Mr. Wayne F. Wehling USDA-Aphis PPQ PRA Unit 133 4700 River Road Riverdale, MD 20737 Re: Objections to Interstate Shipment of Commercially-Raised Butterflies Dear Mr. Wehling: I am a member of the St. Louis Chapter of the North American Butterfly Association (NABA). NABA is a national organization that promotes butterfly watching, gardening, and conservation. I view the interstate shipment of commercially-raised butterflies as harmful to local butterfly populations, for the reasons set forth in this letter. The risk of harm to butterflies, which are important plant pollinators, outweighs the recreational benefit of being able to buy and release butterflies at weddings and other social events. I therefore urge the USDA to PROHIBIT all interstate shipment of commercially-raised butterflies intended for release. 1. Release of commercially-raised butterflies may spread diseases and epidemics to local butterfly populations. The most important reason not to allow interstate shipment of commercially-raised butterflies is the unintended consequence that the commercially-raised butterflies will introduce disease - whether fungal, bacterial, or viral - into the local population of butterflies. This risk outweighs any potential benefit from allowing releases of commercially-raised butterflies, which are primarily for recreational purposes (weddings, etc.). All known biological organisms are affected by diseases and parasites. We do know that there are many species of viruses, bacteria and fungi that cause diseases in butterflies. Such diseases have been found to be prevalent in shipments of commercially-raised butterflies. Because butterflies are such an important link in the pollinator/plant chain, it is not prudent to take any chances of spreading disease to local butterfly populations by allowing interstate shipments of commercially- raised butterflies. 2. Interbreeding of commercially-raised butterflies with local butterflies will threaten the survival of local butterfly populations. Genetic problems will occur when commercially-raised butterflies of one species breed with local individuals of the same species. On the surface, it may seem that a butterfly of one species is the same as any other butterfly of that species. But genetically, that is not the case. When these differences are examined carefully, it is obvious that interstate shipments of butterflies has serious, negative impacts on local populations which could be irreversible. For example, not all Monarchs are the same. The Western subspecies of Monarch does not migrate in the same way that the Eastern subspecies does. The Eastern subspecies is known for its tremendous feat of migrating to the mountains of central Mexico in the winter. The Eastern Monarch definitely has genes for migration, genes that tell the butterfly exactly where to go - because the Monarch that flies south to Mexico in the winter is not the same butterfly that flew north in the spring. Rather, the Monarch that flies south in the winter is an offspring of the Monarch that migrated back to the U.S. in the spring. That means that some genetic code is telling the Monarch what to do. It is also called "species intelligence or memory" and it is passed on from one generation to the next in the genes. The Western Monarch does not have that genetic code, because the Western Monarch does not fly to Mexico. What will happen when commercially-raised Monarchs from California interbreed with Monarchs in the eastern part of the united States? Mixing the genes from the Western and Eastern subspecies of Monarch may confuse the migration mechanisms. 3. Introduced butterflies will put further stress on butterfly populations which are already in decline. The introduction of large numbers of commercially- raised butterflies has other negative impacts on local butterflies, besides disease and interbreeding. The released butterflies would directly compete with local butterfly individuals for both habitat and food resources. Local populations, already on the decline and stressed by loss of habitat and pesticide/herbicide spraying, would be even more stressed if they have to compete with large numbers of introduced butterflies, even though they are all of the same species. 4. Scientific surveys of butterfly populations are skewed by released butterflies. Once a butterfly is released, it is not possible to distinguish it from a local butterfly. Scientists and amateur naturalists alike study and survey butterfly populations. The North American Butterfly Association sponsors the annual, nation-wide Fourth of July Butterfly Count, now in its 25th year. Similar to the 100-year old Christmas Bird Count of the National Audubon Society, the purpose of the butterfly count is to determine the status of butterfly populations in a given area and to monitor changes in those populations over time. When released butterflies are inadvertently counted, for there is no way to distinguish it from a butterfly that truly belongs in the area, such scientific surveys are skewed. Thank you for listening to my comments. __________________________________________ __________________________________________ __________________________________________