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monarch-esa-petition-final_61585

monarch-esa-petition-final_61585

In addition to

In addition to initiating the Monarch Joint Venture, the U.S. Forest Service International Programs runs a monarch protection campaign that unites partners across Canada, the United States, and Mexico, and coordinates habitat conservation efforts through training and community outreach (see: http://www.fs.fed.us/global/wings/butterflies/welcome.htm). These efforts rely on the voluntary participation of conservation partners, school children, and other agencies, and are not attached to any legal mandate. The agency also participates in efforts to conserve and restore monarch habitat in all three nations, on public lands, and on private lands, and is making plans to form partnerships with farming organizations to conserve milkweed as part of its international monarch protection program. Though important, these programs cannot be considered as cognizable regulatory mechanisms for ESA purposes. Canadian Species of Special Concern Monarchs were designated a “species of special concern” in Canada in 1997, 2001, and 2010 (see: http://www.sararegistry.gc.ca/document/default_e.cfm?documentID=2027). A species of special concern is a “wildlife species that may become threatened or endangered because of a combination of biological characteristics and special threats” (http://www.cosewic.gc.ca/eng/sct2/sct2_6_e.cfm). This status does not come with substantive protections and indeed the latest monarch status report does not include any discussion of how Canadian officials intend to provide monarchs with any substantive protections; thus it is not an adequate regulatory mechanism. Furthermore, the majority of this species’ breeding habitat occurs in the United States, and threats in the States must be addressed in order for the butterfly to recover. Importantly, the Assessment and Status Report published by Canadian authorities and associated with the most recent listing notes that herbicide and pesticide use across North America is a threat to monarchs, but the Report does not indicate that Canadian authorities are mandating or even strongly recommending any significant action to protect milkweed habitat from this threat; indeed, milkweeds remain listed under the noxious weed acts of multiple provinces. The continued inclusion of milkweed as a noxious weed in parts of Canada is another indication that a Canadian species of special concern status cannot be considered an adequate regulatory mechanism. In sum, no existing regulatory mechanisms exist to adequately protect monarchs because the vast majority of monarch protection comes from voluntary measures, and even when measures are enforceable, they do not address monarch conservation on a rangewide scale. Some existing conservation efforts have undoubtedly increased and protected monarch habitat, but the continuing trend of steep decline plainly demonstrates that these existing measures are wholly insufficient to overcome the myriad threats to monarchs. Herbicide and pesticide use in summer habitat, development, climate change, and other synergistic threats are landscape-scale problems that cannot be adequately addressed through a mix of voluntary conservation measures. Rather, monarchs face threats that can only be adequately addressed through the comprehensive protections of the ESA. Monarch ESA Petition 88

As explained elsewhere in this petition (see Threats- Overutilization), upon listing the monarch butterfly, petitioners request that the Service implement measures that promote the continuance of activities that benefit monarch conservation such as citizen tagging and monitoring, scientific research, classroom rearing, education, and other activities that are beneficial for monarch conservation (see Appendix B). Petitioners also recognize the valuable role that the native seed industry plays, and will continue to play, in propagating milkweed seed and plants to facilitate monarch habitat recovery. Take of monarch caterpillars, eggs, and pupae routinely occurs as part of normal milkweed production activities. Should the Fish and Wildlife Service list the monarch butterfly as a threatened species under the ESA, we strongly recommend that the agency recognize the valuable role that milkweed producers will play in monarch habitat recovery and streamline the permitting process for incidental take permits for milkweed producers, so that the listing will not hinder milkweed production efforts. FACTOR FIVE: OTHER FACTORS AFFECTING THE MONARCH’S CONTINUED EXISTENCE Several other factors also threaten the monarch butterfly including increased pesticide use, global climate change, severe weather events, the spread of invasive species, and mortality at solar energy facilities. Pesticides Monarchs face threats at all life stages from pesticides used throughout their range. The term “pesticides” encompasses herbicides, insecticides, fungicides, nematocides, rodenticides, and all of the other biocides. Impacts of pesticides on monarchs can occur from indirect and direct effects, and from lethal and sub-lethal injuries (e.g., Kohler and Triegskorn 2013). Monarchs are harmed from widespread loss and degradation of habitat as a result of herbicide use that kills host milkweeds and alters nectar plant quality and abundance (e.g., Pleasants and Oberhauser 2012). As discussed in detail in the Modification and Curtailment of Habitat or Range section of this petition, use of glyphosate on genetically engineered, Roundup Ready corn and soybeans has been identified as the major cause of the precipitous drop in monarch numbers over the last 15 years, and this threat to the population continues as new areas are converted to corn and soybeans for biofuels, in addition to upcoming threats from the imminent introduction of new genetically engineered, herbicide-resistant crops (see discussion in Loss and Curtailment of Habitat and Range section of this petition). Larvae and adults, and under some circumstances, eggs and pupae, of monarch butterflies can be killed or impaired by exposure to pesticides via contact from overspray, drift of spray particles and vapor, runoff, dust, and through ingestion of pesticide-contaminated food and water. Pesticides also have “inert” ingredients, many of which are also toxic to butterflies (Stark et al. 2012). Monarch ESA Petition 89

MONARCH CONSERVATION
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