Rose Franklin's Perennial & Butterfly Farm

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Plausible Negative Consequences of Protecting the Monarch under the Endangered Species Act

                                                                                                                                                                                            by Rose Franklin        February 15, 2024 

On August 26, 2014, a petition was filed with the U.S. Secretary of the Interior, through the United States Fish and Wildlife Service, to protect the Monarch butterfly under the Endangered Species Act. The petitioners (The Center for Biological Diversity, Center for Food Safety, The Xerces Society, and Dr. Lincoln Brower) state that the North American Monarch population has declined by more than 90% in the past two decades and may be threatened with eventual extinction.

I, like most butterfly enthusiasts, am highly concerned by the drastically reduced number of Monarchs. But I wonder if adding the monarch to the Endangered Species List will help or hinder the Monarch population. I wonder, too, if listing the monarch as an endangered species might, to an even greater extent, deprive humans of its majestic beauty and further increase the distance between mankind and nature. Once a species is listed on the Endangered Species List, it is generally illegal to even touch this species.

Entomologists agree that the most significant reason for the plummeting drop in the Monarch population is that milkweed is being destroyed at an alarming rate on agricultural grounds, where it once grew wild in abundance. Milkweed is vital to the Monarch, for it is the host plant for Monarch larvae. Without milkweed to feed the caterpillars, the butterfly cannot complete its lifecycle and thus, the Monarch population cannot survive.

Since 1996, when genetically-modified, Roundup-Ready crops were introduced, milkweed has been rapidly disappearing from farmland. Farmers are now able to plant seed without having to first till the soil, and then spray their fields with Roundup to control the weeds. The herbicide kills the weeds (including milkweed) but does not harm the crops. While only Roundup-Ready soybeans were available in 1996, today the list of genetically-modified crops includes soy, corn, canola, alfalfa, cotton, sorghum, wheat, and sugarbeets. Well over 90% of the corn and soy being planted in the U.S. today are Roundup-Ready varieties, and there certainly appears to be a direct correlation between the use of Roundup-Ready crops and the destruction of milkweed in rural North America. And most of the scientific community seems to be in agreement that the loss of milkweed has likely resulted in the alarmingly low number of Monarchs.

Out of concern that an iconic species might become extinct, the Endangered Species Act was passed by Congress in 1973. The most serious threats to endangered animal species have traditionally been shooting, poisoning, and trapping. To address these concerns, Section 9 of the Endangered Species Act states that it would be unlawful for any person “to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, or collect” the species in danger of extinction. Known as the “take clause,” Section 9 makes it illegal for people to take the threatened species from the wild. The government extended the “take clause” to sometimes include the “taking of habitat which harbors, or could harbor, the endangered species.”

If the monarch is added to the Endangered Species List, it will then be illegal for anyone to take a Monarch from the wild, and if the Fish and Wildlife Service determines at some point that milkweed is critical to the Monarch’s survival, it may be illegal to harm, wound, or kill a milkweed plant also.

The petitioners say they recognize the valuable roles that citizen scientist monitoring and tagging, and classroom and in-home rearing of monarchs play in monarch conservation and hence request that upon Endangered Species Act listing, the Fish and Wildlife Service facilitate or waive permitting requirements for teachers and citizen scientists, so long as their rearing endeavors are limited to raising 10 or less monarchs per year.

How likely is it that the Fish and Wildlife Service would allow teachers and citizen scientists to rear Monarchs in the home or in the school if the Monarch is added to the list? Not very likely at all! Rarely, very rarely, has the Fish and Wildlife Service granted exceptions to the “take clause” and permitted the general public to take the listed animal from the wild and raise it in the home or in the school. If the Monarch is indeed listed as a threatened species, it will likely be illegal for any U.S. citizen (except for university professors who are studying the insect) to harass, harm, pursue, wound, kill, trap, capture, or collect Monarchs. It will almost certainly be illegal to collect any number of Monarch eggs, caterpillars, pupae, or adults from the wild.  

Some teachers and citizen scientists, rather than collecting Monarch eggs and/or caterpillars from the wild, purchase them from commercial butterfly breeders, the industry that often provides adult Monarchs for release at weddings, anniversaries, open houses, memorial services, and fund-raising events. The petitioners, however, ask that all commercial breeding of Monarchs be prohibited. Why? Because they somehow concluded that commercial breeders were raising and releasing millions upon millions of Monarchs per year, potentially interfering with scientific studies on the distribution and movement of wild Monarchs which, the petitioners claim, are increasingly important in light of habitat loss and climate change. In reality, commercial butterfly breeders produce significantly less than 10% of the number of Monarchs that the petitioners suggested they do, even if the petitioners' "millions and millions" meant only two million. Nonetheless, if the Monarch is added to the Endangered Species List, and if the petitioners' request is granted by the Fish and Wildlife Service,  there will be no commercial breeders for teachers and citizen scientists to obtain their ten or less Monarch eggs and/or caterpillars from (should they be unable to find them in the wild). And as I stated previously, is is highly doubtful that the Fish and Wildlife Service would make an exception to the "take clause" and allow Monarchs to be reared in the home or in the school anyway.

Personally, I would be saddened to think that citizen scientists and school teachers would be forbidden from raising Monarchs, thus denying children the rewarding experience of observing the miraculous Monarch metamorphosis first-hand. Watching a Monarch caterpillar chewing on milkweed is like watching a child chew on an ear of buttered sweet corn. Seeing a caterpillar pupate is nothing less than amazing, and witnessing the emergence of a majestic Monarch butterfly from its chrysalis is simply mystical.  

I would also be saddened to think that brides would be deprived of large, beautiful, brightly colored Monarchs on the most important day of their lives, and that those mourning the loss of a loved one might have to compromise for small, fast-flying, zig-zagging Painted Ladies instead of graceful, ballerina-like Monarchs. Everyone knows and loves the Monarch, and everyone wishes to have Monarchs released at their special event. And Monarch releases are an environmentally-friendly alternative to throwing rice and/or releasing balloons at weddings and other special events.

For many people, a butterfly release is their first close-up encounter with a live butterfly. In releasing Monarchs, people, often for the first time, experience the amazing, relaxing, mesmerizing feeling that butterflies bring to humans. Many people leave the butterfly release with a goal of attracting Monarchs to their gardens. Some newlyweds send a packet of milkweed seeds home with every guest. If Monarch releases are banned by the Fish and Wildlife Service, all the people who have experienced the joy of a Monarch butterfly release will know that others are being deprived of something quite spectacular, an experience that is beautiful and peaceful, and brings people a little closer to nature.

With so many U.S. citizens now aware of the fact that Monarchs are dwindling in number because milkweed is rapidly disappearing from the agricultural landscape, many are eager to aid the Monarch in its quest to multiply. Americans have, in the last few years, begun to plant milkweed seeds and plants by the tens of thousands. I know this to be true because I operate a perennial nursery and have watched milkweed sales skyrocket in recent years. And because the Monarch has an enormous fan club, I have no doubt that milkweed sales will continue to rise in coming years, in my nursery, and in hundreds more across the nation.. Milkweed might be vanishing from rural farmland, but it is popping up in home gardens, in city parks and state parks and national parks, along nature trails, and in botanical gardens. Within a few years, I suspect we will see that milkweed hasn't disappeared, but instead, was simply redistributed. And with a dramatic increase in the number of milkweed plants will come an increase in the number of Monarchs, this assuming, of course, that droughts, floods, and violent storms don’t take their toll on the population.

The Monarch is no more at risk of extinction than many other butterfly species. Those of us who garden for butterflies have watched the population of most butterfly species dwindle over the past few decades. Yes, the Monarch population has dwindled but so too have the numbers of other butterfly species dropped dramatically.  

It is widely accepted that  (1) the loss of habitat, and (2) the overuse of insecticides and herbicides are the two factors that have contributed most to the diminishing butterfly population. Here in the northeast, millions of woodland butterfly larvae have likely been killed by aerial spraying that was intended to control the gypsy moth population. Here and elsewhere, insecticides aimed at controlling mosquitoes and other pestilent insects have probably wiped out thousands, and in all likelihood, millions, more butterflies. Butterflies were not the intended targets of the insecticide spraying, but they have certainly suffered the consequences.  

I think the Monarch is fortunate in having an audience that is alert to its needs and is willing to aid it in its time of need. Other butterfly species are not so blessed. My opinion is that the Monarch should not be listed as a Threatened Species. Listing it will not likely increase its numbers and may actually decrease their numbers. Planting more milkweed will most assuredly increase the population. Listing the Monarch will likely make it illegal to raise Monarchs in the home and in the classroom, illegal to release Monarchs at weddings and other special events, and illegal to take  Monarch eggs, caterpillars, chrysalises, or adults from the wild for any purpose (including education and display). Maybe Monarchs will even have to be removed from butterfly houses and other such public displays too.

Instead of supporting the petition to list the Monarch as an Endangered Species, let’s all just plant more milkweed. I feel assured that will more quickly increase the monarch numbers.  

 Originally it was thought that the U.S. Fish & Wildlife Service would rule on whether the Monarch would be added to the Endangered Species List within a few years of the petition being filled in 2014 but the U.S. Fish & Wildlife put this decision on the back burner as there were too many other rulings to be made about animal species that appeared to be more threatened than the Monarch. It's now been over ten years since the petition was filed and a decision has still not been made---but the petition is still there and a ruling should one day be made. 
It is my hope that the Monarch is NOT added to the Endangered Species List. If it is, we and other butterfly farmers will no longer be permitted to ship monarch eggs, caterpillars, pupae, or adults to our customers. None of us, not me and not you, would likely be permitted to raise monarchs during the summer. School teachers would no longer be allowed to raise monarchs in the classroom and activity directors would no longer be permitted to grow Monarchs in summer camps, day cares, or in nursing homes. Only a few select universities would likely be permitted to raise and study Monarchs while the rest of us could only watch them from afar.  
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Added March, 2026: My husband and I are turning 75 and 80 years old this summer, both have some health issues, and want to sell the business and retire. Until the U.S. Fish & Wildlife Service makes it's decision on whether the Monarch is going to be added to the Endangered Species List though, we consider it is both unethical and unfair to sell the business. If the Monarch is added to the Endangered Species List and Monarchs are no longer permitted to be sold and reared, Monarchs-And-Milkweed.com won't be of much value to whomever owns it at that point. So until that decision is made, Andy (my husband) and I feel stuck right here, growing, selling, and shipping Monarchs.
          Rose Franklin

Written by me (Rose Franklin) in May, 2025, and added to the web site then:

The U.S. Fish & Wildlife Service is proposing to add the Monarch butterfly to the Endangered Species List as a threatened species and if listed, intends to limit the number of monarchs that can be sold per year by butterfly farmers like myself. 

If the U.S. Fish & Wildlife Service lists the Monarch as an endangered species it is being proposed that these rules will apply: (1) no more than 250 monarchs could be reared per year by any individual or by any facility, (2) that no more than 250 monarchs per year could be sold from any facility (like a butterfly farm), and (3) monarchs would not be permitted to be shipped across any state line.  

Since we often ship more than 250 monarch larvae per week (and sometimes as many as 250 per day during our busy season), we'd be able to ship monarchs one or two days per year. We’d only be able to fill 25 orders of 10 caterpillars, and all of those orders would have to ship to Pennsylvania addresses (since that’s the state we reside in and shipping to other states would be illegal). Upon receipt of the first 25 Pennsylvania orders, our shopping cart button would have to be removed from the web site and all our other monarch customers turned away.  

If the U.S. F&W Service prohibits butterfly farmers from shipping more than 250 monarchs per year and also deems it illegal to ship monarchs across the state line, hundreds of teachers will likely be unable to obtain monarch larvae for their classrooms. Many home hobbyists will also have no access to monarch larvae.

The reason the U.S. F&W Service doesn't want the monarch to be reared in large numbers is due to the fear of having diseased butterflies introduced into the wild. I understand that concern but wonder if putting butterfly farmers out of business wouldn’t have a negative impact on the monarch population.

There are only a few dozen commercial butterfly farmers (also known as butterfly breeders) in the entire United States. As is the case with any profession, there might likely be a few, very few, butterfly farmers who lack the knowledge, skill, integrity, and/or ethics to produce high quality butterflies. Most, however, adhere to stringent standard operating procedures which facilitate in producing a high-quality product.  

At a butterfly farm, adult butterflies are protected from predators and monitored to assure their environmental and nutritional needs are being met. Larvae are protected from predators like ants, wasps, and Tachinid flies. The butterfly pupae are protected from Chalcid wasps whose larvae will parasitize the developing butterflies and kill them. Most commercial butterfly farmers sanitize everything that comes into contact with the butterfly eggs, larvae, and pupae. Even the milkweed being fed to the larvae is sanitized prior to use.  

Professional butterfly farmers are generally better butterfly caretakers than Mother Nature herself. And all this extra care is highly appreciated by the retail customers who purchase their eggs, larvae, pupae, and/or adults.

Most school teachers know that not only are monarch eggs and larvae difficult to find in the wild but also often infected with disease. When attempting to teach the miraculous life cycle of a monarch, it’s disheartening for both the teacher and his or her students to see white fly maggots dropping from their freshly-pupated monarch caterpillars, caterpillars which will now die and decay inside the pupae and thus, produce no majestic monarch adults. And from mid-August thru early September (when most teachers raise monarchs in the classroom) a lot of the wild larvae are tainted with Tachinid flies.

If butterfly farmers are only permitted to sell 250 monarchs per year, there will be hundreds of teachers unable to obtain caterpillars for their classrooms. And from what I’ve been told by the teachers who have been raising monarchs in the classroom for a number of years, many of their students become adults who protect and/or grow milkweed on their properties, this a direct result of raising monarchs in the class room when they were young.

Here's my issue with adding the monarch to the Threatened List. The monarch is by far not the only butterfly species that is losing ground in its struggle to survive. Most butterfly species, in fact, have dramatically declined in number over the past 40 years. From my observation the monarch is no worse off than many other butterfly species.  

The monarch though, is the butterfly used in classrooms for rearing projects and if teachers won't be allowed to have monarchs, they will most likely have no butterflies for their unit on butterfly life cycles (metamorphosis). Swallowtails won't work for fall rearing projects because they overwinter as pupae---and the pupae can't be overwintered in a classroom because classrooms are much too warm. Many butterflies use trees as hosts and trees can't easily be taken into classrooms either. 

I'm nearing retirement age (well actually, past it already) so it's not just that I am upset about losing the income from monarch sales. I am worried that if teachers can't have monarchs in the classroom, kids won't have that exposure to nature----and sadly, kids (except for Amish kids) are becoming less absorbed in nature with every decade that passes.

Comparing the Monarch population to that of other butterfly species over the past 20 years

                                                                                                                                                                      by Rose Franklin,   May, 2025  

Recently the results of the first national analysis of U.S. butterflies concluded that these majestic creatures are disappearing from the national landscape at a ‘catastrophic’ rate. The lead study author was Collin Edwards, an ecologist and data scientist at the Washington Department of Fish and Wildlife. Nick Haddad, an entomologist at Michigan State University, was a co-author.

A compilation of 76,957 surveys from 35 monitoring programs were blended together for the analysis. The surveys were conducted by scores of volunteers who spent hundreds of thousands of hours over the past several decades of summers counting the various butterfly species in their local areas, this according to Edwards. Then Edwards, Haddad, and a team of over 30 butterfly researchers combined and analyzed all the surveys. The study included over 12.6 million recorded butterfly sightings over the past two decades.

The conclusion of this countrywide systematic analysis was that the number of butterflies in the contiguous U.S. has decreased by 22% between 2000 and 2020. Many of the species included in the study declined by 40% or more. The Red Admiral is down by 44% and the American Lady butterfly decreased by 58%. Even the invasive Cabbage White, a butterfly species whose larvae feed on cabbage, broccoli, and cauliflower, fell by an astonishing 50%.  

According to Edwards and Haddad, climate change, habitat loss, and insecticides have likely worked together to weaken our butterfly populations. And based on previous research from the Midwest, it appears that insecticides are the biggest culprit.  

Now let’s compare the population decreases from the national analysis of U.S. butterflies to the population decrease of the Monarch butterfly to determine if the Monarch warrants being added to the Endangered Species List as a threatened species.

The Monarch population has been monitored at the Mexican over-wintering grounds since the winter of 1994-1995. To measure the population, scientists record the total number of hectares that are occupied by Monarch colonies. For reference, one hectare equals approximately 2.47 acres.

During the winter of 2000-2001 the total area occupied by Monarch colonies at the over-wintering sites in Mexico was 2.83 hectares. During the winter of 2020-2021 the total area occupied was exactly the same, 2.83 hectares. But those figures are not the numbers presented in the arguments for adding the Monarch to the Endangered Species List.

Instead the proponents usually compare the winter of 1996-1997, the year the population was at its highest in recorded history, to a more recent year. During the 1996-97 winter, 28 years ago, Monarchs covered 18.19 hectares of Mexican mountainside. Comparing that winter to the winter of 2020-2021 the proponents calculate that the Monarch population has decreased by 88% since 1996-1997. What the proponents fail to publicly recognize is that the population of 1996-1997 was extraordinarily large, far above the average population size over the last 30 years of recorded history.

Even if we don’t compare the Monarch populations of 2000-2001 to 2020-2021 (which were exactly the same at 2.83 hectares) and instead use the 20-year average between 2000 and 2020, which was 4.40 hectares, the Monarch population of 2020-2021 has decreased by 52%, which closely compares to the 20-year decrease in the population size of the Red Admiral, American Lady, and Cabbage White.

I hope the U.S. Fish & Wildlife Service decides against adding the Monarch to the Endangered Species List and denying Monarchs to be used for school rearing projects, summer nature programs, festival and fair exhibits, butterfly releases, etc., the Monarch will be removed from the human-to-nature connection and ultimately, people will no longer understand the monarch-milkweed connection. Unless people associate the Monarch with milkweed, few people will aspire to grow and/or protect existing patches of milkweed. So long as there is a human-to Monarch connection, the Monarch will be blessed with stewards who protect its needs.

I'll have memories of when my husband and I took monarch eggs, larvae, pupae, and adults into preschools and elementary schools and taught about the butterfly life cycle as hundreds of children listened attentively to our words. We even did this in a few Amish schools and always, in every school, did it free of charge. I'll have memories of when we voluntarily took adult monarchs to nursing facilities and allowed each resident to hold a monarch, look at it closely, and then release it. 

Plant milkweed for them to lay eggs on. One of the milkweeds they highly favor for egg-laying  is Tropical Milkweed (Asclepias curassavica), a South American native that must be treated as an annual in most of the U.S. In September and October, Tropical Milkweed provides nectar for the Monarchs that are migrating to Mexico.

Plant nectar plants for the adult Monarchs to feed on. Butterfly bushes (Buddleia davidii), Purple Coneflower (Echinacea purpurea), Meadow Blazing Star (Liatris ligulistylis), Milkweed (Asclepias), and Zinnia are among their favorite nectar sources.

Refrain from using insecticides and herbicides on your property.  Remember, butterflies are insects that might be harmed by the insecticides you use, and herbicides might kill plants that are vital to butterfly  survival and reproduction.

Work to protect natural Monarch habitats (areas containing milkweed and wildflowers that can be utilized for nectaring) from being disturbed or forever destroyed.

Donate to Monarch Watch or another organization dedicated to the conservation, education, and research of Monarch butterflies.

The Monarch Migration

I, Rose Franklin, created the 'Save the Monarch' brochure to educate the public on the obstacles facing the Monarch and urge readers to assist the Monarch in its struggle to multiply.

The brochures were printed by a commercial printer on high-quality, heavy weight, semi-gloss paper and thus, are attractive and professional in appearance. They were printed on 8 1/2" X 11" stock, were pre-folded, and ready to hand out.

We are now sold out of the brochures and have no intention of getting more printed. I will send the PDF to any organization that would like to print the brochure for distribution. I highly suggest you print the brochures on 24#, simi-gloss paper. Just send me an email and MilkweedLady@aol.com and ask for PDF.

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Rose Franklin's Perennials
107 Butterfly Lane      Spring Mills, PA 16875