monarch-esa-petition-final_61585

Though monarchs are found in relatively small, peripheral, and introduced populations in
tropical and subtropical locations outside of North America (see Appendix A), these nonmigrating
populations cannot conserve the genetic diversity and spatial distribution of the
species, are limited in population growth potential such that they cannot substitute for the
abundance of the continental North American population, and are themselves vulnerable to
extirpation.
Numerous species have been protected under the ESA that have large ranges and relatively
abundant population sizes but that have experienced population decline and that face significant
threats to their continued existence. A few examples of such species include the gray bat (Myotis
grisescens), Indiana bat (Myotis sodalis), fat pocketbook mussel (Potamilus capax), piping
plover (Charadrius melodus), Chinook salmon (Oncorhynchus (=Salmo) tshawytscha), and
small whorled pogonia flower (Isotria medeoloides). A species is not required to have declined
to the level of range-wide endangerment in order to qualify for protection under the ESA.
The ESA states that a species shall be determined to be endangered or threatened based on any
one of five factors (16 U.S.C. § 1533 (a)(1)): 1) the present or threatened destruction,
modification, or curtailment of its habitat or range; 2) overutilization for commercial,
recreational, scientific, or educational purposes; 3) disease or predation; 4) the inadequacy of
exisiting regulatory mechanisms; and 5) other natural or manmade factors affecting its contined
existence. The monarch is threatened by all five of these factors and thus warrants protection
under the Act:
Factor One: Modification or Curtailment of Habitat or Range
Monarch habitat has been drastically reduced and degraded throughout the butterfly’s summer
and winter ranges and threats are ongoing. Monarch habitat is threatened by, among other things,
pesticide use from genetically engineered, pesticide-resistant crop systems that kill milkweeds
and nectar sources, as well as by development, logging, and climate change.
A primary threat to the monarch is the drastic loss of milkweed caused by increased and laterseason
use of the herbicide glyphosate in conjunction with widespread planting of geneticallyengineered,
herbicide-resistant corn and soybeans in the Corn Belt region of the United States
and to planting of genetically-engineered cotton in California. In the Midwest, nearly ubiquitous
adoption of, glyphosate-resistant “Roundup Ready” corn and soybeans has caused a precipitous
decline of common milkweed, and thus of monarchs, which lay their eggs only on milkweeds.
The majority of the world’s monarchs originate in the Corn Belt region of the United States
where milkweed loss has been severe, and the threat that this habitat loss poses to the resiliency,
redundancy, and representation of the monarch cannot be overstated.
Monsanto introduced Roundup Ready soybeans in 1996 and Roundup Ready corn in 1998.
Genetically-engineered herbicide-resistant varieties (nearly all Roundup Ready) now comprise
94 percent of soybeans and 89 percent of all corn grown in the United States. Glyphosate is not
only being applied to vastly more acres than ever before, it is being applied more intensively to
the acres that are treated with it. Between 1995, the year before Roundup Ready soybeans were
introduced, and 2013, total glyphosate use on corn and soybeans rose from 10 million to 204
million pounds per year, a 20-fold increase. Roundup Ready crops have also shifted the
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