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Date: November 2018

Docket No.: FWS-RJ-ES-2015-0112

Please accept these comments submitted on behalf of the Xerces Society for Invertebrate Conservation and the Natural Resources Defense Council in response to the positive 90‐day finding the Service issued for the rusty patched bumble bee (Bombus affinis) on September 18, 2018 (FWS-RJ-ES-2015-0112). The Xerces Society submitted a petition for protection of the rusty patched bumble bee on January 31, 2013. We urge the Service to promptly issue a proposed listing to protect the rusty patched bumble bee as endangered under the Endangered Species Act. Our comments cite recent research and provide additional evidence to support the following factors outlined in our 2013 petition. In addition, we provide updated information about this species’ current range and conservation status, including a recently published IUCN Red List extinction risk assessment for the rusty patched bumble bee, in which the species was listed as Critically Endangered.

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