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

[Addsum-Tony Frates]

It should be more clearly noted however that this isn't a "voting"  
process; this isn't American Idol.

The FWS has already decided to review this under a 90-day finding.   
Nothing is going to be pulled back at this point, and the comments  
they are seeking are scientific and commercial data relating to the  
status of the North American Monarch subspecies* for the 12-month  
finding that they are going to be working on.

All of these comments opposing or supporting listing are really  
largely inapplicable and misdirected at this time.

Tony Frates


*The other comment mentioning the species as a whole not being in  
danger of exinction misses the point that this is a petition to list  
Danaus plexippus plexippus and not every/all subspecies of Monarchs,  
and they are different; and also that a threatened status under the  
ESA would refer to a taxon that is in danger of becoming extinct.







Quoting "Smith, Catherine" <SMITHCATH at ecu.edu>:

> 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
> _______________________________________________
> native-plants mailing list
> native-plants at lists.plantconservation.org
> http://lists.plantconservation.org/mailman/listinfo/native-plants_lists.plantconservation.org
>
> Disclaimer
> Posts on this list reflect only the opinion of the individual who is  
>  posting the message; they are not official opinions or positions of  
>  the Plant Conservation Alliance.
>
> To unsubscribe, send an e-mail to   
> native-plants-request at lists.plantconservation.org with the word   
> "unsubscribe" in the subject line.
>
> _______________________________________________
> native-plants mailing list
> native-plants at lists.plantconservation.org
> http://lists.plantconservation.org/mailman/listinfo/native-plants_lists.plantconservation.org
>
> Disclaimer
> Posts on this list reflect only the opinion of the individual who is  
>  posting the message; they are not official opinions or positions of  
>  the Plant Conservation Alliance.
>
> To unsubscribe, send an e-mail to   
> native-plants-request at lists.plantconservation.org with the word   
> "unsubscribe" in the subject line.
>