Risk Management Approach to Identifying Options for Protecting the Monarch Butterfly

The Environmental Protection Agency (EPA) is concerned about the dwindling population of monarch butterflies and intends to identify efforts that will protect the monarch butterfly by conserving the milkweed plant, the plant upon which monarch butterfly larvae depend.   In this document, the EPA's Office of Pesticide Program outlines an approach for taking action to protect monarch butterflies. This document is the start of the process which will depend upon (i) input from a diverse group of stakeholders to identify and integrate information with respect to influences on the population dynamics of the monarch butterfly and the milkweed plant; and, (ii) cooperation and collaboration from these diverse stakeholders to identify activities that will balance weed management needs across varied landscapes with conservation of the milkweed plant.

Background 
Over the past decade, threats to pollinators, including honey bees, bats, and butterflies, have become an important issue.  Pollinators play a key role in agriculture and food production, and thus the issue of declining pollinator health has been the focus of much research and work. Over the past several years, the EPA has been working with a wide range of partners to develop measures to protect pollinators from the potential effects of pesticides.  As EPA continues its pollinator protection efforts, it is expanding its pesticide risk management efforts to include steps to protect monarch butterflies.
The EPA is initiating efforts focused specifically on the monarch butterfly for several reasons.  First, the U.S. has been engaged in an effort with Canada and Mexico through the Canada/Mexico/U.S. Trilateral Committee for Wildlife and Ecosystem Conservation and Management, where the three partner nations have agreed to make natural resource conservation a priority.  Consistent with its objective to conserve and manage natural resources across North America, the committee has recognized the monarch butterfly as an emblematic species shared by the three countries and renewed their collaborative effort to protect the species and its required resources. Secondly, in addition to the efforts of the Trilateral Committee, President Obama issued a memorandum on pollinator protection entitled, Creating a Federal Strategy to Promote the Health of Honey Bees and other Pollinators.  The memorandum highlights the importance of the monarch butterfly and establishes a task force of Federal agencies to develop a strategy to conserve pollinators and the monarch butterfly in particular.  The memorandum states that the task force is to develop a strategy that looks to developing partnerships with external stakeholders such as state, tribal and local governments, farmers, corporations, and non-governmental organizations to achieve the goal of protecting and conserving the monarch butterfly and its habitat.  Finally, in February 2014, the EPA's Office of Pesticide Programs (OPP) received a petition from the Natural Resources Defense Council (NRDC) asking the EPA to take actions to reduce the use of the herbicide, glyphosate, because NRDC believes that the widespread use of glyphosate has impacted the monarch butterfly by reducing the presence of the milkweed.  While the EPA has denied NRDC's petition, the EPA concludes that its ongoing efforts to protect bees, in conjunction now with this effort to protect the monarch butterfly, are in line with the objectives of the NRDC petition.
Numerous publications have highlighted the importance of the common milkweed (Asclepias syriaca L.) as a critical food resource for monarch butterfly larvae (Danaus plexippus L.), and have emphasized the importance of conservation of milkweed to preserve monarch butterfly populations.  In addition, together with several non-governmental organizations, various agencies within the Federal government have been working collaboratively with the Monarch Joint Venture to develop and implement measures to protect monarch butterflies and their migration.  In this document, EPA identifies the types of information that may be important to have in order to identify appropriate actions to take under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) to protect monarch butterflies (including milkweed resources) while also enabling pesticide users to meet important weed management needs.  The approach and objectives outlined here will support and complement the actions and objectives of the Trilateral Committee and the Presidential Memorandum on Pollinator Health.

Outreach
In its efforts to conserve and protect the monarch butterfly and the milkweed plant, the EPA anticipates working with a range of partners to identify information, develop and implement actions, and track progress on reducing risk to the species.  Since threats to pollinators, including the monarch butterfly and its resources, are many, efforts to protect such resources will need to be multifaceted and reflect  the interests of various sectors such as federal, academic, public, industry, and non-governmental.  EPA's efforts therefore, will be informed and built upon input from these stakeholders.  We will look to our stakeholders to provide input for developing actions that are meaningful and are aimed at the protection of the monarch butterfly and its habitat but that are also balanced with respect to land owners needs for weed and vegetation management.    
In a similar manner, efforts of the EPA and its stakeholders will be further coordinated and part of broader efforts that will be led by the U.S. Department of the Interior (DOI).  DOI has the lead among the federal agencies assigned to develop a strategy to conserve the monarch butterfly.  Efforts led by the DOI will likely address other factors and issues (other than herbicides) that are affecting the monarch butterfly and its critical resources.  Ultimately, the broad and multifaceted strategies of the U.S. will be coordinated with our North American partners  -  Mexico and Canada  -  not only so ideas and approaches can be shared, but to insure that efforts between the countries are complementary.

Objective and Scope
The EPA will contribute to ongoing monarch butterfly conservation efforts by identifying situations in which areas of milkweed can be preserved in a manner that balances this objective with weed management needs.  The EPA will seek to identify these situations for areas that are important to the monarch butterfly.  The EPA envisions working with a range of stakeholders such as pesticide users from both the agricultural and non-agricultural community; members from the academic community including extension personnel; representatives from non-governmental organizations; state agencies, and the public.  Interactions with these stakeholders will identify opportunities to reduce the potential impact of herbicides on the milkweed plant.  The Agency with input from stakeholders will review both direct effects, which are those that occur at or very close to the time of the pesticide application itself; and, indirect effects, which occur by or as a result from the pesticide and are later in time, but still reasonably certain to occur.  For example, direct effects to the monarch butterfly, from herbicides, insecticides or other types of pesticides can be addressed through the agency's risk assessment framework utilized for estimating effects to other pollinators.  And so, the focus of this effort will be on reducing potential indirect effects to the monarch butterfly from herbicide impact on milkweed plants.  

The EPA also recognizes that it is possible that if EPA were to take regulatory action to reduce the potential impact from one herbicide to protect important monarch butterfly resources, such efforts could result in a market shift to other herbicides that would not be subject to similar risk mitigation measures.  To the extent that happened, there could well be little or no improvement for monarch butterflies.  In order to avoid this, the EPA envisions that its effort should not be limited to looking at just one or two herbicides, but across a number of herbicides.  To begin to determine which herbicides ought to be considered in the scope of this action, the EPA will consider and evaluate different types of information such as: 
   (i) volume of use of various herbicides on acreage in agricultural production and in non-agricultural areas such as rights-of-way, pastures/rangeland, forestry sites, and industrial areas critical to the monarch butterfly and where the milkweed plant is commonly found; 
   (ii) information on the monarch butterfly such as its lifecycle, seasonal distribution, its population demographics over time, and any modeling analyses relevant to critical life stage parameters to which the monarch butterfly population is most sensitive;
   (iii) availability of laboratory or field data that specifically relates to the effects of various herbicides on the milkweed plant species; 
   (iv) information on both spatial and temporal parameters of weed management needs particularly with respect to different land use categories and herbicide uses; and in agricultural production areas where herbicide use may overlap with habitat of the monarch butterfly development, reproduction, and migration; and 
   (v) information on existing practices that promote co-occurrence of agricultural production with maintenance of milkweed populations.
         
Balance of Weed Management and Milkweed Protection
The EPA understands that efforts to reduce the impact of herbicides on milkweed must take into account the weed management needs of the sites being treated.  In certain scenarios, such as crop production, milkweed plants in an agricultural field are considered weeds, and their presence may be incompatible with other goals of these land uses.  In other scenarios, such as non-agricultural, industrial, or rights-of-way, milkweed may not be a target species of herbicide use.  In these scenarios, herbicides are employed as part of integrated vegetation management to selectively eliminate or control certain plant species.  Use of herbicides in this context can result in more stable plant communities (such as those composed of native species) that contributes to supporting wildlife and wildlife habitat by reducing fragmentation or threats from soil erosion or wildfire.

Information on weed management across the variety of landscapes where milkweed can be found and the impacts of not controlling it or other weedy species will be crucial to developing options to conserve monarch butterfly habitat.  This is particularly important in non-crop areas, where herbicide use may overlap with the habitat of monarch butterfly development, reproduction, and migration.  Such information will help the EPA to identify opportunities to balance milkweed protection while still meeting weed management needs across the varied landscapes where it can be found.

Analysis and Actions
The efforts to conserve the milkweed plant from effects of herbicides may encompass a number of pesticidal compounds.  Therefore, in contrast to a typical quantitative single-chemical analysis approach, the EPA will rely upon both qualitative and quantitative analyses to weigh risks and benefits and identify actions to conserve the milkweed plant where it is important to monarch butterflies. The EPA anticipates that a number of actions could be taken to protect monarch butterflies  -  for example, requiring changes to pesticide label instructions such as: lowering the rates, decreasing the frequency; modifying the timing of applications; or establishing spray drift buffers in fields that are treated with pesticides in order to protect critical milkweed resources.  The agency could also support education and training on best management practices.  These management practices may be in addition to and complementary of other conservation efforts aimed at creating, conserving, or restoring wildlife habitat.  Interaction between partners of different sectors to adopt management practices in a coordinated manner not only at the field level, but at the landscape level and area-wide level as well, will be important for success.  For example, conservation banking effort(s) could be undertaken that could establish, preserve, or restore habitat for monarch butterflies, or cooperative efforts could be established to fund further research into protection measures for the monarch butterfly.  If appropriate, support of such efforts could be considered by EPA as risk mitigation in regulatory decisions for herbicides that are determined to adversely impact the monarch butterfly. The agency is soliciting public comment on which potential action or a combination of actions discussed above would be the most effective in reducing the impacts of herbicides on the monarch butterfly. The agency is also requesting that any additional measures not discussed here be identified.

Next Steps
Following the 30-day comment period, EPA will evaluate any comments or information submitted in response to its proposed approach for protecting monarch butterflies.  EPA will begin to gather and assess information to understand weed management needs as well as information on the monarch butterfly and milkweed.  In the near future EPA will reach out to engage stakeholders to develop potential steps forward.  EPA is also continuing to work with the coalition of government agencies in response to the Presidential Memorandum, in which efforts regarding the monarch butterfly are being led by the DOI.  EPA believes that open communication with the full range of stakeholders engaged on this issue will be important in order to identify and coordinate actions that can be taken to protect monarch butterfly and its resources in a manner that also considers weed and vegetation management needs in the varied landscapes where herbicides are used.

