Date: 3/5/25 9:55 am
From: Lynn Foster <lfoster5211...>
Subject: AAS Call to Action--Monarch Butterflies
Dear Arbirders:

Monarch butterflies aren't birds, but birds benefit from the habitat that
is necessary for monarchs to exist. It has been noted on this discussion
list that the US Fish and Wildlife Service will be considering whether to
designate the monarch a threatened species. USFWS wants comments by March
12, one week from today. If you have not yet sent a comment, I encourage
you to do so.

The AAS Board of Directors is finalizing the text of a comment. Because the
deadline is a week away, I thought that even though our draft may not be
100% final, seeing the gist of it might help some of you who are
considering commenting yourselves. The text follows, in italics.

*The Arkansas Audubon Society is a statewide organization committed to
fostering a greater knowledge of the natural history of Arkansas and
promoting conservation of the state’s natural resources. We support the
listing of the Monarch Butterfly (Danaus plexippus) as threatened under the
Endangered Species Act. We also support the designation of critical habitat
wherever necessary throughout this species’ range to support its recovery. *

*Like many conservation entities, we have been concerned by the drastic
population declines of the North American populations of this species.
Their complicated life history, spanning many states and three countries,
makes conservation difficult, which is another reason why these efforts
should be overseen at the federal level. Indeed, their unique life cycle is
yet another reason to declare them threatened. Monarchs fly through
Arkansas in the spring and again in the fall, migrating to and from their
overwintering grounds in Mexico. A few monarchs even stay in the state
throughout the summer. It has also been documented that a generation of
monarchs, possibly a fifth generation, is born in Arkansas in late summer,
making Arkansas a locus of critical habitat for both breeding and migrating
monarchs.*

*In 2015, Arkansas published a Wildlife Action Plan which designated the
monarch as a Species of Greatest Conservation Need. This designation was
based on “the drastic decline of the migratory subspecies” and the
recommendation of the Association of Fish and Wildlife Agencies. At that
time, habitat loss was noted as the main threat to this species, and data
gaps such as identifying migratory corridors and determining important
areas within the state for breeding monarchs needed to be filled. There is
still much work to do to benefit this species in Arkansas. Arkansas’s plan
is currently being revised with new information, which will provide new
rankings and updated concerns. It is our belief that the status of the
monarch in Arkansas has only worsened since 2015. Federal listing and
designation of critical habitat will support conservation efforts
throughout its range and throughout Arkansas. *

*Thank you for considering this comment. We are hopeful that the Service
will take this important step towards preserving this iconic species.*

You can find information on how to comment at
https://www.regulations.gov/document/FWS-R3-ES-2024-0137-0001. Thanks to
those who have already submitted comments.

Lynn Foster
President, AAS

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