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monarch-esa-petition-final_61585

monarch-esa-petition-final_61585

together to support and

together to support and coordinate efforts to protect the monarch migration across the lower 48 United States (http://www.monarchjointventure.org/). While some of these entities are working to further the conservation of monarchs and their habitat, the implementation of the MJV is not a regulatory mechanism because it is a voluntary and unenforceable effort. Several programs exist on National Wildlife Refuges (NWRs) to foster monarch conservation. Refuges across the nation engage in monarch related activities, but all such activities are voluntary and none of them are adequate to provide monarchs with meaningful protections. Each NWR makes its own determination on how to manage monarchs. Many programs involve activities such as monarch festivals and citizen surveys. These voluntary efforts, while beneficial, are by their nature inadequate and not cognizable as regulatory mechanisms for purposes of ESA listing.. The U.S. Department of Agriculture’s (USDA) Natural Resources Conservation Service (NRCS) is part of the Monarch Joint Venture. Through a Conservation Innovation Grant, the NRCS has partnered with the Xerces Society and the seed industry to increase the availability of native milkweed seed for large-scale restoration efforts in the several states including California, Nevada, Arizona, New Mexico, Texas, and Florida. While this is an important program for monarch habitat creation, it is not a regulatory mechanism that can protect monarchs from the landscape level threats that they face (see: www.xerces.org/milkweed/). The U.S. Forest Service has some programs that benefit monarchs, but it does not have an agency-wide mandate or policy on monarch protection. The Forest Services’ efforts at protecting monarchs are inadequate regulatory mechanisms because the majority of the agency’s efforts are voluntary, the policies that protect animals such as monarchs provide only minor benefits, and the agency cannot utilize its authority to address significant threats across the range of monarchs. An example of a Forest Service policy that tangentially benefits monarchs is the regulation requiring a permit for the collection of plants and animals on Forest Service lands. While in theory this could protect individual monarchs from being collected, it does not provide protection for the monarch’s habitat. The Forest Service also maintains several webpages containing information on monarch butterflies that are focused on education and monitoring. Under the Monarch Joint Venture, an organization comprised of numerous stakeholders and initiated by the U.S.Forest Service International Programs, some National Forests have made efforts on behalf of monarchs including the creation of gardens designed to attract pollinators at ranger stations, controlling weeds and encouraging native plants, conducting butterfly surveys, restoring overwintering sites, and endeavoring to use thinning and prescribed burns to create conditions that foster native plants. Though useful, these voluntary and unenforceable efforts cannot be considered adequate regulatory mechanisms to protect and recover monarch butterflies. Several units of the National Park system in California contain monarch overwintering sites. National Park lands are protected from the development pressures facing other monarch habitats in California, but measures are not in place that specifically provide for monarch protection on Park Service lands. Monarch ESA Petition 82

Additionally, FWS will phase out the use of all genetically-engineered crops to feed wildlife and will ban neonicotinoid insecticides from all Wildlife Refuges nationwide, effective January 2016. The decision, applicable NWR System-wide, was announced on July 17, 2014, via a policy Memorandum issued by the Chief of the NWR System, James W. Kurth (http://www.centerforfoodsafety.com/files/agricultural-practices-in-wildlifemanagement_20849.pdf). While not specifically for monarch butterfly protection, the policy provides a strong monarch protection model, as it will largely eliminate the threat of geneticallyengineered herbicide-resistant varieties and neonicotinoids on National Wildlife Refuges. However, the protected land area of these Refuges is minor in relation to the area of protected land needed to conserve monarch populations from further decline. In sum, though some programs are in place on federally- managed lands that provide some benefit to monarchs, there are no existing regulatory mechanisms at the federal level which are adequate to safeguard the species. In addition, there are no mechanisms to protect monarchs from overutilization or activities that facilitate the spread of disease. Although the USDA regulates the interstate shipment of live butterflies, existing permits do not track the number of butterflies transported nor do they require the butterflies to be screened for disease. The spread of parasites and diseases is a major factor of concern for monarch conservation. Given the growing popularity of butterfly releases, lack of required screening for parasites, and potential for cross-species transmission in operations where multiple butterfly species are reared together, the lack of regulatory mechanisms governing the commercial rearing and release of wild butterflies poses a significant threat to monarchs (see Altizer and de Roode 2010, p. 26). In June 2014, the White House issued a Presidential Memorandum (2014) conceding that monarchs faced "an imminent risk of failed migration." The Memorandum established a federal strategy to address the alarming declines in populations of honey bees and other pollinators, including the monarch. Although the Memorandum is an important acknowledgement of the monarch crisis, it does not constitute a regulatory mechanism. State Mechanisms There are also no existing regulatory mechanisms at the state level that are adequate to protect monarchs. Some states have plans in place to protect some monarch habitat, but these protections are limited to specific sites and fail to provide monarchs with the landscape-scale protections necessary to stem their precipitous decline. Because they are easily identifiable and charismatic, monarchs have been officially listed as state insects or butterflies across the country. Seven states list monarch butterflies as their official state insect or butterfly including Alabama, Idaho, Illinois, Minnesota, Texas, Vermont, and West Virginia. These designations do not, however, confer substantive protections to the monarch. At the state level, Iowa and California provide examples of measures states have taken that can benefit butterflies, but because of its broad geographic range and the widespread environmental stressors affecting monarchs, piecemeal state programs are not adequate to safeguard the species. Monarch ESA Petition 83

MONARCH CONSERVATION
Parks for Monarchs
Increasing the availability of native milkweed - Monarch Lab
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