What if the monarch butterfly is listed as threatened? Understanding options with 4(d) rules

The monarch butterfly is currently being re-evaluated for consideration by the United States Fish and Wildlife Service (FWS) for listing under the Endangered Species Act (ESA). Based on a 2020 FWS decision, the monarch is currently designated as warranted, but precluded for listing, because other species are of higher conservation concern. However, the FWS has announced that a new decision is expected to be released for public comment by December 2024.

To better understand what this could mean for Iowans that commonly encounter monarchs (homeowners, farmers, ranchers, community scientists), let’s go over what might happen if the monarch is listed as threatened. Threatened means the species is likely to be listed as endangered. Being listed as endangered means a species is at risk of going extinct throughout most or all of their range. It should be noted that this is just an example of what might happen, not what will happen.

As summarized above, a threatened species is one that will likely become endangered in the future and is awarded protection through Federal actions (e.g., restrictions on transporting individuals, creating recovery plans, monetary aid to implement different conservation activities). Along with these protections, section 4(d) rules often accompany species listed as threatened to optimize conservation of a species, while reducing impact to landowners. These rules are exclusive to threatened species. For example, the Dakota skipper butterfly was listed as threatened in 2014, and within the same year, FWS developed a 4(d) rule that exempts incidental take resulting from livestock operations, including grazing and haying. The FWS recognized that livestock operations could aid in species conservation. Therefore, the 4(d) rule reduced any potential hardship livestock producers might face (e.g., having to obtain an incidental take permit) to maintain regular operations that were potentially helpful, not harmful, to Dakota skippers. 

If the monarch butterfly is listed as threatened, a 4(d) rule may also be proposed. Although we don’t know what exactly would be in a 4(d) rule for the monarch butterfly, some land management strategies could be included to exempt these actions from being considered species take or harm. The goal would be to encourage continued voluntary conservation actions that improve and add monarch butterfly habitat. However, the monarch butterfly is an extremely unique case because they can be found across a wide range of the United States compared to other listed species that occur in distinct areas. Therefore, additional considerations will likely be added to any potential 4(d) rules. 

Many questions come up when thinking about the upcoming decision for the monarch butterfly, but it’s important to remember that FWS considers and responds to all comments made by the public. If you may be impacted by the listing, make sure your comments are received by FWS during the open comment period; typically, 60 days for significant proposed findings/decisions. In the case of the monarch butterfly, public comment would be accepted after the proposed listing decision (December 2024). These comments could include support for including a 4(d) rule and examples of exemptions to consider. If a 4(d) rule is proposed, additional public comment would be accepted on the feasibility and details of exemptions. 

The Iowa Monarch Conservation Consortium will post on our website and social media platforms as updates become available. To learn more about the Iowa Monarch Conservation Consortium, visit iowamonarchs.info and follow @IowaMonarchs on Facebook, and X