23
Dec
Fish and Wildlife Service Proposes “Threatened” Status for Monarch, after EPA Failure to Stop Harmful Pesticides
(Beyond Pesticides, December 23, 2024) As the U.S. Fish and Wildlife Services (FWS) proposes to list the Monarch butterfly as a threatened species under the Endangered Species Act, a look at the factors contributing to the butterfly’s catastrophic decline includes a stunning failure of the U.S. Environmental Protection Agency’s (EPA) regulation of pesticides to protect biodiversity and the ecosystems necessary to its survival. While there are many factors affecting the survival of Monarchs, EPA’s Office of Pesticide Programs (OPP) has allowed pesticide use to continue unabated, with only rhetorical attention to the problem. Meanwhile, the science shows a range of pesticide effects associated with insecticides and herbicides. A study published in PLOS One in June identifies insecticides as the primary driver in butterfly’s decline, as EPA points, almost exclusively to herbicide use and the destruction of Monarchs’ food source, milkweed habitat. While two or several factors can be true at the same time, EPA has failed to consider the confluence of factors, including the impacts of climate, as rising temperatures are exacerbated by the production and use of petrochemical pesticides.
FWS is stepping in at a critical time with looming biodiversity collapse and in the absence of EPA taking the reins to eliminate pesticides that are threatening the existence of Monarchs. Populations of both Eastern and Western monarch butterflies have been decreasing in recent years, leading environmentalists to clamor for an “endangered” classification for the species. Declining monarch populations are symptomatic of the ongoing insect apocalypse, which threatens worldwide ecology and agriculture—and exemplifies the failure of the EPA, including OPP, to regulate with a holistic lens that protects biodiversity.
EPA’s narrative on Monarchs is symptomatic of a program that is focused on some factors in isolation of the full range of critical elements associated with all the pesticides it registers in combination. In addition, rather than leading with its mandate to focus on pesticides in the protection of Monarchs, the agency appears to be deflecting on the issue by posting on its website issues other than pesticides that are affecting Monarchs’ survival.
On its Monarch page, OPP highlights “loss of breeding habitat, loss of overwintering habitat in Mexico (where the butterflies spend their winters), changes in weather patterns (including winter storms), and other factors.” The agency Incudes reference to an article that, while mentioning pesticides, stresses migratory challenges as the cause of decline. Then, the agency continues with a focus on herbicides as the problem, stating the following: “EPA believes that a holistic approach is needed for monarch conservation that includes judicious use of herbicides, balancing weed management needs with monarch conservation needs, and focusing on ways to support monarch conservation through pesticide registration review, registration and stakeholder outreach and education.” The webpage then links to a 2015 risk management document that further focuses on herbicides to the exclusion of insecticides and other pesticides. On its Action to Protect Pollinators page, EPA refers back to its 2015 document and is locked into the assumption that, despite the harm it causes, there must be continued reliance on genetically engineered herbicide-tolerant crops that are dependent on widespread herbicide use as well as other production and land management practices that rely on herbicides. The agency does not consider organic management systems in its analysis, despite its commercial and cost-effective efficacy and productivity in the market.
Although many factors are involved in the devastation of insect populations, scientific studies show that pesticide use ranks high, led by the use of seeds coated with neonicotinoid insecticides. Other pesticide impacts include mortality from insecticide drift and the destruction of milkweed by herbicides. These impacts are exacerbated by climate change, which is made worse by the production and use of petrochemical pesticides and fertilizers.
Monarch butterflies serve as an indicator of the status of insect pollinators and their habitats. Because so many people have been involved in monitoring their populations, the U.S. Fish and Wildlife Service (FWS) has responded to the call to protect them by proposing to list monarchs as a threatened species and designate critical habitat under the Endangered Species Act (ESA). Plants or animals can be listed as either “threatened” or “endangered.” When a species is listed, it can help provide resources and even legal action to protect them. FWS explains the terms: an endangered species is a plant or animal species “that is in danger of extinction throughout all or a significant portion of its range,” and a threatened species is one “that is likely to become endangered in the foreseeable future throughout all or a significant portion of its range.”
In 2022, the International Union for Conservation of Nature (IUCN) classified the monarch butterfly as endangered and updated the classification to vulnerable a year later. Although the IUCN listing has no legal weight in the United States, it calls attention to the plight of the butterfly, which according to IUCN 2022 estimates, showed that the eastern population of migratory monarchs declined by as much as 84 percent between 1996 and 2014 and the western migratory monarch’s population dropped from around 10 million insects in the 1980s to 1,914 in 2021—a loss of about 99.9 percent.
The proposed listing will provide increased federal protection and resources for monarch conservation, in the form of protection from harm, a comprehensive recovery plan, and ongoing funding to restore their habitat. ESA prohibits the “take” of a single individual of a listed species. “Take” is defined in ESA as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct.” The likely “take,” which includes unintentional harm or death, of even one individual of a listed species, is enough to constitute a “may affect” determination under EPA’s policy and trigger the need for formal consultation with FWS. Hence, the proposed designation has the potential to prohibit pesticide use that harms not only monarchs but other pollinators as well.
Tell the U.S. Fish and Wildlife Service to finalize its proposed listing of monarchs as threatened.
Comment to the U.S. Fish and Wildlife Service
I am very concerned about the impact of pesticide use on biodiversity—particularly in promoting the “insect apocalypse.” Populations of both Eastern and Western monarch butterflies have been decreasing in recent years, leading many to want an “endangered” classification for the species. Declining monarch populations are symptomatic of the ongoing insect apocalypse, which threatens worldwide ecology and agriculture. Although many factors are involved in the devastation of insect populations, scientific studies show that pesticide use ranks high, led by seeds coated with neonicotinoid insecticides. Other pesticide impacts include mortality from insecticide drift and the destruction of milkweed by herbicides. These impacts are exacerbated by climate change.
Monarch butterflies serve as an indicator of the status of insect pollinators and their habitats. I am happy to see the U.S. Fish and Wildlife Service (FWS) propose to protect them by listing monarchs as a threatened species and designating critical habitat under the Endangered Species Act (ESA). Plants or animals can be listed as either “threatened” or “endangered”. FWS explains the terms: an endangered species is a plant or animal species “that is in danger of extinction throughout all or a significant portion of its range,” and a threatened species is one “that is likely to become endangered in the foreseeable future throughout all or a significant portion of its range.” While it can be argued that monarchs should be listed as endangered, either listing will provide needed protection.
In 2022, the International Union for Conservation of Nature (IUCN) classified the monarch butterfly as endangered and updated the classification to vulnerable a year later. Although the IUCN listing has no legal weight in the United States, it calls attention to the plight of the butterfly, which according to IUCN 2022 estimates, showed that the eastern population of migratory monarchs declined by as much as 84 percent between 1996 and 2014 and the western migratory monarch’s population dropped from around 10 million insects in the 1980s to 1,914 in 2021—a loss of about 99.9 percent.
FWS’s proposed listing will provide increased federal protection and resources for monarch conservation, in the form of protection from harm and a comprehensive recovery plan and ongoing funding to restore their habitat. ESA prohibits the “take” of a single individual of a listed species. “Take” is defined in ESA as “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect or attempt to engage in any such conduct.” The likely “take,” which includes unintentional harm or death, of even one individual of a listed species, is enough to constitute a “may affect” determination under EPA’s policy and trigger the need for formal consultation with FWS. Hence, the proposed designation has the potential to prohibit pesticide use that harms not only monarchs but other pollinators as well.
Please finalize the listing of monarch butterflies as threatened.
Thank you.
