[Pollinator] POLLINATOR ACTION ALERT: Comments needed on California import of Bombus impatiens

[Laurie Adams]

TO:      Pollinator Stakeholders
 
FR:       Tom Van Arsdall, on behalf of Laurie Davies Adams
 
RE:       Comments on Proposal to Import Non-Native Bombus impatiens Bumblebee into California for Pollination of Field Crops
 
COMMENT DEADLINE:       Friday, JANUARY 19, 2007
 
ACTION REQUEST:    Consider Submitting Comments!  We have confirmed that the California Department of Food & Agriculture (CDFA) will also accept comments filed via e-mail.  We suggest you prepare your comments as a Word [or pdf] document and attach to a transmittal e-mail to the attention of Jim Rains at jrains at cdfa.ca.gov.  
 
SUGGESTED KEY POINTS:
Personalizing your comments based on your own scientific expertise and experiences is most effective.  Following are some key points for your consideration:
 
* The applicant proposes to import a non-native species, Bombus impatiens, as a TEMPORARY to provide supplemental crop pollination services, until work on developing a native species commercially can be completed.
 
* The need for supplemental crop pollination services in California, at a level that would justify importation of a non-native species, has not been demonstrated by the applicant.  Alternative remedies, including an increase in the supply of honeybee hives have not been considered.
 
* Pollination services are important to California agriculture and healthy ecosystems.  The applicant and other interested stakeholders should focus on the ongoing effort referenced in the application to identify and commercialize appropriate native species.
 
* Risk mitigation measures that would be relied upon to prevent adverse ecological impacts are fraught with unanticipated vulnerabilities and should not be relied upon as a basis for granting the importation of Bombus impatiens.  
 
* The ecological risks and unknowns of this temporary measure are far too great to justify importing a non-native species, as adverse consequences could be irreversible.
 
* The CDFA Division of Plant Health and Pest Prevention Services should not approve the requested permit for importing Bombus impatiens.
 
ADDITIONAL BACKGROUND:
The Coevolution Institute (CoE) has prepared and submitted the attached.  These comments attempt to respond to the immediate issues raised in the application and then offer more broadly applicable policy recommendations that would help guide more informed decisions on such issues in the future.  Feel free to incorporate any points in your own comments.
 
NAPPC's structure and protocol prohibit submission of policy-related comments in NAPPC's name.  
 
However, the preparation of CoE comments benefited greatly from excellent input received from NAPPC volunteers.  Thanks in particular are due to Peter Kevan, Robbin Thorp, Liz Day and others.  
 
Comments don't need to be long to make a difference.  Pollinator stakeholders need to be heard.  
 
CDFA's decision in this proceeding could set a positive or negative precedent that will likely have future consequences for policies in California and other states.
 
Laurie Davies Adams
Executive Director
Coevolution Institute
423 Washington St. 5th
San Francisco, CA 94111
415 362 1137
www.coevolution.org
www.nappc.org
www.pollinator.org

Visit the above sites to register for the October 18
Pollinator Symposium at the USDA Jefferson Auditorium

Our future flies on the wings of pollinators.
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