Endangered and Threatened Wildlife and Plants; Endangered Species Status for the Eastern Regal Fritillary, and Threatened Status with Section 4(d) Rule for the Western Regal Fritillary

Insecticides are a serious threat to the continued survival of the regal fritillary. The proposed rule does not adequately describe or address this threat. The final rule must rely on the best available science when making listing decisions based on the known threats to the species. This comment provides a supplementary study that was not included in the comments sent by the Center for Biological Diversity and WildEarth Guardians. Deynze et al. (2024) showed that insecticides explain more of the decline in richness of Midwestern butterflies than other threats from land use, climate, and herbicides. Neonicotinoids and neonicotinoid treated crop seeds, in particular, stood out as the most impactful groups among insecticides. EPA has not fully consulted on any neonicotinoid insecticide and consultations are not expected to finish before the regal fritillary is listed. In the absence of full consultation on these and other insecticides, the final listing decision must do more to protect the regal fritillary. Additional 4(d) rules that would protect known locations are necessary and advisable for the protection of this species.

Filed on regulations.gov — full text not in the inline record.