WASHINGTON, Sept. 2, 2015 - The extended public comment period on EPA’s proposed risk management plan for the monarch butterfly closed last week, but not before scientists, environmental groups and agribusiness stakeholders weighed in on a decision that could have far-reaching implications for how farmers operate in the future.

Of the 60 plus comments submitted and available via the Federal eRulemaking Portal, over half were in favor of EPA instituting some sort of regulation to curb the destruction of monarch habitat, or specifically noted that pesticides were the reason monarch populations were dwindling. About a third of the comments were against any regulatory action.

The EPA’s proposal focuses on how to reduce the “potential indirect effects to the monarch butterfly from herbicide impact on milkweed plants,” which provide a critical food source during the butterfly’s larval stage. The proposal also solicits stakeholder policy recommendations.

The Xerces Society for Invertebrate Conservation recommended that EPA take “immediate action” to curb what it and many other wildlife groups see as the primary threat to monarch milkweed habitat: “increased and later-season” use of the herbicide glyphosate on genetically-engineered (GE) crops resistant to the product.

Xerces said research has shown Monsanto’s Roundup Ready corn and soybeans, designed to resist glyphosate, have “played a role in eliminating milkweed from cropland throughout the monarch’s vital Midwest breeding range.” For instance, between 1999 and 2012 when glyphosate use was rising, milkweed declined about 64 percent on Midwest cropland, and the region produced 88 percent fewer monarchs, the group said.

Glyphosate is extremely effective at killing perennial weeds like common milkweed at the root, the Xerces argued, which makes regrowth the following year largely impossible. In addition to protecting common milkweed from pesticides, the group recommended EPA restore and protect 40 other milkweed species native to the U.S. that are considered monarch host plants.

The American Farm Bureau Federation and CropLife America (CLA), which represents makers and marketers of crop protection products, said protections for milkweed habitat have to be balanced with weed management systems that ensure higher yields.

The Farm Bureau’s executive director of public policy, Dale Moore, urged the agency in his comments “to work through the stakeholder process… to ensure that farmers and ranchers are not harmed by limitations on pesticides that are important to their operations.” Moore urged EPA not to take actions to conserve milkweed that would be detrimental to production agriculture.

Ray McAllister, CLA’s director of regulatory affairs, said there isn’t conclusive evidence that monarchs are dying off at the rate some conservation groups claim, and that any decline in butterfly populations is due to a “complex set of factors, with complex solutions, many falling outside of EPA’s authority.”

CropLife stressed that if EPA were to impose bans or restrictions on herbicides, farmers might be forced to convert more land to agricultural use to maintain the same level of productivity, thereby decreasing the amount of available habitat for the butterfly. The better way to address the issue of habitat loss is through educational programming for farmers, McAllister wrote.

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The EPA’s proposal says explicitly that the agency will look at “a number” of herbicides for their potential to harm milkweed plants, and will evaluate them with the understanding that herbicides are in some cases critical for crop protection and are employed as part of an integrated vegetation management plan that is actually beneficial to some plant communities.

While no definitive regulatory prescriptions are made in the proposal, EPA said it would consider requiring changes to pesticide label instructions, mandating a certain schedule for applications or establishing spray drift buffers in fields that are treated with pesticides “in order to protect critical milkweed resources.”

The release of EPA’s proposal was prompted in part by a 2014 petition from the Natural Resources Defense Council that asked the agency to mandate a reduction in the use of glyphosate. EPA denied the group’s petition in 2015, although the agency said it agreed with the petition’s premise that herbicides may be connected to population decline in monarchs.

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