The monarch butterfly, likely the most famous butterfly in North America, will soon receive federal protections under the Endangered Species Act (ESA). In December, the U.S. Fish and Wildlife Service (FWS) decided that listing the monarch under the ESA as a threatened species was warranted, proposing a rule to list the species in the Federal Register on December 4.

This decision comes a decade after initial efforts by environmental groups (among them, the Center for Biological Diversity, the Center for Food Safety and Xerces Society) petitioned the agency to list the butterfly in 2014 and provided data about the decline of the monarch population. With Illinois included in much of the monarch’s migratory range, many challenges might face Illinois soybean farmers once this rule is finalized. A top concern is how the U.S. Environmental Protection Agency (EPA) will interpret the listing in light of recent changes to pesticide policy, such as the Vulnerable Species Action Plan, the Herbicide Strategy and other expected pesticide strategies the EPA is set to release in the next 12 to 24 months. Further, the listing, will require federal agencies to consult with FWS to avoid actions that might harm the monarch, meaning there could be unforeseen implications for farmers participating in programs from the U.S. Department of Agriculture and other federal agencies.

The U.S. Fish and Wildlife Service has 12 months to finalize the monarch’s listing as a threatened species. During this period, Illinois soybean producers can share their opinions regarding the decision, stressing the importance of balancing conservation needs with economic implications for farmers.

Threatened Listing
A species listed as “threatened” receives federal protections under the ESA similar to those of “endangered” species. However, under section 4(d) of the ESA, the FWS has the flexibility to create species-specific rules that include exceptions that minimize disruptions to agriculture. For example, the proposed rule includes exceptions for activities like habitat management (mowing and haying) and routine agricultural activities (plowing, disking, drilling, mechanical manipulation of the land). Concerningly, the FWS did not include an exception for agricultural pesticide use. Instead, they requested public comments specifically about whether the rule should include pesticide-specific restrictions or exceptions, and if the EPA’s current efforts are sufficient to protect the species from pesticide exposure.

The Role of Farmer Voices
The proposed listing and 4(d) rule have not been finalized. Following the announcement, the FWS opened a 90-day (Dec 12 to March 12) period for public comment. Farmers can read the proposed rule details, documents, and submit comments at www.regulations.gov by searching under docket number FWSR3-ES-2024-0137. Farmers looking for advice or guidance in offering public comments can contact me directly (corey.lacey@ilsoy.org) with questions. FWS has at least 12 months to collect and review public comments, analyze additional science and engage in discussions with stakeholders. Throughout this period, Illinois farmers can share their perspectives about the listing decision and rule, stressing the need for the agency to balance conservation needs with economic implications for farmers. State associations such as Illinois Soybean Growers will be working hard to understand and communicate the implications of the proposed listing to our farmers and relay those stories back to the FWS. It’s important to also share success stories illustrating how farmers already are working to conserve monarch butterflies and other pollinators on their farms.

What Can Soybean Farmers Do
While these rules are being finalized, there are some things Illinois soybean farmers can do:

1. Plant Milkweed and Nectar Plants: Milkweed is essential for monarch caterpillars. Planting native milkweed species provides critical habitat for their growth and development. Adult monarchs need nectar from flowers. Planting a variety of nectar-rich flowers supports adult butterflies throughout their lifecycle. Plantings can be made in field borders, near buildings and in other out-ofthe-way areas.
2. Pesticide Use: Illinois farmers should stay up to date on pesticide label changes as ESA mitigations begin appearing on labels moving forward.
3. Speak Up: Farmers can participate directly in public comment periods, webinars and listening sessions hosted by the FWS over the coming months. They can also become members of organizations such as Illinois Soybean Growers, which actively engages policymakers on behalf of Illinois farmers on this and other issues.

Milkweed is vital for monarch caterpillars, while nectar-rich flowers support adult butterflies. Planting both provides essential habitat and can be done in field borders, near buildings or in other unused areas.