The US Fish and Wildlife Service is proposing to list the monarch butterfly (Danaus plexippus) as a threatened species under the Endangered Species Act (ESA).  While recognizing the monarch’s ecological and cultural importance, the Association submitted comments respectfully opposing the proposed listing for several reasons.
 
First, the Environmental Protection Agency’s (EPA) Herbicide Strategy and Draft Insecticide Strategy are designed to minimize potential harm to the monarch and other non-target organisms by implementing mitigation measures that reduce spray drift, runoff, and collateral pesticide exposure. These strategies rely on refined risk assessments and population-level evaluations rather than individual-level restrictions, and they provide practical guidance—such as establishing buffer zones and adopting drift-reduction methods—that enable farmers to maintain effective weed and pest control.
 
Second, voluntary and targeted conservation programs are already succeeding. Multiple conservation programs, including the Conservation Reserve Program (CRP), the Environmental Quality Incentives Program (EQIP), and the Agricultural Conservation Easement Program (ACEP), have shown success in improving pollinator habitats across private and public lands, as documented in the Mid-America Monarch Conservation Strategy.
 
Third, if the monarch butterfly is listed as threatened, the agricultural sector may face additional regulatory burdens and uncertainties. For many commodities support hundreds of thousands of jobs and provide major economic value across multiple states, new restrictions could raise compliance costs and disrupt long-established practices.
 
In written comments submitted this past week, the Association commented that it believes USFW should focus on targeted habitat management instead of listing. Monarch butterfly declines are linked to factors such as habitat loss, changing land-use patterns, climate variation, and threats at overwintering sites, indicating that localized or targeted responses are more appropriate than a sweeping threatened listing. Encouraging strategic habitat enhancements, such as planting milkweed in priority locations, sustaining overwintering grounds, and funding pollinator-friendly crop rotation practices, will likely produce more direct benefits for the monarch. Given the effectiveness of existing pesticide strategies, proven voluntary programs, and targeted habitat improvements for monarch butterfly conservation, listing the species as threatened under the ESA is unnecessary at this time.