Date: October 29, 2013

Re: January 12, 2010 Petition to Regulate the Movement of Commercial Bumble Bees

On behalf of the Xerces Society, the Natural Resources Defense Council (NRDC), and Defenders of Wildlife, we write to request an update on the status of our January 12, 2010 Petition for Rulemaking, in which we asked the Secretary and Administrator to regulate the movement of commercial bumble bees in order to help control the spread of parasites and pathogens of bumble bees. Nearly four years have elapsed since we submitted our Petition, and neither the U.S. Department of Agriculture (USDA) nor the Animal and Plant Health Inspection Service (APHIS) has responded. The requested rulemaking is urgent and overdue. Numerous bumble bee pollinators have already declined dramatically and pathogens from commercial bumble bees are likely responsible for this; without agency intervention, we will likely continue to see a dramatic decline in bumble bee pollinators with perilous and potentially irreversible consequences.