As a potential Endangered Species Act listing of the monarch butterfly looms, a new federal conservation agreement negotiated by NRECA and other industry interests could offer co-ops regulatory certainty.
Through a Candidate Conservation Agreement with Assurances, a formal yet voluntary plan sanctioned by the U.S. Fish and Wildlife Service, co-ops can get credit for efforts they’ve already made to protect monarchs. FWS released the CCAA on April 15 for 60 days of public comment.
“The agreement provides a consistent approach to monarch habitat conservation across the continental United States but with a lot of flexibility built in so co-ops can tailor their activities to meet their specific needs,” said Stephanie Crawford, NRECA regulatory issues adviser.
“Those co-ops that have already been implementing pollinator-friendly projects and join the CCAA may not need to alter much [if the species is listed] except to monitor and track their work for purposes of the agreement.”
Under the agreement, FWS will offer special permits to participating landowners for certain limited activities that may result in incidental harm to the species.
FWS said it will decide by the end of June whether the monarch warrants federal protection. If listed, co-ops will have a year to sign on to the CCAA before conservation requirements take effect.
NRECA advocated for provisions in the CCAA that included securing a low administrative fee and permission for consortiums of co-ops, like a G&T and its member systems, to join and share costs. Actions already taken by co-ops that align with the conservation measures in the agreement will count toward committed targets.
Many co-ops in the monarch’s annual migratory path from Mexico to Canada have taken significant steps to conserve the distinctive orange-and-black-winged pollinator. Some have planted acres of milkweed—the only plant monarchs lay eggs on and feed on in the larvae stage—as well as nectar flowers for adult monarchs to graze on. These habitats lie in rights of way as well as around solar installations, headquarters and other co-op facilities.
Should FWS decide not to list the monarch as endangered or threatened, it would almost certainly be challenged in the courts, Crawford said.
“Such a development will lead to increased regulatory uncertainty for co-ops that choose not to proactively enroll in the CCAA,” she said.
FWS said the monarch agreement is the largest agreement of its kind ever, impacting all or parts of 48 states, and called it an “unprecedented conservation opportunity” for energy and transmission companies as well as state transportation departments.
The Butterfly Effect: Co-ops’ Proactive Pollinator Efforts Help Prepare for a Federal Listing of the Monarch