March 12, 2025

Barbara Hosler
Regional Listing Coordinator
U.S. Fish and Wildlife Service
Midwest Region Headquarters
5600 American Blvd.
Bloomington, MN 55437

RE: FWS-R3-ES-2024-0137 (Endangered and Threatened Species: Species Status with Section 4(d) Rule for Monarch Butterfly and Designation of Critical Habitat)

Dear Ms. Hosler:
Pennsylvania Farm Bureau (PFB) wishes to offer its comments on the U. S. Fish & Wildlife Service’s (USFWS) proposal to list the monarch butterfly as a threatened species and designate critical habitat under the Endangered Species Act of 1973, as amended. PFB is Pennsylvania’s largest general farm organization, representing approximately 27,000 members engaged in all manner of agricultural activities, including the production and processing of crops; the production and processing of animals; the production and processing of forestry products; landscaping and horticultural services; agriculture-related support services; and food manufacturing.

PFB is also part of the American Farm Bureau Federation (AFBF), our nation’s largest general farm organization, working together to build a sustainable future of safe and abundant food, fiber, timber and renewable fuel for our nation and the world. In a letter dated Feb. 5, 2025, AFBF has previously expressed its concern that the proposed listing of the monarch butterfly could significantly impact agriculture across the country, and requested a 60-day extension of the comment period in order to fully understand the impacts this proposed listing may have on agriculture across the United States. PFB supports that request, and while it is obviously too late for such an extension to be granted at this point, it is our understanding that USFWS intends at present to reopen the comment period at a later date, at which time we will provide more detailed observations. For the time being, we wish to offer the items below for your consideration.

First of all, preserving natural surroundings for America’s wildlife has long been a priority for America’s farmers. More than 100 crops are dependent on insect pollination, and farmers are committed to protecting the monarch butterfly through voluntary conservation efforts. Indeed, more than 77 million privately owned farm and ranch acres are enrolled in voluntary conservation programs, providing habitats for countless animals and insects, including the monarch. In addition, farmers have contributed to conservation efforts through federal programs like the Conservation Reserve Program (CRP), and with regard to language in the proposal “allowing” for “activities that may maintain, enhance, remove or establish milkweed and nectar plants within the breeding and migratory range that do not result in conversion of native or naturalized grassland, shrubland or forested habitats,” we would note that technically, USDA considers CRP to be crop land, and it would help to have clarity that moving land in and out of CRP is allowed.

PFB urges the USFWS to recognize the efforts farmers are taking to preserve monarch habitat, and we have encouraged those individuals to share their experiences with the agency as it considers a “threatened” designation for the monarch. These approaches provide for maximum flexibility for the agency to balance protection of the butterfly with the needs of America’s farmers. Indeed, given that monarch butterfly migration paths cross large swaths of the United States, we believe that any impacts of the butterfly proposed listing must recognize regional differences and varying conservation efforts by farmers nationwide. Farm Bureaus across the country have been involved with state and regional conservation efforts for the monarch, often in conjunction with the energy and utility sectors, those who manage natural areas, and urban leaders throughout the United States. AFBF is also a member of “Farmers for Monarchs,” which is committed to protecting the butterfly population through voluntary efforts to restore and enhance habitats.

The proposal also asks for comments on potential restrictions on pesticide use with regard to protecting monarch butterfly habitat. When considering this issue, PFB first observes that pesticides are highly regulated and rigorously tested to ensure they can be safely used when applied, as directed by the label and backed by the best available science, and innovative new technologies now allow farmers use pesticides as precisely as possible, applying them only as needed down to the level of an individual plant. Pesticides undergo several years of rigorous testing before they are deemed safe for use on farms, a process that takes approximately 11 years prior to approval (and for additional context, on average, only one in 10,000 discoveries makes it from the lab to the field). EPA solicits public comments for all pesticides during the approval process, and more than 350 EPA scientists focus full-time on regulating pesticides.

Given the above, we recommend that USFWS work with agriculture to ensure a final listing of the monarch accounts for current regulatory and conservation practices used on farms, including the use of pesticides. While we respect the agency’s goal of identifying ways to assist the monarch butterfly, we are concerned at the potential impact of what could be a wide-ranging review of an unknown number of crop protection tools that are important to farmers.

Should USFWS proceed in this manner, we urge the agency to work through a stakeholder process to ensure that farmers are not harmed by limitations on pesticides that are important to their operations. For our part, we believe that there should be no restrictions for use of pesticides based only on the monarch if the monarch is not found in a particular area at a particular time. USFWS should work with AFBF, PFB and other stakeholders to identify ways to narrowly tailor any restrictions on insecticide use based on the movement of the butterfly. Recall also that in 2024, EPA finalized the ESA Herbicide Strategy, which introduces a new approach to mitigate against drift and runoff/erosion impacts. While improved from its draft version, concerns remain about the strategy’s feasibility for certain crop production in certain regions of the country.

Thank you again for the opportunity to share our concerns, and as noted above, we stand ready to offer more detailed recommendations if, as expected, this proposal is re-opened for public comment.

Sincerely,

Grant R. Gulibon, Regulatory Affairs Specialist