13 March 2025, San Francisco: Yesterday the Center for Food Safety (CFS) filed comments urging the U.S. Fish and Wildlife Service (FWS) to finalize its recent proposal to list monarch butterflies under the Endangered Species Act (ESA). The organization also submitted dozens of supporting scientific studies and sources, spearheaded a group sign-on letter joined by fifty conservation organizations, as well as over 16,000 individual comments from individual CFS members.
The once-abundant orange-and-black butterflies have suffered catastrophic declines, with recent counts showing populations at near-record lows. For example, the western monarch population was counted at 9,119 monarchs in 2024, a stunning 96% decrease from the 233,394 counted in 2023 and the second-lowest count since monitoring began in 1997. Meanwhile, for each of the last six years the population of eastern monarchs that execute the remarkable fall and spring migration to and from their Mexican overwintering grounds has remained at less than half the size monarch scientists say is needed to mitigate the risk of extinction. CFS’s groundbreaking 2015 report Monarchs in Peril first highlighted the causation of their dramatic decline by genetically engineered herbicide-resistant crop systems.
“The monarchs’ tragic collapse represents a damning indictment of industrial agriculture and pesticide use,” said George Kimbrell, legal director at the Center for Food Safety. “This proposed listing is a landmark victory resulting from a decade of advocacy, but our work isn’t finished. FWS must prioritize Monarchs’ survival not Monsanto’s profits.”
CFS’s decade-long battle for monarch protection began in 2014, when the organization, along with the Center for Biological Diversity, Xerces Society, and renowned monarch biologist Dr. Lincoln Brower, petitioned FWS to protect the iconic butterflies under the ESA. After years of delay and litigation to force decisions, monarchs were finally placed on the candidate waiting list for protection in 2020 and then formally proposed for listing in December 2024.
In its comments CFS is calling on FWS to:
Finalize ESA protection of monarchs and account for all the pesticide drivers of their decline. In the ESA listing, protect Monarchs from herbicides and insecticides Designate critical habitat for both the western and eastern monarch populations.
“The science is clear: herbicides like glyphosate have decimated milkweed, the monarch caterpillar’s sole food source, on cropland throughout the eastern population’s critical Midwest breeding range,” said Bill Freese, Science Director at CFS. “Meanwhile, drift-prone herbicides like dicamba kill or impair reproduction of flowering plants that adult monarchs need for nectar, and insecticides like neonicotinoids poison monarchs directly. We can’t protect these butterflies while giving a free pass to the very pesticides driving their decline.”
Monarchs face multiple threats in addition to pesticides, including habitat loss due to development, climate change disrupting migration patterns, and millions killed by vehicles annually during migration.
In Canada, monarchs were listed as endangered under the Species At Risk Act in 2023. In Mexico, they are considered a species of special concern. The International Union for Conservation of Nature ranks them as vulnerable.
The ESA has proven 99% effective at preventing the extinction of species under its protection. Finalizing threatened status for monarchs would provide not only protection from harm but also a comprehensive recovery plan and ongoing funding to restore their habitat.
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