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most commonly used adulticides are organophosphate (e.g., malathion, naled) and pyrethroid<br />

(e.g., pyrethrin, permethrin, resmethrin, sumithrin, prallethrin) insecticides (Mazzacano and<br />

Black 2013). These compounds have broad -spectrum toxicity and can cause severe impacts to<br />

non-target animals including butterflies.<br />

General losses of biodiversity in insect communities that affect a wide range of orders and<br />

families have been noted by some researchers in areas where mosquito adulticides are sprayed<br />

(Eliazar and Emmel 1991, Kwan et al. 2009). Multiple studies have also shown negative impacts<br />

of mosquito treatments specifically on butterfly populations. Barrier treatments, in which<br />

pesticide applied as a spray to foliage forms a coating that kills adults that come into contact with<br />

it, can have lethal and sub-lethal effects on adult or immature butterflies.<br />

The decline of the federally endangered Schaus swallowtail butterfly (Heraclides aristodemus<br />

ponceanus), endemic to southern Florida, has been linked to pesticide applications for mosquito<br />

control (Eliazar and Emmel 1991), as has the decline of the Miami blue butterfly (Cyclargus<br />

thomasi bethunebakeri) (USFWS 2012, 77 FR 20948). Mosquito-control pesticides are also<br />

considered to be a contributing factor in the extinctions of the Florida zestos skipper (Epargyreus<br />

zestos) and rockland grass skipper (Hesperia meskei pinocayo) (see:<br />

http://www.fws.gov/southeast/news/2013/032.html ).<br />

In areas that are being treated for mosquitoes, <strong>monarch</strong>s can be exposed to the insecticides at the<br />

larval stage if the insecticides are over-sprayed or drift onto milkweed hosts, or as adults if<br />

butterflies are flying or visiting nectar plants during or after applications.<br />

Researchers at the University of Minnesota investigated toxicity to <strong>monarch</strong>s of two insecticides<br />

often used to control mosquitos (Oberhauser et al. 2006, Monarch Joint Venture 2014), and<br />

found that <strong>monarch</strong>s did have higher mortality when exposed:<br />

The University of Minnesota conducted research on how <strong>monarch</strong> larvae and adults were<br />

affected by exposure to insecticides commonly used in mosquito control (resmethrin and<br />

permethrin). These pyrethroids can be sprayed as ultra-low volume treatments or as barrier<br />

treatments. Ultra-low volume treatments intended to affect insects as they are flying, whereas the<br />

barrier treatments remain on leaves, providing a barrier to mosquitoes that may not be out<br />

foraging during the day. Both the ultra-low resmethrin study and the barrier permethrin study<br />

showed negative impacts on <strong>monarch</strong> larvae and adults. Leaves from the barrier treatments<br />

resulted in higher mortality to <strong>monarch</strong> larvae than control leaves up to 3 weeks after the initial<br />

application (Monarch Joint Venture 2014).<br />

Increased mortality of <strong>monarch</strong>s from mosquito control programs is thus a significant potential<br />

threat, although impacts have not been assessed.<br />

Grasshopper Control on Rangelands in the Western United States<br />

Insecticides are commonly used in rangeland areas across many western states to control native<br />

grasshoppers that compete with cattle for forage. When grasshopper numbers are high, the<br />

Animal Plant Health Inspection Service (APHIS) routinely facilitates spraying of insecticides to<br />

control Mormon crickets and grasshoppers on public and private lands. APHIS lists three<br />

Monarch ESA Petition 99

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