On January 19th 2007 The Xerces Society submitted comments on an effort to import the non-native Bumble bee (Bombus impatiens) for pollination of field crops in the state of California. The Xerces Society opposes importation of Bombus impatiens, due to the many ecological risks and unknown outcomes of importing this bee. We strongly disagree with the finding that the prescribed risk mitigation measures adequately address the significant ecological risks associated with importation of Bombus impatiens. The proposed mitigation measures are fraught with vulnerabilities and should not be relied upon as a basis for allowing the importation of Bombus impatiens.

The Xerces Society urges 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.

These comments are submitted by Scott Hoffman Black, Executive Director and Matthew Shepherd, Pollinator Conservation Director, The Xerces Society for Invertebrate Conservation; 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, DC; 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.