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HomeMy WebLinkAboutGreyCloudcomments Twin Cities Campus Department of Entomology College of Food, Agricultural and Natural Resource Sciences 219 Hodson Hall 1980 Folwell Avenue St. Paul, MN 55108-6125 612-624-3636 Fax: 612-625-5299 February 20, 2024 To whom it may concern: I am writing to express concern and provide information about negative impacts on the rusty patched bumble bee (Bombus affinis), a federally endangered species, from the proposed Rachel Development construction project at the former Mississippi Dunes property. I am an Associate Extension Professor at the University of Minnesota and have been studying bumble bees for over 25 years. I have worked extensively on determining the status and habitat needs of the rusty patched bumble bee since 2007. The status assessment conducted by the US Fish and Wildlife Service states that “Bombus affinis has been observed and collected in a variety of habitats, including prairies, woodlands, marshes, agricultural landscapes, and residential parks and gardens.” The rusty patched bumble bee actively uses these habitats for nesting and foraging from April to October. While it is true that you will not find rusty patched bumble bees foraging on flowers between November and March, this does not mean that they are not on the landscape (see the figure below). From late fall to early spring, rusty patched bumble bee queens hibernate, either on the surface of the ground under leaves, or a few inches below the soil surface. They are essentially defenseless at this time. If the ground is disturbed, the cold temperatures make it difficult or impossible to fly to find another overwintering site. Disturbance of the ground poses a direct risk. These queens are the only link to the next generation of rusty patched bumble bees. New colonies are started each spring by queens that have survived the winter. Just because you don’t see the insects from November to March doesn’t mean they aren’t completing their lifecycle during this critical time point. Given that 1) the rusty patched bumble bee is currently threatened with extinction, 2) the proposed Rachel Development construction project is within an area designated by the US Fish and Wildlife Service as having a high potential of occurrence of the rusty patched bumble bee, 3) the proposed construction reduces habitat and poses a threat of direct killing rusty patched bumble bee individuals, I recommend consultation with the US Fish and Wildlife Service to assess impacts. I also recommend conducting a new environmental review of construction plans to reduce negative impacts on this endangered species. The habitat assessment that was conducted in January of 2022 did not accurately assess habitat availability for or possible use by rusty patched bumble bees. I also request that all public documents, reports, and communications be made available for public and expert review. I am happy to provide information additional information about rusty patched bumble bee habitat use and help form plans to reduce the likelihood of harming individuals and to help create habitat options. Supporting materials Szymanski et al. (2016). Rusty patched bumble bee (Bombus affinis) species status assessment. https://www.fws.gov/midwest/endangered/insects/rpbb/pdf/SSAReportRPBBwAdd.pdf Mola, J. M., Richardson, L. L., Spyreas, G., Zaya, D. N., & Pearse, I. S. (2021). Long‐term surveys support declines in early‐season forest plants used by bumble bees. Journal of Applied Ecology, 58(7), 1431-1441. https://doi.org/10.1111/1365-2664.13886 Sincerely, Elaine Evans, PhD Associate Extension Professor University of Minnesota 612-644-1227 elainee@umn.edu