Advocate For ESA Protections

The U.S. Fish and Wildlife Service is seeking public support to pass their proposal to protect monarch butterflies under the Endangered Species Act. Use this guide to write an impactful public comment and give monarchs a fighting chance.

The Proposed Rule

The U.S. Fish and Wildlife Service has proposed to list monarch butterflies as threatened under the Endangered Species Act, which will provide species-specific protections for stabilizing and growing the monarch population, including minimizing insecticide and herbicide use, maintaining public support for monarch conservation, and increasing breeding, migratory, and overwintering habitat.

Since the 1990s, eastern and western migratory monarch populations have already declined by over 80% and 95%, respectively. If this trend continues, the USFWS predicts a 56-74% chance of extinction for the eastern population by 2080 and a staggering 99% chance for the western population.

Source: Monarch Watch

How to Write a Public Comment

Now, whether or not this proposed rule is published or withdrawn depends on you. The FWS has opened a 90-day commenting period ending on March 12, 2025 to seek public input from individuals and organizations to help shape their final decision.

Join us in submitting a public comment at regulations.gov to make your voice heard! Below, we compiled a shortened list of guiding topics and questions that USFWS is looking for, which is written in more detail in the Federal Register’s 4(d) proposal rule document.

Source: U.S. Fish & Wildlife Service

Feel free to answer one or any number of these questions based on your personal experience and opinion; although, it is preferred if those claims are backed up by supporting evidence (e.g. scientific journal articles or other publications) as the Endangered Species Act states that decisions made are “solely on the basis of the best scientific and commercial data.” Cite any supporting articles to avoid copyright concerns.

Identity: What is your name? Where do you live? Who are you (e.g. scientist, organization, interested individual, etc), and why do you care?
Population: What are the habitat requirements for survival? How are monarch butterflies distributed across the US? What are the historical, current, and projected population levels and status of monarch butterflies?
Threats: What factors (e.g. habitat loss, pesticide and herbicide use, infrastructure collisions, climate change) are contributing to the decline in the monarch population? How should these factors be addressed?
Protections: Do you agree with the protective regulations and economic impacts outlined in the proposed rule? If not, how should they be modified?
Habitat: Which specific areas should be designated for critical habitat?

Additionally, we’ve also provided Monarchs Matter’s submitted comment below. You’re welcome to use it as an example or copy and modify it to reflect your identity and perspective.

Example Public Comment by Monarchs Matter

My name is Cynthia, and I’m a youth monarch conservation researcher and activist from Long Island, New York.

In my childhood, I saw monarch butterflies a few times around the elementary school playground, but now as an adolescent I never see them except when I volunteer at community gardens with milkweed plants. In fact, because of the scarcity of monarch butterflies, I never knew that they were native to New York and the entirety of North America until I started volunteering at community gardens 3 summers ago. That summer, I also witnessed the metamorphosis of a monarch butterfly for the first time and had the opportunity of tagging, holding, and releasing a monarch. That magical experience fueled by curiosity in monarch butterflies and journey in saving monarch butterflies through my youth-led nonprofit Monarchs Matter. Locally, I have engaged youth and my community in planting milkweed, tagging monarch butterflies (mwtag.org), and collecting citizen science data for the Monarch Larva Monitoring Project (mlmp.org). Both children and adults alike are entranced by monarch butterflies’ resilience and migration. We have dedicated hours to restore monarch habitat and collect data for monarch conservation research, but at the end of the day, the monarch butterfly decline is a nation-wide problem that requires national protection.

Since the 1990s, the western and eastern monarch butterfly populations have declined by over 95% and 80%, respectively, primarily due to habitat loss and herbicide and insecticide spraying. The increased application of the herbicide glyphosate (Roundup), since the introduction of genetically modified herbicide-resistant crops in 1996, has contributed to a 31% decline in non-agricultural milkweed and an 81% decline in agricultural milkweed between 1999 and 2010, which represents a loss of more than 1 billion milkweed plants (Pleasants & Oberhauser, 2013; Flockhart et al., 2015). Moreover, agricultural milkweed has been shown to host almost 4 times more monarch eggs than non-agricultural milkweed, yet agricultural glyphosate use in the United States continues to remain at high levels of over 113.4 million kilograms sprayed annually—a 300-fold increase from 0.36 million kilograms in 1974 (Pleasants & Oberhauser, 2013; Benbrook, 2016). Hence, reducing herbicide use and reestablishing milkweed in agricultural areas can be pivotal to recover monarch populations. For eastern monarch butterflies, previous research has highlighted that improving breeding habitat in the South and the Midwest is one of the most effective conservation strategies: increasing nectar and milkweed availability, decreasing insecticide use, and increasing the amount of habitat by just 2% can increase the monarch population growth rate to above 1 (Oberhauser et al., 2016). For western monarch butterflies, California’s breeding areas in Central Valley and overwintering areas in central and southern coasts have been identified as the priority action zones (Xerces Society, 2024). However, the effects of climate change on monarch habitat can not be overlooked. By 2055, future suitable habitat is projected to shift northward, potentially expanding but falling outside the current distribution of monarch butterflies. Thus, the benefits of this expanded habitat may be limited without the corresponding availability of milkweed and nectar plants (Batalden et al., 2007).

The urgency to list monarch butterflies under the ESA is also underscored by protective actions by other agencies and organizations. Canada listed monarch butterflies as an endangered species under the federal Species at Risk Act (SARA) in December 2023 to prohibit harming and catching monarch butterflies and prepare a recovery strategy. Similarly, Mexico has enacted legal protections for monarchs and established the Monarch Butterfly Biosphere Reserve, a UNESCO World Heritage Site, that protects the oyamel fir forests where monarchs overwinter. Since December 2023, the International Union for the Conservation of Nature (IUCN) Red List of Threatened Species has recognized migratory monarch butterflies as vulnerable. As a critical step of the monarch migratory cycle, the United States must join this collaborative effort to secure a sustainable future for monarchs.

Thank you for your time and consideration.

Sincerely,

Cynthia Zhang

monarchsmatter.net@gmail.com

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Works Cited

Batalden, R. V., Oberhauser, K., & Peterson, A. T. (2007). Ecological Niches in Sequential Generations of Eastern North American Monarch Butterflies (Lepidoptera: Danaidae): The Ecology of Migration and Likely Climate Change Implications. Environmental Entomology, 36(6), 1365–1373. https://doi.org/10.1603/0046-225x(2007)36[1365:enisgo]2.0.co;2

Benbrook, C. M. (2016). Trends in glyphosate herbicide use in the United States and globally. Environmental Sciences Europe, 28(1). https://doi.org/10.1186/s12302-016-0070-0

Flockhart, D. T. T., Pichancourt, J.-B., Norris, D. R., & Martin, T. G. (2015). Unravelling the annual cycle in a migratory animal: breeding-season habitat loss drives population declines of monarch butterflies. Journal of Animal Ecology, 84(1), 155–165. https://doi.org/10.1111/1365-2656.12253

Oberhauser, K., Wiederholt, R., Diffendorfer, J. E., Semmens, D., Ries, L., Thogmartin, W. E., Lopez-Hoffman, L., & Semmens, B. (2016). A trans-national monarch butterfly population model and implications for regional conservation priorities. Ecological Entomology, 42(1), 51–60. https://doi.org/10.1111/een.12351

Pleasants, J. M., & Oberhauser, K. S. (2012). Milkweed loss in agricultural fields because of herbicide use: effect on the monarch butterfly population. Insect Conservation and Diversity, 6(2), 135–144. https://doi.org/10.1111/j.1752-4598.2012.00196.x

Xerces Society. (2024). Western Monarch Call to Action. Xerces.org; The Xerces Society. https://xerces.org/western-monarch-call-to-action