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GCSAA submits comments on USFWS monarch butterfly listing proposal

May 27, 2025

The U.S. Fish and Wildlife Service (USFWS) is proposing to list the monarch butterfly as a threatened species under the Endangered Species Act (ESA), with a 4(d) rule that includes specific protections and flexibilities. The USFWS is also proposing to designate critical habitat for the monarch butterfly in specific areas in California. 

GCSAA submitted official comments to the federal docket on Monday, May 19. The association is requesting to secure a 4(d) exception. The 4(d) exception allows for specific, tailored exemptions from the general prohibitions of the ESA. It ensures that certain activities, like farming, ranching and golf course management (including pesticide spraying), can continue without major disruption, even if they might incidentally "take" monarchs (harm, harass or kill them). This flexibility is intended to encourage conservation and balance the needs of land managers with the need to protect the monarch butterfly. 

Please review the GCSAA monarch butterfly listing comments and reach out to Chava McKeel, director, government affairs, if you have additional questions.