UPDATE: In December 2024, the United States Fish and Wildlife Service proposed listing the monarch butterfly as "Threatened" under the Endangered Species Act (ESA), which would offer federal protections. GCSAA weighed in with public comments on that rulemaking and you can read the comments below. However, in late 2025, the agency delayed the final decision, reclassifying it as a "long-term action," pushing a final ruling potentially to late 2026 or beyond.

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.