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application period later into the growing season when milkweed is more susceptible to<br />

glyphosate.<br />

Additional <strong>monarch</strong> habitat is being lost due to the rapid conversion of grasslands and other<br />

milkweed-containing land types to corn and soybean fields to produce biofuels. Most remaining<br />

<strong>monarch</strong> habitat in the Midwest is on Conservation Reserve Program (CRP) lands. This habitat is<br />

threatened by ongoing conversion of these lands to corn and soybean production, a change<br />

driven by federal biofuels policy. Nationally, CRP acreage has shrunk by 11.2 million acres (30<br />

percent) since 2007, with more than half of this decline occurring in the Midwest, which has lost<br />

6.2 million CRP acres. This land-use change has resulted in the widespread elimination of<br />

milkweed from these habitats due to glyphosate use.<br />

Glyphosate used in conjunction with Roundup Ready crops has nearly eliminated milkweed from<br />

cropland throughout the <strong>monarch</strong>’s vital Midwest breeding range. It is estimated that in Iowa, for<br />

example, cropland lost 98.7 percent of its milkweed from 1999 to 2012. In just the 13 years from<br />

1999 to 2012, it is estimated there was a 64 percent decline in overall milkweed in the Midwest,<br />

most of which was from croplands. Because cropland milkweed produces nearly four times as<br />

many <strong>monarch</strong>s as plants in other settings, milkweed loss in corn and soybean fields has had a<br />

disproportionate impact on <strong>monarch</strong> numbers. It is estimated that in 2012, the Midwest produced<br />

88 percent fewer <strong>monarch</strong>s than it did in 1999.<br />

Monarch habitat is further threatened by the imminent introduction of new herbicide-resistant<br />

crops that are genetically engineered to now be resistant to multiple herbicides including for the<br />

first time 2,4-D and dicamba, which will be used in addition to glyphosate. Herbicides frequently<br />

drift beyond the boundaries of crop fields to affect wild plants growing nearby. These new<br />

genetically engineered crops will lead to sharply increased herbicide use, continued elimination<br />

of common milkweed from cropland, and reduction via herbicide drift of flowering plants that<br />

provide <strong>monarch</strong> adults with nectar, thereby threatening <strong>monarch</strong> nectaring habitat. Remnant<br />

<strong>monarch</strong> habitat outside of croplands is also being lost and degraded.<br />

Monarch breeding, nectaring, and wintering habitats have also been lost to development, and this<br />

threat is ongoing. Between 1982 and 2010, 43 million acres of land in the United States were<br />

newly developed, representing a 58 percent increase in developed land over a roughly 30-year<br />

period. Of note, more than 37 percent of developed land in the United States was developed<br />

during the last 28 years. East of the Rockies, it has been very roughly estimated that<br />

approximately 167 million acres of <strong>monarch</strong> habitat, an area about the size of Texas, may have<br />

been lost since the mid-1990s due to agricultural changes and development including nearly onethird<br />

of the <strong>monarch</strong>’s total summer breeding range.<br />

Monarch breeding habitat west of the Continental Divide is being lost due to urban and rural<br />

development, aggressive roadside management, herbicides, intensification of agriculture, and<br />

long-term drought. Glyphosate is also heavily used in the western portion of the <strong>monarch</strong>’s<br />

range, and may be degrading habitat there as well.<br />

The <strong>monarch</strong> is also threatened in its winter range. Monarch wintering habitat in California is<br />

threatened by development and natural senescence. Monarch wintering habitat in Mexico is<br />

Monarch ESA Petition 8

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