HomeMy WebLinkAboutXerces Society Public InputXE RC E S Protecting the Li
that Sustains Us
SOC I ETY -----
for Invertebrate Conservation
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 (Bombes 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 (IPaQ 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
628 NE Broadway, Suite 200 1 Portland, OR 97232 1 1,855,232 6639 1 www,xerces.org
XERCES
SOC I ETY
for Invertebrate Conservation
References:
Protecting the Life that Sustains Us
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 Conseri ation, 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 Conseri,ation,
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:Hdoi.org/10.1093/biosci/biabl2l
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.
EnWronmental 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.aregis.com/home/item.litml?id=2716d 87l f88042a2a56b8001 a 1 fl aca
e (Accessed Feb 21, 2023)
628 NE Broadway, Suite 200 1 Portland, OR 97232 1 1,855 232 6639 1 www,xerces.org
"L EA VE A BETTER
LEGACY"
1,249 TOTAL Petition Signatures — Collected Online as of
February 20th, 2024
Submitted by Friends of Grey Cloud for the Public Record
February 21st, 2024
info@friendsofgreycloud.org 1 651-505-0986
PETITION EMAILS ORIGINAL RECIPIENTS:
TO:
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