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monarch-esa-petition-final_61585

monarch-esa-petition-final_61585

The specific toxicity of

The specific toxicity of each neonicotinoid insecticide to the monarch butterfly has not been investigated, but it is likely that monarchs are vulnerable to one or more of these compounds as larvae or adults, or possibly even as eggs or pupae, given the toxicity of neonicotinoids to so many other butterfly species. Several lepidopteran pests of crops and trees are on the lists of specific insects that can be controlled by neonicotinoid applications. For example, sampling a few product labels, imidacloprid applied in CoreTect Tree and Shrub Tablets controls pine tip moth larvae (Bayer CropScience 2007), and Gaucho 600 Flowable seed treatment controls black cutworm (Bayer CropScience 2010); acetamiprid applied in TriStar 30 SG foliar spray controls caterpillars of gypsy moth, tobacco bud worm, fall army worm, southern army worm, cabbage looper, and diamondback moth (Cleary Chemical Corporation 2006). Since neonicotinoids are the most widely applied insecticides in the world (Jeschke et al. 2011) and their use overlaps with monarch breeding areas, there is an urgent need to investigate the lethal and sub-lethal toxicity of these compounds to monarchs. In the Midwestern Corn Belt, neonicotinoid use skyrocketed in the last decade, mainly as a result of almost all corn and most soybean seeds being sold having been pre-treated with neonicotinoid coatings (Krupke et al. 2012), despite questionable efficacy (Stevens and Jenkins 2014). Figures 25 through 29 illustrate this dramatic increase. Figure 25. Estimated annual agricultural use in pounds of neonicotinoids in the United States, 1994-2009 (Data from: Stone, W.W. 2013. Estimated annual agricultural pesticide use for counties of the conterminous United States, 1992–2009. U.S. Geological Survey Data Series 752. Monarch ESA Petition 92

Figure 26. Increasing imidacloprid use in the United States in 1993, 1999, 2005, and 2011. Data from the USGS Pesticide National Synthesis Project, available from: http://water.usgs.gov/nawqa/pnsp/usage/maps/show_map.php?year=1992&map=IMIDACLOPR ID&hilo=L Monarch ESA Petition 93

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