USDA / USFW Insect Permits

Paul Cherubini cherubini at
Fri Jun 16 12:21:18 EDT 2000

Wayne.F.Wehling at wrote:

> 3) Because the monarch is a "plant pest" the USDA regulates the monarch
> butterfly in order to uphold compliance agreements for the National
> Environmental Policy Act (NEPA).  It is the USDA's responsibility/jurisdiction
> to regulate the monarch because it is, by definition, a plant pest!

Why wasn't the monarch regulated from 1959 to the early 1990's? 
In Sept. 1997, Dr. Robert Flander's of the USDA explained that
during this 35 year period, USDA had a "hands off approach" with regard to
requiring permits and enforcing them for native butterflies that were not 
pests of crops such as the monarch.Thus it seems the USDA also has the 
authority to not bother regulating certain native butterflies if it doesn't want to,
even without doing risk assessments. 

In what year did the "National Environmental Policy Act (NEPA)" enter the 
picture? Where can we get ahold of a copy of this document?

Is there also a document we can read that outlines the scope and protocol for doing
the risk assessments necessary to exempt groups of Lepidoptera from regulation?


Paul Cherubini

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