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Monarch CCAA

Enroll now. Avoid restrictions later.

The Monarch CCAA locks in today’s terms through our SMART-ROW process. The window closes the day the listing lands.

Check your eligibility

Where the listing actually stands

The agency missed its own deadline, took the rule off the calendar, and is now being asked by a federal court to set a new one.

Dec 2024
USFWS proposes listing the monarch as threatened, with a 4(d) rule and designated critical habitat.
Dec 2025
The statutory one-year deadline for a final determination passes with no decision.
Jan 2026
Interior moves the rule to “long-term actions.” No new date is set. The proposal is not withdrawn.
Feb 2026
Two conservation groups sue USFWS to compel a binding deadline. The case is still open.

Current as of September 2026. We update this page as the case moves.

Compliance and cost pull the same lever

The conservation measures the agreement requires are integrated vegetation management. Meeting the requirement is the thing that lowers your cost.

0

Days of guaranteed notice

New applications to the nationwide Monarch CCAA close the day the monarch is listed. Not at announcement, not after a transition period. Applications already submitted can still be processed. New ones cannot start.

USFWS Monarch CCAA FAQ · CBD/CFS v. USFWS, N.D. Cal., filed 2/12/26
30%

Lower long-term program cost

Targeted treatment suppresses woody regrowth at the root instead of cutting it back every cycle. Independent analysis puts planned IVM at $1,412 per acre over twenty years against $3,114 for mowing only.

Goodfellow, The Cost Efficiency of IVM, TREE Fund / Utility Arborist Research Fund
2023

The year the bat’s 4(d) rule stopped existing

The northern long-eared bat was reclassified from threatened to endangered. Endangered species don’t get 4(d) rules, so the streamlined rule covering routine maintenance didn’t survive. One utility anticipated up to 30,000 new consultations a year on routine ROW work.

USFWS final rule and effective-date notice · National Grid, via USFWS

Same right of way. Two management approaches.

The conservation measures the agreement requires are the same practices that stop paying to clear the same acre twice.

Right of way mowed on a schedule with woody regrowth returning
Mowed on a scheduleCut it back, watch it return. The root system is untouched, so next cycle costs what this one did.
Right of way managed with integrated vegetation management, native cover established
Managed on a planTargeted treatment suppresses woody species and lets native cover establish. Lower cost, cleaner access, and it satisfies the agreement.

We handle all of it

Most operators don’t disagree about the monarch CCAA. They just don’t have a spare person to run a federal enrollment on top of everything else.

01

Application & certificate

02

Habitat assessment

03

GIS mapping

04

IVM plan

05

Mowing & trimming

06

Monitoring & reporting

And we keep doing your ROW mowing and trimming exactly like we always have.

Questions operators ask

It keeps getting delayed. Why would we move now?
The delay is the risk. The agency blew its own deadline and took the rule off the calendar, and now a federal court is being asked to set one instead.
When the agency owned the date, you’d have seen it coming. Now a judge may set it, and the enrollment window closes the day it lands. You can’t file after.
The 4(d) rule will cover our maintenance work anyway.
Two problems. The proposed 4(d) rule didn’t settle ROW treatment. USFWS explicitly asked for comment on whether to include an exception for energy and transportation infrastructure, so that’s an open question, not a protection. And 4(d) rules only exist for threatened species.
Ask the folks who were relying on the bat’s 4(d) rule in March of 2023 how that held up.
This is a conservation program. It’s going to cost us and tie our hands.
The required measures are IVM: targeted herbicide, adjusted mowing timing, native seed. That isn’t new spend on top of your maintenance budget. It’s the maintenance budget, redirected to the lever that actually suppresses regrowth.
You’re already paying for this ground to be managed. The agreement just says do it the way that costs less.
We don’t have anybody to run a federal enrollment.
That’s the offer, and it’s the part most contractors can’t match. Application and certificate of inclusion, habitat assessment, GIS mapping, the IVM plan, mechanical mowing and trimming, ongoing compliance monitoring and reporting, folded into the ROW work we’re already doing on your system.
You sign. We handle the rest. And we keep mowing and trimming for you exactly like we always have.
Herbicide is a hard sell with our landowners.
Backwards, and worth saying plainly. Broadcast mowing is what keeps a right of way in brush. Targeted herbicide is what lets the native flowering community establish, which is the outcome the landowner and the sustainability report both want.
Enrollment gives you something to show them: a federal conservation agreement on the ROW running through their property, and ground that looks like prairie instead of stumps.
What if we enroll and the monarch never gets listed?
Then you spent five years running a program that takes at least 30% off your long-term vegetation cost, and the regulatory insurance was free.
There’s no version of this where the vegetation work doesn’t pay for itself. The listing just decides whether it also saved you a permitting problem.

We are inside this program, not selling around it

200+
Partner and sponsor, ROW as Habitat Working Group

The University of Illinois Chicago group that administers the Monarch CCAA, representing more than 200 organizations across energy, rail, and transportation.

rightofway.erc.uic.edu
20
Years applying herbicide on right of way

Licensed applicators since 2007, across 48 states. The conservation measures this agreement requires are the work we already do.

1.3M
Acres already enrolled nationwide

More than 100 organizations across 47 states have committed acreage. The program has a finite cap, and peers are moving.

See the program
Brent Oberlink, President of Lanracorp

“Most contractors will tell you this is somebody else’s problem. We’ll do the enrollment, the mapping, the plan, the monitoring, and keep mowing your right of way like we always have.”

Brent OberlinkPresident, Lanracorp · Applying herbicide on right of way since 2007

Find out if your system qualifies

Before someone else sets the deadline. Tell us the basics and we’ll come back with what enrollment would look like on your system, and what it would cost to run.

Check your eligibility

Four fields. No sales deck.