Loading...
HomeMy WebLinkAboutXerces Society_Comment_Feb.21.2024 February 21, 2024 To Whom It May Concern, The Xerces Society for Invertebrate Conservation is an international nonprofit organization dedicated to protecting invertebrates and conserving their habitats. We have concerns about the significant environmental impacts of Rachel Development’s proposal, particularly for invertebrate conservation. We also request that all public documents, reports and communications be made available for public and expert review, and request that a new EAW be performed. We list our detailed concerns below for the Rusty Patched Bumble Bee, but want to emphasize our support for further protections and surveys of all the rare and threatened invertebrate species that are likely to be impacted by this proposed development. Rusty Patched Bumble Bee Rachel Development’s proposed project overlaps with the United States Fish and Wildlife Service (USFWS) ‘high potential zone’ for the federally endangered Rusty Patched Bumble Bee (Bombus affinis). According to the USFWS, these zones are areas where the Rusty Patched Bumble Bee is “likely to be present” and use the area for foraging and nesting (USFWS Rusty Patched Bumble Bee Map). The preservation, conservation, and restoration of areas within “high potential zones” are critically important for the persistence and conservation of the Rusty Patched Bumble Bee. Rachel Development should follow the process within the USFWS to conduct an Information Planning and Consultation (IPaC) review to prevent harm to the Rusty Patched Bumble Bee, as defined by the Endangered Species Act. Surveys or assessments to determine suitable habitat or the presence of the Rusty Patched Bumble Bee requires extensive research by credible experts with knowledge of their biology and habitat requirements. Rusty Patched Bumble Bees are active from April through September. As most flowering plants bloom for only a short period, Rusty Patched Bumble Bees must forage over a large area, relying on many different forage plants in different areas of the landscape. For example, Rusty Patched Bumble Bee queens are more reliant on flowering trees and forest-associated herbaceous flowering plants in the spring than in the summer (Mola et al. 2021). These temporal variations in floral abundance across the landscape can make it difficult to assess whether or not the Rusty Patched Bumble Bee is present in an area without intensive surveying. In addition, the nesting and overwintering habitats of many bumble bee species are not well known (Liczner and Colla 2019). Although Rusty Patched Bumble Bees are thought to nest and overwinter underground, the nesting preferences of this bumble bee species is vastly understudied and determining overwintering habitats used by queens is incredibly difficult. Thus, unless sufficient surveys have been conducted to determine that Rusty Patched Bumble Bee is absent from an area, there is no ideal or “safe” time of the year for construction activities that sufficiently reduces risk of harming Rusty Patched Bumble Bee in ‘high potential zones’ where nesting or overwintering bees may be present in the soil. The habitat suitability assessment for the Rusty Patched Bumble Bee conducted by Resource Environmental Solutions lacks the scientific integrity required for determining suitable bumble bee habitat for several reasons. First, the habitat suitability study was conducted in January of 2022 when forage plants used by bumble bees are not blooming nor when the bees are active, indeed their assessment noted there was three inches of snow on the ground. Habitat suitability studies for bumble bees should occur during the spring, summer and fall while the bees are active above ground and their forage plants can be adequately documented. Second, surveys for rare bee species and assessments to denote nesting habitat require specific field methodologies and protocols, such as occupancy modeling, and nest site surveys (Boone et al. 2023, Pugesek and Crone 2021). Both of these techniques require significant time, site visits, expertise and detailed analyses. For example, past research has indicated that at least six, 30-minute surveys conducted in early July (or 10, 30-minute surveys conducted in August) are required to determine if Rusty Patched Bumble Bees are present at a site (Otto et al. 2023). We want to emphasize that these regulatory decisions should be based on the science and data of species biology, established ecological survey methodologies and a precautionary approach to protect the rare and sensitive invertebrate populations. Thank you for your consideration to protect invertebrates. Sincerely, Julia Brokaw, Plant-Pollinator Database Specialist Genevieve Pugesek, Conservation Biologist Sarina Jepsen, Director of Endangered Species Program References: Boone, M. L., Evans, E., Arnold, T., & Cariveau, D. P. (2023). Increasing sampling efficiency of Bombus communities with rare and endangered species by optimizing detection probabilities: A multi-species occupancy modelling approach using roadsides as a case study. Biological Conservation, 283, 110122. Liczner, A. R., & Colla, S. R. (2019). A systematic review of the nesting and overwintering habitat of bumble bees globally. Journal of Insect Conservation, 23(5-6), 787-801. Mola, J.M., Hemberger, J., Kochanski, J., Richardson, L.L, & Pearse, I.S. (2021). The importance of forests in bumble bee biology and conservation, BioScience, 71(12), 1234-1248, https://doi.org/10.1093/biosci/biab121 Otto, C. R., Schrage, A. C., Bailey, L. L., Mola, J. M., Smith, T. A., Pearse, I., ... & Grundel, R. (2023). Addressing detection uncertainty in Bombus affinis (Hymenoptera: Apidae) surveys can improve inferences made from monitoring. Environmental Entomology, 52(1), 108-118. Pugesek, G., & Crone, E. E. (2021). Contrasting effects of land cover on nesting habitat use and reproductive output for bumble bees. Ecosphere, 12(7), e03642. USFWS Rusty Patched Bumble Bee Map https://www.arcgis.com/home/item.html?id=2716d871f88042a2a56b8001a1f1aca e (Accessed Feb 21, 2023)