[PCA] The monarch massacre: Nearly a billion butterflies have vanished

[Smith, Catherine]

Thank you, John Barr, for helpful information and perspective that can inform responses to the call for public comments at Regulations.gov (docket # FWS-R3-ES-2014-0056).  Comments can be submitted until March 2.  To date, only 309 comments have been submitted.  That's a very low number.  If many of the comments take the same position, the result will be a skewed, unrepresentative sample.  In contrast, EPA's recent call for comments on proposed redefinition of 'waters of the US' under the Clean Water Act received 900,000 comments.

I hope many on this list will find time to submit a comment. If you're pressed for time, you can use information and ideas generated by this discussion to craft your response.  Again, deadline is March 2.

Comments can make a difference, as agencies can and do pull back proposed regulation for revision based on comments received.  Any well-conceived, supported comment is welcome.  All comments are read, categorized, and the categories are summarized by contract specialists for consideration by the proposing agency.  

Catherine F. Smith
Spring Mills PA
Professor Emeritus, English/Professional and Technical Communication, East Carolina University
author, Writing Public Policy: A Practical Guide to Communicating in the Policymaking Process (Oxford UP, 4th ed forthcoming 2015)


________________________________________
From: native-plants [native-plants-bounces at lists.plantconservation.org] on behalf of John barr [john at nativecottagegardens.com]
Sent: Wednesday, February 18, 2015 11:40 AM
To: native-plants at lists.plantconservation.org
Subject: [PCA] The monarch massacre: Nearly a billion butterflies have  vanished

This is being debated in the Monarch community.

1. The Monarch Butterfly is not in danger of extinction.  It is firmly established as both a native and an invasive (ironic) in multiple locations around the world.
2.  The mass migration from the northern tiers of the US and Canada to Mexico and from the rockies to the California coast is the phenomena that is in danger of extinction.

Biggest threat: GMO corn, soy, and alfalfa.
Other threats:  Climate change,  habitat loss due to development in the US and logging in Mexico, butterfly farming and releases, increased disease (OE) and parasites caused by year round breeding on non-native milkweed (A. curassavica).

Pro:  Publicity and awareness leading to efforts (public and private) and funding (public and private) the head off listing.  Possible changing ethanol mandate (some estimates that 40% of GMO corn goes to ethanol).  Possible changes to Conservation Reserve Program (lots of marginal lands moved to GMO corn to feed the ethanol mandate).  Climate change threats brought home with an iconic insect, could reinforce efforts at halting and reversing.

Con:  GMO and ethanol industries are politically powerful and rich.  Anything they perceive as a threat is going to get squashed, to the best of their ability.
The listing singles out butterfly farmers and releases, these folks are directly threatened and vocal.
Schools use monarchs raised in the classroom to give kids a hands on experience with nature and insect development, this could be curtailed or eliminated.  (Most teachers do not collect the monarch eggs themselves from the wild, they purchase from Butterfly farms and Monarch Watch, so policing would be pretty easy, if FWS chose to enforce.)
“A Bridge Too Far”, because it the the migration not the insect that would be listed, it is on somewhat uncharted territory, opponents of the ESA could use this as a target.
Monarch enthusiasts are often just that: MONARCH enthusiasts.  They are enamored with the Monarch butterfly first and the rest of the natural world not at all.  Hence, the buddlia and invasive milkweed planting.  They fear their handling of the monarch could be threatened.

The most knowledgeable and public biologists in Monarchy are divided into two camps: Sticks and carrots.  Some prefer to entice change with a carrot, some believe a stick is required.

I always picture the carrot being held by a stick, so both seem necessary.

john in austin
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