I have obtained a copy of Xerces' petition. While the petition carefully avoids stating that honey bees are a threat to native bees, there are several significant points. In the first two paragraphs below, they use the unqualified phrase *commercial bee rearing and movement*. Then they go on to 1) make a case for regulating any organisms that could directly or indirectly affect bumble bees and 2) draw a direct connection between honey bee parasites and bumble bees (DWV, Nosema ceranae, and Aethina tumida). So in effect, they are setting the groundwork to use the Honey Bee Act to regulate bumble bees and quite probably honey bees.
* * *
General threats to bumble bee pollinators include: introduced disease from commercial bee rearing and movement, loss of habitat from increasing urbanization and expansion of intensive agriculture, widespread use of pesticides, introduction of competitive species, and parasites.
The dramatic decline in North American bumble bees is most likely caused by introduced diseases from commercial bee rearing and movement.
Parasites and pathogens of bumble bee pollinators are indirect plant pests that should be regulated under the PPA. The PPA broadly defines plant pests to include fungi, viruses, infectious agents and other pathogens, and any similar articles "that can directly or indirectly injure, cause damage to, or cause disease in any plant or plant product."
Indirect plant pests that are pathogens of bumble bees include, but are not limited to: viruses (e.g. Deformed Wing Virus35), bacteria (e.g. Spiroplasma sp.), microsporidia (e.g. Nosema bombi), and protozoa (e.g. Apicystis bombi and Crithidia bombi).36 Nematodes, internal mites (e.g. the tracheal mite Locustacarus buchneri), external mites, and the small hive beetle (Aethnia tumida) can also harm bumble bees, and thus can be considered.
The Honeybee Regulations should be expanded to regulate not just importation of non-honey bees but also the interstate movement of bumble bees. Such regulation is necessary to better protect all bumble bees and those who depend on their services. Honey bees and bumble bees do not share all of the same pests, but they do share a few pests which may be of concern. Deformed wing virus (DWV) and the microsporidia Nosema ceranae are examples of pathogens that have been documented in both honey bees and bumble bees.
quoted from
PETITION BEFORE THE UNITED STATES DEPARTMENT OF AGRICULTURE ANIMAL AND PLANT HEALTH INSPECTION SERVICE
January 12, 2010
THE XERCES SOCIETY FOR INVERTEBRATE CONSERVATION
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