Government views Monarch Butterfly Releases as a threat to Western Milkweeds

[Chip Taylor]

As many of you know, Paul Cherubini has a pronounced tendency for 
taking things out of context.

Here is the my entire posting to Dplex-l - it's long.

This text was prompted by a number of strong reactions to the 
proposed USDA regulations posted to Dplex. My sense is that the USDA 
will not go ahead with these proposed regulations unless it can be 
shown that monarchs pose a credible threat to the threatened and 
endangered milkweeds.

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To Dplex-l

Let's keep in mind that the regulations in question are proposed and 
are not final. These proposed regulations have been offered for 
public comment and once the comment period is over the regulations 
are likely to be rewritten and submitted for comment once again. It 
is appropriate for all who are concerned about this issue to provide 
INFORMED commentary to the USDA. These comments should be addressed 
to:

Docket No. 95-095-2,
Regulatory Analysis and Development,
PPD, APHIS, Suite 3C03,
4700 River Road Unit 118,
Riverdale, MD 20737-1238.

The comments should be mailed by 10 Dec.

  USDA_APHIS is mandated to create appropriate regulations based on 
scientific evidence rather than value judgements, emotions, 
education, economics, or other considerations. It is up to us to help 
provide this evidence and to urge that appropriate research be done, 
should evidence be lacking, on a particular issue - such as whether 
monarchs are even known to utilize the threatened milkweeds as 
hostplants in OK and AZ. At present, there appears to be a conflict 
between two regulations one that permits the shipping of widely 
distributed migratory species such as monarchs and painted ladies and 
another which seeks to protect threatened or endangered plants that 
are potential hosts for monarchs.

Some of the questions we need to ask are:

Do monarchs actually use the species in question as hosts? In eastern 
Kansas  the endangered Asclepias meadii  has been studied by two of 
my colleagues and teams of students for about 10 years. We have also 
looked at this plant most springs. To date no one has reported 
finding monarch larvae feeding on this species.

Are monarchs common or rare during the time when these plants are 
pre-senescent (i.e. potentially suitable hosts)?

Does herbivory by monarch larvae, if it occurs, actually constitute a 
threat to long lived perennial milkweeds? (Meads milkweed appears to 
live 100 years or more.)

We should also remind ourselves and those who might be concerned 
about endangered milkweeds that both the monarchs and the milkweeds 
have coexisted for many thousands of years. To the best of my 
knowledge there is no example of a native herbivore that has 
eliminated a native plant. {if anyone on leps-l can think of an such 
an example, please let me know} (All examples of such negative 
interactions involve introduced herbivores.)

The plants in question occur in remote areas where releases are 
unlikely and we might ask whether a release of monarchs in Oklahoma 
City could conceivably have an impact on a milkweed population in the 
panhandle of OK  hundreds of miles to the west.

And, we have to ask whether there are other more common and perhaps 
overriding threats to these plants such as grazing, development, poor 
land management, off road vehicles, etc.

For those of you interested in milkweeds and the areas in question 
you can find more information on the following web sites.
A Review of Rare, Threatened and Endangered Plant Species in Northern Arizona

welshii
http://www.nau.edu/~envsci/sisk/courses/env440/SCBS/cecilia.htm

uncialis
http://www.ndis.nrel.colostate.edu/ndis/rareplants/PDASC02220.html

The following has a section about the causes of decline and its 
recovery needs. Here they mention that Nebraska Statewide Arboretum 
is doing research on the life history of this milkweed.
http://www.biosurvey.ou.edu/asclepu.htm#decline


The university of New Mexico web site describes a couple of subspecies:

http://nmrareplants.unm.edu/droplist/dropa-c.htm

Asclepias nummularia (Asclepidaceae) - Populations of this species 
occur peripherally in New Mexico (localized in the "boot heel" region 
of the state) and are relatively common in Chihuahua, Mexico.

Asclepias uncialis ssp. ruthiae (Asclepidaceae) - This name may be 
synonymous with Asclepias uncialis ssp. sanjuanensis.

Asclepias uncialis ssp. uncialis (Asclepidaceae) - The distribution 
of this taxon is widespread from Wyoming to southwest Arizona.

(Curiously the proposed regulation only deals with that part of the 
uncialis population in OK and CO when it appears that this species 
has other subspecies in CO and WY.)

Chip
-- 

Monarch Watch
e: monarch at ku.edu
w: http://www.MonarchWatch.org/
Dplex-L: send message "info Dplex-L" to Listproc at ukans.edu
p: 1 (888) TAGGING (toll-free!) -or- 1 (785) 864 4441
f: 1 (785) 864 5321
usps: University of Kansas, Entomology Program, 1200 Sunnyside 
Avenue, Lawrence, KS 66045-7534 
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