3 years ago



The Iowa Department of

The Iowa Department of Natural Resources and the Iowa Prairie Resource Center are members of the Monarch Joint Venture and have active programs for monarch protection. The Prairie Resource Center has focused its efforts on generating native prairie seeds, including milkweeds, and their engagement with the Monarch Joint Venture has generated additional funding for milkweed seeds that will be propagated through prairie habitat in Iowa. While certainly helpful, these programs cannot be considered as regulatory mechanisms that are adequate to safeguard the monarch. California does not have a statewide plan to benefit monarchs, but monarch overwintering sites occur in many State Parks and on other land managed by state agencies in California. State Park rules prohibit visitors from collecting animals and disturbing monarch roost trees, which provides the butterflies with some protection from collection and disturbance. Each park has a General Plan which guides management, but only one of these plans specifically considers monarch protection. The Leo Carrillo State Park General Plan considers monarchs and focuses on issues such as restoring native plants and maintaining overwintering sites for monarchs in non-native eucalyptus groves. None of the other parks specifically provide for monarch protection in their management plan, even if they are known to support large numbers of butterflies. Pismo State Beach, for example, provides a significant overwintering site for migratory monarchs, yet Pismo’s General Plan does not include any monarch specific management measures (International Environmental Law Project and Xerces Society 2012). While many parks do make good faith efforts to protect monarchs, the California State Park system does not provide an adequate regulatory mechanism for the protection of monarchs both due to the voluntary nature of monarch protection efforts and because it cannot provide protections for monarchs at the landscape scale. Local Mechanisms This petition does not attempt to analyze all county or city-level mechanisms that could provide some conservation benefit to monarchs because of the broad geographic range of monarchs. Though some areas may have programs in place that consider monarchs, these isolated programs are not an adequate replacement for range-wide regulatory protection. One example of a strong city ordinance that is beneficial to monarchs is the city of Capitola, California, which has adopted a year-round prohibition on the removal of trees within monarch habitat (with limited exceptions). The ordinance bars construction during monarch season, limits development in monarch habitat, requires developers to provide monarch-friendly landscaping, and mandates the collection of data both before and three years after construction to help develop a database for understanding environmental parameters associated with butterfly behavior (International Environmental Law Project and Xerces Society 2012). Unfortunately, this type of protection applies to a very small number of monarch sites and is an exception to the rule of weak or lacking protections. The vast majority of California’s monarch sites remain unprotected, with almost all jurisdictions allowing tree trimming without appropriate protection for monarchs. Overall, monarchs remain inadequately protected on city and county lands throughout the country. Monarch ESA Petition 84

Private Lands The vast majority of monarchs are dependent on habitat on private land where no existing regulatory mechanisms are in place to protect them. The breeding range of summer monarchs is largely on private agricultural land where protection is entirely lacking. Part of the winter range of western monarchs is on private lands in California, where they are threatened by development and disturbance and there are no existing regulatory mechanisms that are adequate to protect them. Monarchs on California’s private lands do enjoy slightly more protection than monarchs in other states because many of California’s monarch overwintering sites occur primarily within the coastal zone, generally defined as areas within 1,000 yards of the high tide line. Under the Coastal Zone Management Act, cities and counties are required to develop Local Coastal Programs (LCPs) for these areas. Most LCPs do not provide specific protections for monarch overwintering sites, but even the ones that do generally only provide protection during winter months when monarchs are actually overwintering, leaving vital habitat unprotected during the rest of the year (International Environmental Law Project and Xerces Society 2012). This means that landowners can cut limbs, trees, or even entire groves utilized by monarchs for overwintering habitat as long as they don’t do the cutting during the time monarchs may be physically present. Further, many overwintering sites are not even within the coastal zone, thus they don’t even benefit from this limited protection. Across the country, monarch habitat on private lands is under-protected or unprotected. International Mechanisms Monarchs migrate from Canada to Mexico, and the monarch migration is the subject of international attention and processes that reflect significant concern on the part of international bodies for the plight of monarchs. None of these endeavors, however, are adequate regulatory mechanisms due to their voluntary nature, their considerable reliance on anticipated future action, and because they are not equipped to address the most significant threats to monarchs. The North American Monarch Conservation Plan (NAMCP) Parties in Canada, Mexico, and the United States produced the North American Monarch Conservation Plan (NAMCP) in 2008 (Commission for Environmental Cooperation 2008). Like other efforts discussed supra, the NAMCP is not a cognizable “regulatory mechanism” for purposes of determining whether ESA listing is warranted because it is voluntary and relies on plans for future actions. Though the plan cannot be considered as a regulatory mechanism, it reflects a solid research effort and contains useful information on threats to migratory monarchs and recommended conservation actions to remedy such threats. The NAMCP is described by the U.S. Forest Service as a long-term cooperative agenda for monarch conservation, and it offers a list of key tri-national collaborative conservation actions, priorities, and targets to be considered for adoption by the three countries. The Commission for Economic Cooperation, an international body created by the North American Agreement on Environmental Cooperation at the same time as the North American Free Trade Agreement, released the plan. The NAMCP provides a status review of monarchs, and details the current factors causing monarch decline. It notes that the proliferation of genetically engineered, glyphosate-resistant crops in the Midwestern United Monarch ESA Petition 85

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