A Petition to list the Blue Calamintha Bee (Osmia calaminthae) as an Endangered, or Alternatively as a Threatened, Species Pursuant to the Endangered Species Act and for the Designation of Critical Habitat for this Species Blue Calamintha Bee (Osmia calaminthae) (Photo by Tim Lethbridge, used with permission, available at http://bugguide.net/node/view/394002/bgimage). Submitted to the United States Secretary of the Interior acting through the United States Fish and Wildlife Service February 5, 2015 By: Defenders of Wildlife1 535 16th Street, Suite 310 Denver, Colorado 80202 Phone: 720-943-0457
[email protected] [email protected] 1 Defenders of Wildlife would like to thank Olivia N. Kyle, a law student at the University of Denver, Sturm College of Law, for her substantial research and work preparing this Petition. I. INTRODUCTION Petitioner, Defenders of Wildlife (“Defenders”), is a national, non-profit, conservation organization dedicated to the protection of all native animals and plants in their natural communities. With more than one million members and activists, Defenders is a leading advocate for the protection of threatened and endangered species. Defenders’ 2013-2023 Strategic Plan identifies bees as one of several categories of key species whose conservation is a priority for our organization’s work.2 Through this Petition, Defenders formally requests the Secretary of the Interior, acting through the United States Fish and Wildlife Service (the “Service”), to list the Blue Calamintha Bee, Osmia calaminthae, (“Bee”) as an “endangered,” or alternatively as a “threatened,” species under the Endangered Species Act (“ESA”). 16 U.S.C. §§ 1531-44. Additionally, Defenders requests that the Service designate critical habitat for the Bee concurrently with the listing of the species.