3 years ago




EXECUTIVE SUMMARY The monarch is an iconic large orange and black butterfly that is one of the most familiar butterflies in North America. During summer monarchs can be found throughout the United States and southern Canada in most places where milkweeds (Asclepias spp.), their host plants, are available. Each year monarchs undertake a spectacular multi-generational migration of thousands of miles to and from overwintering and breeding areas. Most monarchs east of the Rocky Mountains migrate from southern Canada and the northern United States to the mountains of interior Mexico to overwinter. Most monarchs west of the Continental Divide migrate to coastal California. Monarchs east and west of the Rocky Mountains now face significant threats to their survival in both their summer and winter ranges, and their numbers have declined precipitously in recent years. Overall the North American monarch population has declined by more than 90 percent in the past two decades based on comparisons of the most recent population size estimates to the 20-year average. Numbers of monarchs east of the Rockies have declined by more than 90 percent since 1995; at most recent count, in winter 2013-2014, monarchs east of the Rockies dropped to the lowest number yet recorded, continuing the progression toward declining numbers seen over the last decade. Similarly, numbers of monarchs west of the Rockies have declined by more than 50 percent since 1997. The significant threats facing the monarch are high in magnitude and ongoing. In recognition of the dire status of this symbolic animal, in June 2014 the White House issued a Presidential Memorandum creating a federal strategy to promote the health of honey bees and other pollinators including the monarch. Although this is an important acknowledgement of the large-scale issues that are threatening the monarch, much more tangible action is needed to protect the butterfly and its habitat. Specifically, protecting this iconic species under the Endangered Species Act is a step that should be immediately taken to safeguard and recover the monarch. The Endangered Species Act (ESA) allows species to be listed as “threatened” when they are at risk of becoming endangered in a significant portion of their range. The ESA defines an endangered species as “any species which is in danger of extinction throughout all or a significant portion of its range” and a threatened species as “any species which is likely to become an endangered species within the foreseeable future throughout all or a significant portion of its range.” As applied here, the language of the statute, its legislative history and congressional intent, and the relevant judicial precedent interpreting and applying the statute all make clear that a species need not be at risk of worldwide extinction to qualify for ESA protection. Rather, in enacting the “significant portion of range” provision, Congress intended to provide a means to protect species before they are on the brink of extinction, which is of paramount importance to species conservation. The best available scientific information indicates that the monarch butterfly is threatened in a significant portion of its range. The North American monarch population is significant because without it, the redundancy, resiliency, and representation of the species would be so impaired that the monarch would have an increased vulnerability to extinction. The migratory butterflies in eastern and western North America represent the vast majority of all monarchs in the world. Monarch ESA Petition 6

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 Monarch ESA Petition 7

Parks for Monarchs
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