As Monarch butterflies finished their tardy, impressive sweep through Texas in early November demonstrating a 2014 population rebound, those in the Monarch community debated the wisdom of listing the iconic migrating butterfly as “threatened” under the Endangered Species Act (ESA).

In late August, the Xerces Society, Center for Food Safety, Center for Biological Diversity and Dr. Lincoln Brower submitted this petition to the Secretary of the Interior requesting the Monarch butterfly be listed as “threatened” under the ESA.

This year’s seemingly healthy population, predicted by experts to be two, perhaps three times as large as last year’s record low, is a welcome turnaround from the post-2010 decline associated with the prolonged Texas drought and other challenges to the migration. The rebound has created a bit of a disconnect, arriving the same year as the petition to consider the iconic migrants’ threatened status.

The reasons for the general decline of Monarchs are well documented: genetically modified and herbicide tolerant crops, continued urbanization and habitat destruction along the migratory path, illegal logging in Mexico, climate change, and pesticide use. The ecosystem that supports the Monarch butterfly migration–and pollinator habitat in general–is tattered.  Dr. Chip Taylor stated it well in a recent blog post: “Monarchs clearly aren’t endangered. As this discussion proceeds, we need to make it clear in all communications that it’s about the migration and not the species per se.”

Agreed.

So, is petitioning the federal government to list our favorite butterfly as “threatened” the best way to accomplish that goal?  After giving it much thought, I think not.

Threatened status might motivate large corporations and government agencies to be more considerate of Monarchs and other pollinators, but for private citizens with no government or scientific affiliation, such status could be counter productive.

Monarch cateripllars

Not in your backyard: if ESA threatened status is applied to Monarchs, each household will be allowed to raise only 10 Monarchs per year. Photo by Monika Maeckle

As one who enjoys Monarchs visiting my urban garden eight months of the year and roosting along the Llano River in the fall, I take particular issue with the federal government telling me what I can do with my land.

Milkweed and nectar plants fill my San Antonio pollinator gardens.   We’ve also undertaken a riparian restoration in the Texas Hill Country where Monarchs roost each year, an effort that includes planting native milkweeds and other nectar plants along our riverbanks along the Llano River.

In the course of any given year, I raise several hundred butterflies, not just Monarchs, for fun, joy, and to give as gifts. My goal is to inspire appreciation and understanding of our outdoor world and reinforce the majesty of nature in a small, everyday way.

According to the 159-page petition’s final line,  if “threatened” status is approved, such activities would be a crime.  People like me and you will be allowed to raise “fewer than ten Monarchs per year by any individual, household or educational entity”–unless that activity is “overseen by a scientist, conservation organization, or other entity dedicated to the conservation of the species.”

This seems to strike at the very heart of what has made the Monarch butterfly so iconic and widely embraced–the crowdsourcing of understanding its migration and the groundswell of interest in conserving it.

Catalina Trail, then known as Cathy Aguado, was the woman on the cover of National Geographic in 1976

Citizen scientists and individuals like Catalina Trail were instrumental in the discovery of the Monarch roosting spots in 1976.  File photo.

Let’s not forget that regular folks like us helped piece together the puzzle of the Monarch migration back in 1976 through Dr. Fred Urquhart’s monitoring project and the intrepid explorations of individuals like Catalina Trail, the first person to chance upon the roosts in Michoacán.  Making lawbreakers of regular folks for participating and reserving that privilege only for scientists would do more harm than good.

If milkweed becomes part of critical habitat as defined by the ESA under this petition, that would mean destroying milkweed–or getting caught destroying it–would become a crime punishable by fines or mitigation.   Civil penalties can come to $25,000 per ESA violation and criminal fines up to $100,000 per violation, and/or imprisonment for up to one year.

Many landowners will simply not plant milkweed or will do away with it entirely just to avoid problems.  In some parts of the universe, this is known as Shoot, Shovel and Shut-up, the “practice of killing and burying evidence of any plants or animals that might be threatened or endangered.”

We have seen this attitude first hand in Texas.  Ranchers have been known to destroy first growth Ashe Juniper to preserve grass lands and conserve water to avoid ramifications of disturbing the preferred habitat of the endangered Golden-cheeked warbler.
Also, the U.S. Fish and Wildlife Service is cited as the enforcement agent for these rules– but how likely is it that agency personnel will have the bandwidth to do so? If enforcement is not practical, what is the point of the rule?

The petitioners take special issue with the commercial butterfly breeding industry, which supplies eggs, caterpillars, chrysalises and live butterflies for schools, nature exhibits, conservation activities and events. The petition specifically details how conservation education activities like the rearing of Monarchs in school classrooms or at nature centers will be immune to regulation, “provided that the Monarchs are not provided by commercial suppliers.”

That means if a teacher in a classroom or home school situation in New York City wants to teach metamorphosis to fifth graders using Monarch butterflies, she can only do that with  butterflies personally harvested in the Big Apple. The best intentions often lead to unintended consequences, and that is what I fear in this instance.

“If only wild caterpillars can be collected and brought into the classroom, we will run the risk of excluding urban children…. precisely what we don’t want,” Dr. David Wagner, author of the guide to Caterpillars of Eastern North America, Dr. Felix Sperling of the University of Alberta and Dr. Bruce Walsh, of the University of Arizona, co-wrote in a 2010 article in the News of the Lepidopterist’s Society.

Again, this seems like a case where federal regulation will do more harm than good since the children that most benefit from the tactile experience of raising butterflies are often those living in urban settings with limited access to nature.

Nola Hamilton Garcia with Monarch butterfly

Limiting access to butterflies in the classroom to those found only in the wild will severely restrict access to Monarchs by urban children (who most need it), some scientists say.   Photo by Tracy Idell Hamilton

One of the most contentious issues in the petition is a claim on page 74 that “millions” of Monarch butterflies are released into the environment by commercial butterfly breeders each year.

The claim appears greatly exaggerated to the International Butterfly Breeders Association (IBBA), which challenged the number in a press release headlined, “Number of Monarch Butterflies Released Annually Closer to 32,000 than ‘millions and millions’ as Claimed by Endangered Species Act Petitioners.”  [DISCLOSURE:  I serve on the board of the International Butterfly Breeders Association but do not raise butterflies commercially.  I also am a member of the Xerces Society and have hosted both Dr. Chip Taylor and Dr. Lincoln Brower at our ranch.]

The IBBA challenged the basis for such a claim, noting that the “millions and millions” citation was, in fact, lifted from a single newspaper op-ed piece published eight years ago.  The author, Professor Jeffrey Lockwood, University of Wyoming, acknowledged the number was guesswork.
“That such an unverified claim surfaced in a formal petition before the Secretary of the Interior demonstrates a serious failure in documentation at best,” Kathy Marshburn, IBBA president, said in the press release.

Dr. Tracy Villareal, an IBBA board member, oceanographer, and part owner of Big Tree Butterflies butterfly farm in Rockport, Texas, called the claim “misleading and poor scholarship.” Villareal told me by phone that he would grade such secondhand references unacceptable in a graduate student’s dissertation.

“The authors made no attempt to determine the composition of the 11 million–how many of each species, for example. Nor did they attempt to contact the author to determine how he arrived at this number.  It took me about four hours from my initial email to Professor Lockwood to find out how it was done.”  Read the IBBA’s challenge to the numbers for yourself.

OE Spores with Monarch Butterfly Scales

OE spores can be debilitating for Monarch butterflies.   Concerns about infecting the wild population with the nasty spore persist, and studies continue.  Photo courtesy of MLMP

The petitioners believe that commercial breeders release diseased butterflies into the wild population, potentially damaging it. In particular, the unpronounceable Monarch-centric spore, Ophyrocystis elektroscirrha (OE), poses special concern since it debilitates the butterflies and appears to thrive in conditions where the creatures congregate en masse, are crowded, and/or where milkweeds overwinter, carrying the spores into the next season.

Yet, scientists agree that OE is present in the wild population, too, just as Streptococcus, the nasty sore throat-causing bacteria, is present in the human population. Only when health or conditions are degraded does the disease overtake the butterflies. The science is still uncertain on this.  Studies continue.

Like any industry, commercial butterfly breeding attracts good citizens and bad, but it seems highly unlikely that people who gravitated to the challenging task of breeding butterflies for a living would intentionally release damaged goods into nature. That just makes for bad business. Does the industry need better checks and balances on the health of livestock released into nature?  Absolutely.

The IBBA, an international organization of 104 breeders, plans to release new counts for the number of butterflies released annually at its conference that begins November 12 in Ft. Lauderdale. The organization also will host a discussion on changing or increasing self-policing practices of its membership to keep livestock as disease-free as possible.  As Villareal said in a recent email exchange on the DPLEX list, a listserv frequented by hundreds of folks in the Monarch community, “Working from clean breeders is a critical first step in production. I repeat this for everybody in the back row. CLEAN BREEDERS ARE CRITICAL.”

The ESA petition has created conflict in the small-but-passionate world of butterfly advocates.  A far better use of the community’s time and energy could be spent on initiatives and public education campaigns to restore migratory habitat.

It’s already happening in many ways, through government and small-but-significant public- private partnerships.

In June, President Obama issued a presidential memorandum calling for all federal agencies to “substantially expand pollinator habitat on federal lands, and to build on federal efforts with public-private partnerships.”  Pollinator Week Proclamations have been declared in 45 states, recognizing the vital services that pollinators provide.  The EPA released guidance to help scientists assess the potential risks various pesticides pose to bees, and the USDA announced an $8 million initiative to provide funding to farmers and ranchers who establish new pollinator habitats on agricultural lands as part of its Conservation Reserve Program.

Hardberger Park Land bridge

Yes, please.  Hardberger Park land bridge would facilitate safe movement of wildlife–including pollinators. Photo via Rivard Report

Here in my hometown, we are working with the leadership of San Antonio’s Hemisfair Area Redevelopment Corporation to include pollinator habitat in their upcoming reimagination of the historic 65-acre downtown park that was home to the city’s 1968 world’s fair. Our local public utility, CPS Energy, recently supported the installation of a pollinator garden right downtown at their headquarters on the San Antonio River Walk.   And on our city’s heavily developed northwest quadrant, Hardberger Park has a dedicated butterfly garden. The park conservancy is raising money for a spectacular land bridge that will facilitate safe movement of pollinators and other wildlife.

Let’s focus on individual actions and crafting effective public-private partnerships that raise awareness, plant more milkweed and nectar plants and make rebounds like 2014 common fare–and keep the federal government out of our yards.

NOTE:  Have you taken our Milkweed Poll?  Please do. Three questions, only takes a minute.  GRACIAS!  Please do it now, here’s the link.

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