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

[Addsum-Tony Frates]

In response to Catherine's query:

What the FWS is looking for right now is specific information about
the known status of the Monarch and any information they should be
gathering and/or paying attention to while they prepare their 12-month
finding that will only then lead to a proposal to either list or not
list, at which time there will be an opportunity to specifically
comment on that 12-month finding proposal.

So any information about observances of Monarch declines (which are
seemingly very real, but tough to quantify) in every state where
anyone has made those observations would be helpful.   If there was
any way we could document habitat loss (including losses by invasive
species such as Russian Olive which has very much impacted Monarch
habitat), particularly wet meadows areas where the milkweeds most
typically grow that the Monarch depends on and/or habitat
fragmentation or Monarch predation/disease etc., all of that would
help plus impacts by herbicides/pesticides and the like that John  
mentioned).   Any information that documents population sizes would  
also be something
that they are looking for, or anything that impacts any of the life
cycles that Monarch goes through.

Even anecdotal observations of the paucity of Monarchs in an area  
where they used to be commonly seen could be still be very useful to  
the FWS.   So if one used to see dozens of fluttering Monarchs more or  
less regularly year in and year out at a certain locality, but now  
they see few or none (and putting some general dates/years with those  
comments/observations) could help.  Or if they used to commonly see  
larvae and now the milkweeds aren't there because the area was  
developed, or the plants are there but no larvae, that could be useful  
to them (and would show concern at the same time).

Besides that and absent the above, I guess that comments that applaud
the FWS for even reviewing this and taking measures to help protect
this subspecies could be appropriate just to show general support for
the process.

As an aside:  I think the North American Monarch is classic case where  
federal involvement is highly beneficial/critical because just how  
complex the multi-state migration is, and the vast number of  
stakeholders that are involved.  There needs to be a central  
coordination council/committee/etc. to oversee whatever long term  
plans are implemented that can also apply for funding and that  
basically can see the forest for the trees.  No individual state can  
accomplish that on their own.  So some sort of significant FWS  
involvement I think is needed, regardless of what the 12-month finding  
recommends.  We need the FWS and we need a strong Endangered Species  
Act (which should include listings as appropriate, based on the best  
available science and current conditions/status) for all of these  
reasons, and others.  An ESA status would overall encourage (not  
discourage) conservation including private lands stewardship  
regardless of whether any restrictions would exist on those lands or  
not, free up funding for habitat acquisition, research, etc.

(And this is not to say we don't need the FWS/ESA when a highly  
restricted endemic plant or animal species is involved - just for the  
same reasons but as a microcosm as compared to the situation with the  
North American Monarch.)

Thanks for the dialogue.


Tony





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

> Right, it's not voting.  It's commenting publicly on proposed    
> administrative action, a petition in this case.  Agree (after    
> reading the call for comment at Regulations.gov for docket #    
> FWS-R3-ES-2014-0056) that specific kinds of comment are wanted, not   
>  general argument.   Still, it's an open call, not limited only to    
> scientific or commercial responses.  You could help by telling us    
> what kinds of commentary will best serve the purpose, in your    
> opinion.  Suggestions?
>
> Thanks,
> Catherine Smith
>
>
> From: Addsum-Tony Frates [afrates at addsuminc.com]
> Sent: Wednesday, February 18, 2015 2:54 PM
> To: Smith, Catherine
> Cc: John barr; native-plants at lists.plantconservation.org
> Subject: Re: [PCA] The monarch massacre: Nearly a billion    
> butterflies have      vanished
>
> 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
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>
>
>




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