[Pollinator] Bombus impatiens

[Matthew Shepherd (Xerces Society)]

I think it is worth pointing out that the paper on Bombus impatiens that David highlighted was one part of a proposal by Koppert Biological Systems, Inc. to allow release of B. impatiens into California for open field pollination. The California Department of Food and Agriculture (CDFA) published a Notice of Intent to adopt a Negative Declaration -- i.e., that the release of the non-native bumble bee will have no impact on the environment -- and the associated initial study under the California Environmental Quality Act (CEQA). The initial study included Joseph Sullivan's paper as an appendix. This proposal was released for public comment in December of last year, and many organizations and individuals from across North America submitted comments by the late-January deadline. The comments from CoEvolution Institute were especially strong and a good model for others. 

In brief, the Xerces Society opposed importation of Bombus impatiens, due to the many ecological risks and unknown outcomes of importing this bee. We strongly disagreed with the finding that the prescribed risk mitigation measures adequately addressed the significant ecological risks associated with importation, and believe that the proposed mitigation measures were fraught with vulnerabilities and should not be relied upon as a basis for allowing the importation of B. impatiens. The Society urged the CDFA Division of Plant Health and Pest Prevention Services not to approve the requested permit for importing Bombus impatiens. We believe that there should instead be a focus on the ongoing effort to identify and commercialize bee species that are native to California.

Robbin Thorp contributed greatly to our comments and we received good information from several other researchers, including Sarah Greenleaf and Cory Sheffield. We thank them and everyone else who assisted.

Our complete comments can be download as a PDF file from our web site, www.xerces.org.

Numerous people and organizations signed on to the Society's comments. In addition to Scott and myself, the signatories included:
Robbin Thorp, Ph.D., Professor Emeritus, University of California, Davis
Claire Kremen, Ph.D, Asst. Prof of Arthropod Biodiversity, University of California, Berkeley
Sarah S. Greenleaf, Ph.D., postdoctoral scientist, Department of Plant Pathology, University of California-Davis
Jim Lyon, Senior Vice-President, National Wildlife Federation, Washington D.C.
Gabriela Chavarria, Ph.D., Director, Science Center, Natural Resources Defense Council, Washington, D.C.
Kim Delfino, California Program Director, Defenders of Wildlife, Sacramento, CA
Cory S. Sheffield, Ph.D, Department of Biology, York University, Toronto, CN
Gordon Frankie, Ph.D, University of California, Berkeley
Peter F. Brussard, Ph.D., Department of Biology, University of Nevada Reno
John Losey, Ph.D., Professor of Entomology, Cornell University, Ithaca, NY
Boris C. Kondratieff, Ph.D., Professor of Entomology, Colorado State University, Fort Collins, CO
Vance Russell, Landowner Stewardship Program, Audubon California, Winters, CA
Amanda Jorgenson, Executive Director, California Native Plant Society, Sacramento
Kieran Suckling, Executive Director, Center For Biological Diversity, Tucson
Dan Silver, Executive Director, Endangered Habitats League, Los Angeles, CA
Emily B. Roberson, Native Plant Conservation Campaign, San Francisco, CA
Michael Klein, Entomologist, Klein-Edwards Professional Services
Scott Thomas, Conservation Director, Sea and Sage Audubon, Irvine, CA
Jess Morton, Treasurer, Palos Verdes/South Bay Audubon Society, Palos Verdes Peninsula, CA
Daniel R. Patterson, ecologist, Tucson AZ
Dave Werntz, Science and Conservation Director, Conservation Northwest, Bellingham, WA
Robert S. Jacobson, M.S., Entomologist, Lenoir, NC, San Diego, CA
Erin Robertson, Senior Staff Biologist, Center for Native Ecosystems, Denver, CO.

As a foot note, thanks to the efforts of everyone who submitted comments, it looks like the release of impatiens will not be allowed at this stage. CDFA has yet to officially respond to the submitted comments but the feeling is that the Negative Declaration will not be issued. The large number of submissions against the release and the significance of the issues raised in these submissions will likely mean a more detailed and extensive Environmental Impact Report will be required under CEQA.

Matthew 

PS. My apologies to those people who are getting this email twice. I posted to both the Pollinator and Bombus lists.
______________________________________________________
The Xerces Society for Invertebrate Conservation
The Xerces Society is an international nonprofit organization that 
protects the diversity of life through invertebrate conservation. To 
join the Society, make a contribution, or read about our work, 
please visit www.xerces.org.

Matthew Shepherd
Director, Pollinator Conservation Program
4828 SE Hawthorne Boulevard, Portland, OR 97215, USA
Tel: 503-232 6639 Cell: 503-807 1577 Fax: 503-233 6794
Email: mdshepherd at xerces.org 
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