Somewhere in the southeastern United States right now, a boldly striped caterpillar is hatching from a pinhead-sized egg and beginning to fatten up on leaves.

Within a few weeks, the full-sized six-legged larvae will shed its skin and spin itself into a pale-green chrysalis that will dangle from a silk string for nearly two weeks.

Finally, an adult monarch butterfly will burst through, dry its familiar orange-and-black-veined wings, and take flight, heading north.

By mid-June, this first of four annual monarch generations will have reached the central U.S., where they will mate and lay their eggs on milkweed, the monarch’s only host plant and a critical link in its reproduction.

Around that same time, the U.S. Fish and Wildlife Service (FWS) will be completing a review of the monarch that could carry major implications for electric cooperatives in the path of this famously itinerant insect. The agency will announce whether the butterfly should be protected under the Endangered Species Act; a final decision would be due in June 2020.

“It will have a significant impact on co-ops if there is a fully endangered listing,” says Josh Young of East Kentucky Power Cooperative (EKPC), a G&T in central Kentucky whose service territory lies in the path of the monarch’s migration. “It will affect right-of-way management and site management of different facilities.”

Monarch butterflies sip flower nectar prolifically and are important pollinators for dozens of key plant species. They’re under threat from the eradication of milkweed, the perennial flowering plant where monarchs lay eggs, feed as caterpillars, and transform into adult butterflies. Milkweed is toxic and often considered a nuisance plant. Monarchs are also under pressure from habitat loss because of deforestation of their winter homes in Mexico and California.

Whatever the listing, threatened or endangered, NRECA will push for allowing electric co-ops to continue their outside activities, from vegetation management to new infrastructure construction.

“We want members to be proactive until then,” says Janelle Lemen, NRECA’s environmental regulatory issues director.

One way is to plant and maintain acres of milkweed and nectar plants. Another is to sign a Candidate Conservation Agreement with Assurances (CCAA), a voluntary pact that a coalition of companies and industries enter to blunt the impact of an FWS listing. To be effective, the agreement must be signed before a listing becomes final. Lemen says the draft CCAA is due out soon.

“The CCAA offers a win-win opportunity by giving regulatory certainty to co-ops proactively providing habitat on their systems regardless of whether FWS lists the monarch,” Lemen says.

As part of the CCAA process, NRECA can point to activities co-ops have already undertaken to support the species, including building pollinator gardens and any modifications made to herbicide applications and mowing in easements and rights-of-way, says Stephanie Crawford, an NRECA regulatory advisor who has been working to shape the CCAA.

Experts anticipate that the monarch will likely be listed. The severity of the designation will depend on the numbers.

The latest count of monarchs in Mexico, where millions overwinter each year, is positive. January reports found that populations this year have rebounded by as much as 144 percent above the 2018 count. The number that overwinter in California, however, is at a historic low. Other pollinators are also facing drastic population declines.

“Whether it’s the monarch or another species, the pollinator issue is not going away,” Lemen says.

'A part of doing business'

The monarch butterfly is the only insect that completes a round-trip migration. Some travel thousands of miles over their lifetime. Those that fly to Mexico will spend the winter there, then fly back north into the southeastern United States to reproduce in early spring, and then head farther north for the summer, sometimes into Canada.

To provide a way station on their migratory journey, Dairyland Power Cooperative, the LaCrosse, Wisconsin- based G&T, has built nearly 300 acres of pollinator habitat at solar farms, substations, and a capped coal ash landfill.

Brad Foss, Dairyland’s senior environmental biologist, says many members and the public have been vocal that the co-op should not only comply with environmental standards but go above and beyond.

“That’s part of why we are doing these pollinator projects,” he says. “Environmental stewardship is very important at Dairyland and to our members. It is an expected part of doing business.”

To prepare and seed a pollinator habitat can cost $2,500 to $5,500 per acre or more, depending on the plant varieties and the labor involved, Foss says. Annual maintenance is additional.

Steps involve treating the area with herbicide to remove invasive plant species, seeding the plot with native forbs and grasses, strategic mowing, spot spraying, weed whipping, and using controlled burns to keep non-native foliage at bay.

Foss notes that state agriculture and natural resources departments and companies that specialize in pollinator habitats and prairie restoration can be helpful when planning and growing plots to sustain monarchs.

“The key is to be proactive and collaborate with others with expertise and interest in the project,” he says.

'The new normal'

By mid-summer, generation two has emerged and found its way to the lower regions of the Upper Midwest. Like generation one, this brood is short-lived (less than two months), but it fulfills its critical role of mating and laying eggs.

Connexus Energy has long seen the value of pollinator plants in its rights-of-way and surrounding its solar energy facilities. Based in Ramsey, Minnesota, the state’s largest distribution co-op maintains about 55 acres of pollinator habitat, with the first planted in 2014 and the most recent in 2018.

Including such plots is now standard operating procedure when building solar energy facilities in Minnesota. Pollinators “are essential to Minnesota’s economy” and its $90 billion agricultural sector, the governor said in the state’s annual report.

“We are not as concerned about the impact of a listing because we have already adopted native plantings for our solar gardens,” says Brian Burandt, vice president of power supply and business development at Connexus. “Pollinator habitat is the new normal.”

Not only is it good for species conservation, but the practice helps reduce vegetation management costs, he says.

“If you don’t do anything, you will have noxious weeds that will grow 3 feet high and shade solar projects,” he says.

Each year, hundreds of Connexus members tour the pollinator-friendly gardens, which are also popular for their honey-making beehives.

'Citizens, neighbors, stewards'

Farther north, as summer days give way to autumn, a third and then a fourth generation of monarchs emerge. The year’s fourth brood has a special mission.

Wolverine Power Cooperative cultivates pollinator habitat along the rights-of-way of its 1,600-mile transmission network through minimal mowing, removing undesirable trees and shrubs, and spot applications of herbicide.

The G&T headquartered in Cadillac, Michigan, sows pollinator-friendly seed mixes during construction restoration activities and plans to incorporate milkweeds for monarchs.

“Electric cooperatives often go above and beyond federal and local environmental regulations in our commitment to being good citizens, neighbors, and stewards of our natural resources and wildlife,” says Wolverine Vice President Joseph Baumann.

An endangered or threatened designation of the monarch “can add a level of complexity to operations,” Baumann says, “but our commitment to environmental stewardship often positions us ahead of new compliance requirements.”

Wolverine Power works with FWS and other agencies to maintain habitats, establish additional habitats, and help re- establish threatened and endangered species’ habitats, he says. 
“Should the monarch butterfly be assigned an endangered status, we expect our current maintenance program and pollinator habitat growth practices to place us largely in compliance with its designation,” Baumann says. “Some further steps to protect the species we expect may include added restrictions on herbicides and access to our rights-of-way.”

Proactive approach

Days are shortening, and the fourth generation of monarchs does not linger to mate. Soon after they emerge from their pupa, they begin their mass southward migration. These butterflies will live long enough to fly to Mexico, spend the winter, and mate. Females then return to the U.S. the following spring to lay their eggs on southern milkweed and restart the cycle.

Monarchs stop and fuel up in Kentucky before completing their nearly 3,000-mile journey to warmer climates south of the border.

Some of their grandparents did the same on their spring migration north. That’s why EKPC plants a mix of pollinator-friendly nectar plants that blossom throughout the seasons of the monarch’s lifespan.

This year, the G&T will expand its monarch way stations at its headquarters in Winchester, Kentucky, and its Blue Grass and Spurlock generating stations. It will transition 10 acres of fescue to monarch habitat rich with milkweed and wildflowers like coreopsis, black-eyed Susan, asters, goldenrod, and ironweed.

“Early May through October, we will have flowers out there that will be food sources for monarch butterflies,” says Young, EKPC’s supervisor of natural resources and environmental communications.

Even with its proactive approach, an FWS listing would inject major operational challenges for EKPC. Without permits for summer herbicide application, co-ops may be left with mowing or even hand-clearing vegetation under their power lines—significantly more expensive methods than herbicide, he says.

“We typically maintain rights-of-way using herbicide during the summer when the plants are growing with leaves. It is a low-volume ‘backpack’ application,” Young says. “But if it is a full endangered listing, maintenance of that area in summer will be very hard to get approved due to the potential impacts.”

Whether the G&T pursues further voluntary mitigation by signing the CCAA has yet to be determined.

“Based on what happens in June, we will proceed with a better understanding of the mitigation and what the agreement fully includes,” Young says.

A deciding factor hinges on whether FWS decides that an impact on milkweed harms an endangered species.

“There are millions of milkweed plants that grow in our rights-of-way every year,” Young says. “If impacting one of those is considered having an adverse impact to an endangered species, if that is the case, then it is very, very concerning.”

Crawford says even if FWS stops short of recommending a protected status for monarchs, co-ops aren’t likely to diminish their stewardship work.

“They’re already providing valuable habitat for monarchs and other pollinators on their lands,” she says. “We’ll see this trend continuing.”