monarch-esa-petition-final_61585

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concern given recent dramatic population declines and shrinking availability of both winter and summer habitat. The high rates of mortality of monarch eggs, caterpillars, and adults from disease and predation underscore the importance to the long-term survival of the species of having a very large population size, and magnify the threat posed to the long-term survival of the species by recent dramatic population declines. Factor Three: Overutilization for Commercial, Recreational, Scientific, or Educational Purposes Overutilization poses a significant potential threat to monarchs especially in light of recent dramatic population declines and in conjunction with the many other threats facing monarchs. Millions of monarchs are raised in captivity and sold commercially for primarily educational and entertainment purposes. Capture, sale, transport, and release of monarchs can threaten the wellbeing of wild monarch populations in several ways including disease transmission, loss of genetic diversity, and accumulation of deleterious genetic adaptations, especially when rearing and release is conducted without following careful protocols. Release of captive butterflies can also interfere with studies of the distribution and movement of wild butterflies which are increasingly important in light of habitat loss and climate change. Harvesting wild monarchs also has the potential to exacerbate population decline. In addition, viewing aggregations of wintering monarchs in Mexico and California is a popular tourist activity, and some of these activities may harm wild monarch populations if conducted improperly. Petitioners recognize the valuable roles that scientific research, citizen monitoring, and classroom and at-home rearing of monarchs can play in monarch conservation and hence request that upon listing, the Service facilitate or waive permitting requirements for such activities that are beneficial to monarch conservation. See Appendix B of this petition for requested rules to facilitate monarch butterfly conservation, science, citizen monitoring, and education. Factor Four: The Inadequacy of Existing Regulatory Mechanisms Though numerous voluntary efforts are in place that benefit monarch conservation, there are no existing regulatory mechanisms which adequately address the multitude of complex and synergistic threats that are driving the monarch’s precipitous decline. Some programs are in place at the international, federal, state, and local levels that benefit monarchs, but due to the butterfly’s rapid and severe decline and the significant, ongoing threats to its survival, the monarch needs the comprehensive protection that only the ESA can provide to ensure its persistence and recovery. Factor Five: Other Natural or Manmade Factors Affecting the Monarch’s Continued Existence The monarch is threatened by several other factors including global climate change, severe weather events, pesticides, and the spread of invasive species. Unfavorable weather conditions have been identified as a primary factor contributing to the recent drastic declines in monarch populations. Weather that is too hot or too cold at critical times in monarch development can cause massive mortality of caterpillars and adults. A single winter storm event in Mexican Monarch ESA Petition 10
overwintering habitat in 2002 killed an estimated 450-500 million monarchs. This high death toll from a single storm event is particularly staggering given that the entire monarch population now numbers only about 35 million butterflies. Because of their narrow thermal tolerance and specific microhabitat requirements, climate change threatens monarchs in their summer and winter ranges. The threat from climate change in the monarch’s overwintering habitat in Mexico is so dire that monarchs may no longer occur in the Monarch Butterfly Biosphere Reserve by the end of the century due to climatic changes. The monarch’s summer breeding habitat in the United States is also predicted to become too hot in many areas for monarch’s to be able to successfully reproduce. Pesticides are widely used in the United States, with more than one billion pounds applied each year, including in the core of the monarch’s breeding range where they threaten all monarch life stages. In particular, monarchs are threatened by pesticides used in agriculture, in lawns and gardens, and for mosquito and grasshopper control. Monarchs are threatened by habitat loss due to increasing use of glyphosate and other herbicides that kill host and nectar plants, and also by lethal and sub-lethal effects of insecticides such as neonicotinoids, which are persistent in the environment and are known to be highly toxic to pollinators. Monarchs are also threatened by the spread of invasive tropical milkweed species, which are actively planted by gardeners with the intent to attract monarchs to their gardens. Unlike native milkweeds, this species grows year round so may disrupt migratory cues, and monarchs that breed on the same plants year round may have increased pathogen infections. In sum, monarch butterfly numbers have declined severely and the monarch is threatened by all five of the ESA listing factors. Accordingly, we hereby request that the Service list the monarch as a threatened species with a 4(d) rule, which would allow for protection of the monarch but also still permit activities to continue that promote the conservation of the species, such as scientific research and monitoring, citizen monitoring and tagging, and non-commercial classroom and household rearing of monarchs for educational purposes. Monarch ESA Petition 11
Page 1 and 2: BEFORE THE SECRETARY OF THE INTERIO
Page 3 and 4: PETITIONERS The Center for Biologic
Page 5 and 6: TABLE OF CONTENTS Executive Summary
Page 7 and 8: Though monarchs are found in relati
Page 9: threatened by logging, forest disea
Page 13 and 14: The monarch was very recently a hig
Page 15 and 16: when timely action is not undertake
Page 17 and 18: DESCRIPTION Photo © Jeffrey E. Bel
Page 19 and 20: Based on the short amount of time s
Page 21 and 22: After mating a female must soon fin
Page 23 and 24: legumes (Fabaceae spp.), goldenrod
Page 25 and 26: Monarch butterflies in western Nort
Page 27 and 28: Figure 8. Western monarch collectio
Page 29 and 30: Cardenolide fingerprinting of monar
Page 31 and 32: managers than roost sites (Brower e
Page 33 and 34: POPULATION DISTRIBUTION AND STATUS
Page 35 and 36: land was invaded by common milkweed
Page 37 and 38: Mexico, the Monarch Larva Monitorin
Page 39 and 40: Figure 13. Western Monarch Thanksgi
Page 41 and 42: almost a billion individuals were i
Page 43 and 44: When butterflies were collected for
Page 45 and 46: change, and stochastic weather even
Page 47 and 48: Pesticide usage figures from USDA
Page 49 and 50: Figure 18. Estimated Agricultural U
Page 51 and 52: Figure 20. A: Percentage of U.S. so
Page 53 and 54: In sum, the limited and early-seaso
Page 55 and 56: The Iowa and Minnesota surveys exem
Page 57 and 58: 1999 accounted for 56 percent of th
Page 59 and 60: In response, all of the major agric
Page 61 and 62:
iodiversity in agriculture-dominate
Page 63 and 64:
to butterflies, especially with fre
Page 65 and 66:
action of glyphosate and either 2,4
Page 67 and 68:
Brower et al. (2012a) identify loss
Page 69 and 70:
portion of Sierra Campanario. Loggi
Page 71 and 72:
and 21 additional hectares were imp
Page 73 and 74:
for some natural areas (Internation
Page 75 and 76:
international community and Mexican
Page 77 and 78:
and California, monarchs are able t
Page 79 and 80:
numbers of butterflies being in the
Page 81 and 82:
Petition, Loss of Monarch Habitat i
Page 83 and 84:
Additionally, FWS will phase out th
Page 85 and 86:
Private Lands The vast majority of
Page 87 and 88:
Vidal et al. (2013) identify small-
Page 89 and 90:
As explained elsewhere in this peti
Page 91 and 92:
Neonicotinoids include imidacloprid
Page 93 and 94:
Figure 26. Increasing imidacloprid
Page 95 and 96:
Figure 29. Increasing clothianidin
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2012, Nuyttens et al. 2013). This d
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most commonly used adulticides are
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Global Climate Change The monarch b
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availability (Cockrell et al. 1993,
Page 105 and 106:
Severe Weather and Catastrophic Eve
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two highly invasive swallow-wort sp
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that the entire North American rang
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and Oberhauser 2012). There is also
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the species at the time it is liste
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Baldwin, F.L. 2011. Glyphosate drif
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Brower, A.V. Z., and M. M. Jeansonn
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http://libcloud.s3.amazonaws.com/93
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Cleary Chemical Corporation. 2006.
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Dockx, C. 2007. Directional and sta
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Franz, J.E., M.K. Mao, and J.A. Sik
Page 127 and 128:
Hartzler, R.G., and D.D. Buhler. 20
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Johal, G.S. and J.E. Rahe. 1984. Ef
Page 131 and 132:
Lindenmayer, D.B., J.T. Wood, L. Mc
Page 133 and 134:
Meade, D.E. 1999. Monarch butterfly
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permethrin barrier treatments. Envi
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Rasmussen, N. 2001. Plant hormones
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the Linnean Society 144:191-212. Av
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http://www.nrcs.usda.gov/Internet/F
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U.S. Environmental Protection Agenc
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Wyatt, R., A. Stoneburner, S.B. Bro
Page 147 and 148:
Appendix A: Non-migratory Populatio
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2004). These milkweeds also have be
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y one or a few butterflies and then
Page 153 and 154:
Philippines Although monarchs were
Page 155 and 156:
Resident monarchs have also been st
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Danaus plexippus (Lepidoptera: Dana
Page 159:
Appendix B: Proposed Rules to Facil
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