3 years ago



concern given recent

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

Parks for Monarchs
Increasing the availability of native milkweed - Monarch Lab
valley of the monarch butterfly - Steppes Discovery
Monarch Butterfly Migration PowerPoint -
Monarch Financial Holdings, Inc. 2009 Annual Report - Monarch Bank
MBNZT Calendar 2013 low - Monarch Butterfly NZ Trust
Figure 45.0 A monarch butterfly just after emerging from its cocoon
and ESA - DB Server Test Page - University of Idaho
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