US Fish & Wildlife Monarch Butterfly Petition

As the US Fish & Wildlife (USF&W) continues in their effort to list the Monarch butterfly as threatened on the Endangered Species Act, there are many things for us, as butterfly breeders and conservationists to consider.

**Check out the comments all the way at the bottom of the page that different members, breeders, and agricultural departments have made. It’ll help you as you formulate your own comment.

You can read the entire petition HERE, and that is a great place to start.

Below is the process that US Fish & Wildlife is required by law to follow for listing a species.  You can also read more detail about it HERE.

The 90 day comment period ends March 2, 2015.  This is part of a 12 month review by FWS.  Then they decide to list the Monarch, not list the Monarch, or defer the decision to a later date.

Nick V. Grishin, Howard Hughes Medical Institute, Department of Biophysics and Biochemistry, University of Texas Southwestern Medical Center, wrote an article in the News of the Lepidopterists’ Society, “Why the Monarch Butterfly Should Not Be Listed Under the Endangered Species Act.” In this article, Grishin quotes Dr. Lincoln Brower during a public interview:

“To begin with, one of the petitioners, a renowned monarch scientist Dr. Lincoln Brower, implied so in a public interview: “I think you are going to have difficulty because the monarch is not an endangered species”, and “Do I think the monarch butterfly will become extinct in its range? – no” (Pounds 2014).  According to Pounds (2014) this was the first reaction of Brower on the petition in the works.  A first reaction is rarely wrong, especially from someone as knowledgeable about the Monarchs as Dr. Brower.”

WHAT?! Can you read that again?! Dr. Lincoln Brower said the Monarch butterfly is NOT an endangered species!!  If it’s not endangered, then WHY is he one of the petitioners seeking threatened status under the ESA?

You can read the entire Grishin article HERE. And you can read the article Grishin quoted Brower from HERE.

One of the items that breeders were first to identify in the petition is that it lists an incorrect number of Monarch butterflies released by breeders into the environment.  The petitioners claim that commercially raised monarchs can contribute diseases to wild populations because of the high numbers released. The actual text from the petition is here:

“The potential for captive-reared monarchs to transmit disease or undesirable genetic traits is high because of the vast number of commercially reared monarchs compared to wild monarchs.  Though the exact number of monarchs sold commercially is unknown, there are an estimated 45–60 butterfly farms in operation in the United States that distribute more than 11 million butterflies per year, most of which are monarchs or painted ladies (Vanessa cardui) (Altizer and de Roode 2010, p. 26; Pyle et al. 2012). Thus, it is likely that at least a few million monarchs are released into the wild annually, representing a substantial proportion of the overall monarch population (33.5 million wild monarchs estimated in the overwintering eastern population in 2013-2014, and less than half a million total western monarchs). A recent investigative report on this industry suggests that the commercial monarch industry is rapidly growing, in part due to the increasing popularity of releasing monarchs at weddings (Federman 2008).”

You can find the details HERE about how breeders have responded to that and the actual numbers that are released into the wild.  In fact, you will find in the above document that just 13 butterfly farms release about 84% of the butterflies released into the wild.

In the ESA petition, the reference to 11 million butterflies per year is from the Xerces Society document written by Pyle et al.  In it they cite a NY Times op ed article that derives the 11 million per year number by extrapolating one farm’s numbers.  That editorial can be found here: http://www.nytimes.com/2006/08/24/opinion/24lockwood.html?_r=3&partner=rssnyt&emc=rss&

This is a number containing monarchs and painted ladies but that point is usually glossed over in the anti-release literature.  Millions and millions is frequently how they describe it.  Simple math tells us if these numbers were from 100 farms (very high estimate) over 52 weeks (most farms don’t raise year round), then we get a production rate of 2,115 butterflies per week.  There are not any big farms that are maintaining that production over the period of a whole year.

To get an idea on how Xerces Society and Dr. Lincoln Brower feel about releasing butterflies for weddings, funerals, or for any other reason, check out this NY Times article written September 15, 1998. Click HERE for the article.  And, no, they haven’t changed  their minds since 1998.  Xerces Society has a policy in which they state what they feel are the many problems with doing butterfly releases.  You can see that statement HERE.

The 90-day comment period has closed, but you can still view the comments HERE.

If you are looking for ideas on what you should submit as a comment, we have some members that have already sent in great comments and you can get ideas from them below.  The AFB has met with an environmental law attorney, who had wonderful suggestions for us.  You can click HERE to read the notes from that meeting.  Below, you can also find some notes from her on the things we should all be commenting on during this comment period.

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The recommendation we got from Melinda Taylor, law professor at UT Law School was to write comments that detail our opposition to the listing and provide evidence of positive aspects of the industry.

We should request that USFWS allow commercial activity under a 4d exemption recognizing that adequate guidelines for disease control be used by breeders such as the ones developed by the AFB as a certification process.

Note that the butterfly rearing industry is committed to disease control and the release of healthy butterflies under conditions that reasonably ensure their survival.  We can mention the AFB Code of Ethics, disease testing program, disease education programs, and implementation of a regular blind screening program to ensure parasites and disease are at levels considered acceptable by academic experts.

We should mention that Dr. Sonia Altizer has provided guidelines for this program and we accept her recommendations for allowable levels of OE.  The impact of the industry is far less than suggested by the petitioners. An examination of their original sources revealed their cited numbers came from a Xerces press release that misrepresented numbers in a New York Times op-ed articles.  This was discussed in a press release issued last year.  http://www.enhancedonlinenews.com/news/eon/20141028006031/en

When the author of the op-ed article (Dr. J. Lockwood) was contacted, he shared emails with his editor noting his calculations indicated ~32,000 monarchs a year were released.  A subsequent survey of breeders yielded an upper end estimate of ~250,000 monarchs a year that were released.  This is substantially less than the millions suggested by the petitioners.  It reinforces that the case for the butterfly release industry to negatively affect the monarch population was significantly overstated.

Comments should include examples of activities that are supported by our rearing operations, including (and add more if you think of them) the following.  Pictures, examples of educational materials, perhaps even videos are great.   Links to blogs, websites, press releases, any form of communication is great.  Activities to mention include (but not limited to):

Conservation activities

Education activities

Celebrations

Memorials, funerals

Hospice for fund raising

Number people influenced by activities where they are released

Fund raisers and charities

Support research activities

Talk to Special needs groups

Mikula’s activities

Add photos, videos

Sources of information for local area (i.e. impact of tropical milkweed)

School room programs, educational gardens, educational information (blogs, pamphlets, seed packets, growing instructions) that are supported by your rearing operation

Tours of the facility that do education on butterfly and pollinators

Talks to school groups

Research activities

Another thing to mention in your comments are the procedures you have to raise healthy Monarch butterflies.  Here are some idea-starters for you:

Taping and regular checking for OE

Always using clean healthy stock for breeders

Adding in (after raising at least one generation or having them screened) livestock from an outside, unrelated source

Sanitizing methods for rearing containers

Procedures you take to eliminate cross contamination (gloves, sanitization of gloves, etc)

Courses you have taken

Screening programs you participate in

Never overcrowding

How you raise healthy plants

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**Click on the name below to bring up the comments.

Rose Franklin	Pam Lee
Lori Harris	Commissioner John McMillan Alabama Dept of Agriculture
Kansas Water Office	Utterback Farms
AFB	Todd Stout
Edith Smith	Rick Mikula