Will the interstate restriction regulations proposed by the Xerces Society really
protect bumblebees considering: 

1) the actual causes of the declines in the four Bombus species in question
are unknown. Only circumstantial evidence (timing) suggests disease spread by
escaped commercially reared Bombus might be a factor.  Some Bombus
species continue to be very abundant in the same exact areas where
the other four species in question have seriously declined.

2) the pathogens in question already widely occur in not only
bumblebees, but honeybees as well. So (as Peter Borst pointed out)
how can it be justified to regulate any interstate movement of bees
on the basis of pathogens that are already ubiquitous?

3) Also, as Peter Borst said: "they propose that bumble bees must have 
a clean bill of health, presumably including absence of DWV. This can 
only be detected by costly PCR testing, and presumably the native
bee populations already have, so any attempt to prevent the spread 
of it retroactively is absurd."

4) Only one insect pathologist has signed the Xerces proposal.

Paul Cherubini
El Dorado, Calif.

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