1.2 m (3.9 ft) by 2100; and there will be a 50 percent annual probability of 1.8 m (5.9 ft) by 2050 to 2060, 2.1 m (6.9 ft) by 2070 to 2080, 2.4 m (7.9 ft) by 2080-2090, and 2.7 m (8.9 ft) by 2100. Deception Pass Under the first scenario, with moderate cuts to greenhouse gas emissions (RCP 4.5) and habitat management efforts, the sand verbena moth would lose about half of its current suitable habitat to a 0.3 m (1 ft) rise in sea level by 2070 (Figure 9, top right), and just slightly more than that with a 0.6 m rise in sea level by 2090 (Figure 9, middle left). A 50 percent probability of 1.8 m (5.9 ft) floods in this area would also mean that by 2070 all but small fragments of the moth’s current suitable habitat would be inundated by flooding, making it unsuitable for the saltwater- intolerant Abronia latifolia, and therefore also the moth (Figure 9, bottom right). Fleckenstein et al. (2018b, p. 23) anecdotally noted that the patch size of Abronia latifolia appeared reduced when surveyed in 2017 compared to surveys done in 2012, and that invasive grasses, especially Ammophila arenaria, appeared to be encroaching on A. latifolia habitat at this site. Fleckenstein et al. also noted that backdune habitat at the southern end of the site could potentially be restored and used in the future by the sand verbena moth (Fleckenstein et al. 2018b, p. 24). Some of this habitat would be susceptible to annual flooding by 2070, as described above. However, high-lying habitat in the backshore area that is currently unoccupied by A. latifolia, and would be above predicted annual flood levels, could potentially be restored for sand verbena moth habitat (Figure 10). Under this scenario, it is reasonable to predict that the sand verbena moth at Deception Pass could persist due to creation of new suitable habitat via increased habitat management to replace current suitable habitat lost to sea level rise and annual flooding. Under the second scenario, the same amount of habitat would be lost to sea level rise as in the first scenario, but no new habitat would be created by habitat management efforts. As was noted by Fleckenstein et al. (2018b, p. 23), invasive grasses would continue to encroach on the Abronia latifolia, resulting in additional habitat loss. Under this scenario, only small fragments at the south end of the site would remain free of inundation caused by sea level rise or flooding (Figure 9, lower left), and some of that remaining habitat would likely be lost to invasive grass takeover. Currently, there is only a total of 548 m2 (5899 ft2) of A. latifolia at the Deception

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Pass site (Fleckenstein et al. 2018b, p. 24), which is just slightly more than the 400 m2 (4306 ft2) patch size thought to be required to support the sand verbena moth (COSEWIC 2003, p. 10-11; Fleckenstein 2018b, p. 9). Therefore, it is very unlikely that the sand verbena moth would persist at this site under this future scenario.

0 0.3

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1.8 2.7 Figure 9. Current coastline (upper left), and sea level rise of 0.3 m (1 ft) (upper right), 0.6 m (2 ft) (middle left), 1.2 m (3.9 ft) (middle right), 1.8 m (5.9 ft) (lower left), and 2.7 m (8.9 ft) (lower right), and approximate location of sand verbena moth habitat (outlined in red) at Deception

Under the third scenario, sea level expected to result from RCP 8.5 would rise by 1.2 m (3.9 ft) by 2100, inundating over half of the current suitable habitat (Figure 9, middle right). The annual risk of 2.7 m (8.9 ft) floods would make all of the current suitable habitat, plus most of

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the backshore habitat that could have been restored by increased habitat management under this and the first scenario, unsuitable due to regular exposure to salt water (Figure 9, lower right). The only backshore habitat, outside the perimeter of the currently suitable habitat at this site, that would be above 2.7 m (8.9 ft) floods and could be restored exists in small fragments that are considerably smaller than the minimum Abronia latifolia patch size known to support the sand verbena moth (COSEWIC 2003, p. 10- 11; Fleckenstein et al. 2018b, p. 9). Therefore, despite efforts to increase habitat management at this site, the sand verbena moth would not persist under this future scenario due to habitat lost by effects of climate change. Similarly, under the fourth scenario which assumes sea level rise and flooding associated with RCP 8.5 but without a change in habitat management, the sand verbena moth is unlikely to persist due Figure 10. Orthophotograph of Deception Pass State Park with approximate location of current sand verbena moth habitat outlined in white. The red line indicates a distance of to habitat loss. approximately 100 m (328 ft) from the shoreline. Sandy areas to the east of the current suitable habitat, within 100 m (328 ft) of the shoreline, could be restored to create additional suitable habitat for the sand verbena moth.

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0 m 0.3 m

0.9 m 1.2 m

1.5 m 1.8 m

Figure 11. Current coastline (upper left), and sea level rise of 0.3 m (1 ft) (upper right), 0.9 m (3 ft) (middle left), 1.2 m (3.9 ft) (middle right), 1.5 m (4.9 ft) (lower left), and 1.8 m (5.9 ft) (lower right), and approximate location of sand verbena moth habitat (outlined in red) at Rocky Point. 140

Rocky Point Under the first scenario, the northern and southern extents of the current sand verbena moth habitat at Rocky Point would be lost to 0.3 m (1 ft) of sea level rise by 2060 (Figure 11, upper right), and accompanying 50 percent chance of annual flooding that could be over 1.8 m (5.9 ft) would cover the entire area currently supporting the sand verbena moth population at Rocky Point (Figure 11, lower right). Sea levels would rise to 0.6 m and flooding to 2.4 m (7.9 ft) by the end of the century, but even by 2060 all of the current habitat would be lost under RCP 4.5, assuming A. latifolia could not Figure 12. Orthophotograph of Rocky Point with approximate location of tolerate being inundated every current sand verbena moth habitat outlined in white. The red line indicates a distance of approximately 100 m (328 ft) from the shoreline. other year, on average, by floods. This scenario also includes an increase in habitat management for the moth. However, backshore habitat suitable for restoration to support the sand verbena moth (i.e., that which is contiguous with current habitat and within about 100 m (328 ft) of the shoreline) would also be inundated by 1.8 m (5.9 ft) floods, except for the backshore area at the northern end of the site, which is already developed (Figure 12). Given the predicted impact of climate change on current sand verbena moth habitat, as well as on contiguous habitat with the potential for restoration, it is unlikely that sand verbena moth would persist at Rocky Point under the first scenario beyond approximately 2060. The remaining scenarios involve less habitat management efforts and/or increased greenhouse gas emissions that result in higher sea level rise and annual floods in a shorter timeframe. These scenarios would only bode worse for the sand verbena moth at Rocky Point. As such, even under the best-case scenario as well as all other future scenarios considered here, it is unlikely the sand verbena moth at Rocky Point will persist. Graveyard Spit and Kulakala Point Based on projections for nearby Port Angeles, Graveyard Spit and Kulakala Point are likely to experience sea level rise of 0.3 m (1 ft) by 2080 and 0.6 m by 2100 under the best-case greenhouse gas emissions scenario (RCP 4.5). Under the worst-case greenhouse gas emissions 141

scenario (RCP 8.5), this area will see sea level rise of 0.3 m (1 ft) by 2070, 0.6 m by 2080, 0.9 m (3 ft) by 2090, and 1.2 m (3.9 ft) by 2100. There will be a 50 percent annual probability of flooding of over 1.8 m (5.9 ft) by 2070, and 2.1 m (6.9 ft) by 2090, under a scenario of moderate cuts to emissions (RCP 4.5). Under a scenario of unchecked pollution, there will be a 50 percent probability of flooding of over 1.8 m (5.9 ft) by 2060, 2.1 m (6.9 ft) by 2080, 2.4 m (7.9 ft) by 2090, and 2.7 m (8.9 ft) by 2100. Graveyard Spit

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Figure 13. Current coastline (left), and sea level rise of 0.3 m (1 ft) (middle) and 0.6 m (2 ft) (right) at Graveyard Spit. The red circle indicates the approximate location of the sand verbena moth population. Under the best-case scenario of greenhouse gas emissions (RCP 4.5), the current location of the sand verbena moth population at Graveyard Spit is likely to be largely unaffected by 0.3 m (1 ft) of sea level rise (expected by 2080), and is unlikely be inundated but may be negatively impacted by 0.6 m (2 ft) of sea level rise (expected by 2100) (Figure 13). However, the 50 percent annual probability of 1.8 m (5.9 ft) floods that are expected by 2070 under moderate cuts to emissions (RCP 4.5) are expected to all but completely inundate Graveyard Spit (Figure 14), making it very unlikely that the sand verbena moth or its host plant would persist. As such, despite management efforts to maintain or increase sand verbena moth habitat by invasive plant removal, sea level rise coupled with annual flood risk make it unlikely that the sand verbena moth will persist at Graveyard Spit under any of the future scenarios considered here.

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0 m 0.3 m

0.6 m 0.9 m

1.2 m 1.8 m Figure 14. Current coastline (top left); and sea level rise of 0.3 m (1 ft) (top right), 0.6 m (2 ft) (middle left), 0.9 m (3 ft) (middle right), 1.2 m (3.9 ft) (bottom left), and 1.8 m (5.9 ft) (bottom right), at Graveyard Spit (to north) and Kulakala Point

(to south). Red circles indicate the approximate locations of the sand verbena moth populations.

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Kulakala Point Although we don’t know the exact location of the sand verbena moth detection at Kulakala Point, it is evident from the orthophotograph that the only suitable habitat at the site would be either immediately along the shoreline, or in the sandy area between the shoreline and the marsh (Figure 15). Therefore, the rise in sea level of 0.3 to 0.6 m that is expected by 2100 under the best-case scenario for greenhouse gas emissions (RCP 4.5) may inundate the sand verbena moth habitat if it is Figure 15. The only two potential locations with suitable habitat for the sand verbena moth population at Kulakala Point are immediately along the located immediately along the shoreline, or in the backshore area between the shoreline and the marsh shoreline at Kulakala Point. (indicated by orange star). Alternatively, if population at is located in the sandy area between the shoreline and the marsh, a rise in sea level of 0.3 m (1 ft) to 0.6 m may fail to inundate, but negatively impact the population (Figure 16, upper left and right). Regardless, sea level rise of 1.2 m (3.9 ft) expected by the end of the century under RCP 8.5, and flooding of over 1.8 m (5.9 ft) expected between 2060 (RCP 8.5) and 2070 (RCP 4.5), will cover nearly the entirety of Kulakala Point (Figure 16, lower right). Therefore, even under the lowest emissions scenario (RCP 4.5), it seems unlikely the sand verbena moth could survive the combination of potential sea level rise and predicted annual flooding at Kulakala Point beyond 2060. Despite the maintained or increased management of invasive plant species at this site, even the lowest magnitude of projected effects of climate change make it unlikely that the sand verbena moth could persist at Kulakala Point in any of the future scenarios considered here.

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Figure 16. Sea level rise of 0.3 m (1 ft) (upper left), 0.6 m (2 ft) (upper right), 1.2 m (3.9 ft) (lower left), and 1.8 m (5.9 ft) (lower right) at approximate location (orange star) of sand verbena moth population at Kulakala Point.

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Fort Worden The sand verbena moth habitat at Fort Worden State Park is located immediately along the coastline on the southern side of the point, and in the sandy backshore habitat that comprises about half of the interior of the site on the southern side of the point (Figure 17). Climate change projections from neighboring Port Townsend indicate that under the best-case emissions scenario (RCP 4.5), Fort Worden will experience a rise in sea level of 0.3 m (1 ft) with a 50 Figure 17. Orthophotograph of the Fort Worden State Park site with sand verbena percent annual probability moth habitat outlined in white. of 1.8 m (5.9 ft) flooding by 2070, and a rise in sea level of 0.6 m with a 50 percent annual probability of 2.1 m (6.9 ft) floods by 2090. Under a worst-case greenhouse gas emissions scenario (RCP 8.5), Fort Worden would undergo sea level rise of 0.3 m (1 ft) by 2060, 0.6 m by 2080, 0.9 m (3 ft) by 2090, and 1.2 m (3.9 ft) by 2100. Under the RCP 8.5 scenario, Fort Worden would also have a 50 percent annual probability of floods of 1.8 m (5.9 ft) by 2060, 2.1 m (6.9 ft) by 2080, 2.4 m (7.9 ft) by 2090, and 2.7 m (8.9 ft) by 2100. Even under the best-case emissions scenario, 0.3 m (1 ft) of sea level rise at Fort Worden would inundate the shoreline on most of the southern part of the point by 2070, making it unlikely that sand verbena existing right along the coastline would persist. In addition, a 50 percent annual probability of 1.8 m (5.9 ft) floods would mean that most of the suitable habitat in the sandy backshore area in the southern half of the site would be inundated by 2070 under RCP 4.5 (Figure 18). Sea level rise and flooding would increase under this scenario to 0.6 m and 2.1 m (6.9 ft), respectively, by 2100.

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1.8 2.7 Figure 18. Sea level rise of 0.3 m (1 ft) (top left), 1.2 m (top right), 1.8 m (5.9 ft) (bottom left), and 2.7 m (8.9 ft) (bottom right) at Fort Worden State Park, with sand verbena moth habitat outlined in red. Under the worst-case scenario of greenhouse gas emissions (RCP 8.5), Fort Worden would experience the 0.3 m (1 ft) of sea level rise and 1.8 m (5.9 ft) floods even earlier, by 2060, and would undergo a sea level rise of 1.2 m (3.9 ft) with a 50 percent annual probability of 2.7 m (8.9 ft) floods by 2100. Under this scenario by 2100 all but fragments of the coastline and at least a third of the sandy backshore habitat would be inundated by sea level rise alone, and flooding would leave only the narrow strip of suitable habitat located along the paved road in the backshore area above water. Under the first, best-case scenario, there would be moderate cuts to greenhouse gas emissions and invasive plant management would increase. In this scenario, we would see over half of the existing sand verbena moth habitat lost to sea level rise and coastal flooding. However, narrow

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corridors of habitat may still exist along the paved road in the backshore sandy area, and between the coastline and flooded middle section of the backshore sandy area, that would not be impacted by either sea level rise or annual flooding (Figure 18, bottom left). This area is large enough (> 400 m2) (4306 ft2) that a healthy and flowering sand verbena patch here could support a sand verbena moth population. It is possible that annual flooding in close proximity to this remaining habitat could compromise the host plant (e.g., by increased salinity in the water table), but we cannot reasonably predict this outcome, and according to sea level projections alone it appears that some habitat would remain in suitable condition. Increased invasive plant management under the first scenario could mean that additional sand verbena moth habitat is created on the north side of the spit (where currently there are no sand verbena patches) in the area not yet inundated or at 50 percent risk of annual flooding under RCP 4.5. In this scenario it is a reasonable prediction that even with a substantial portion of the existing habitat lost to sea level rise and annual flooding, an increase in habitat management efforts could help the sand verbena moth to persist through 2100 at Fort Worden State Park. Under the second scenario, with no change in habitat management and moderate cuts to greenhouse gas emissions, only a fraction of the existing habitat would be left unaffected by sea level rise or annual flooding. Invasive plants, especially grasses, are currently encroaching on sand verbena in some areas at Fort Worden (Fleckenstein et al. 2018b), meaning that without additional habitat management some existing habitat may also be lost to invasive grass takeover in the future. The sand verbena moth at Fort Worden may persist in the second future scenario. The third scenario assumes greenhouse gas emissions consistent with RCP 8.5, which would expose almost all of the existing suitable habitat to inundation or flooding by 2100, thereby making it unsuitable for Abronia latifolia and the moth. Only a narrow strip of suitable habitat along the paved road in the backshore area would remain (Figure 18, bottom right). However, this remaining habitat is large enough (at least 8,000 m 2 or 86,111 ft2) that it could support the sand verbena moth, assuming the A. latifolia was viable despite its close proximity to permanently and perennially flooded areas. Further, because this scenario also assumes an increase in habitat management for sand verbena moth, it is possible that additional habitat could be restored north of the paved road into which the moth could expand. In this scenario the sand verbena moth at Fort Worden could persist through the rest of the century. In the fourth scenario only a narrow strip of existing habitat would remain above predicted sea level rise and coastal flooding, as with the third scenario. However, without an increase in habitat management, no additional habitat would be created, and invasive plants could potentially threaten the existing habitat that remains. Given these pressures, it seems unlikely the sand verbena moth would persist at Fort Worden under the fourth scenario.

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