Sale of non-native bumblebee species – agricultural hybrids

Expert justification

From the justification of the Regional Authority of the Ústí nad Labem Region, on granting disapproval pursuant to Section 54, Paragraph 3 of Act No. 114/1992 Coll. on Nature and Landscape Protection, as amended, to the release of a specially protected animal bred in captivity into the wild and pursuant to Section 56 of the Act on granting an exemption from the legal protection of a specially protected animal

We quote:

So far, 38 species of bumblebees and bumblebees, collectively included in the genus Bombus, have been recorded in the Czech Republic. Currently, 25 species of them belong to one of the Red List categories (Hejda et al. 2017)

For comparison, in 2005, 16 species met the Red List criteria. The number of critically endangered or extinct species has also increased – currently 11 compared to 9 species in 2005. It is therefore clear that the genus Bombus, as a whole, belongs to the significantly endangered taxa.

The ground bumblebee (Bombus terrestris) is a species with a relatively large range, covering Europe, Asia Minor, North Africa and the Canary Islands. The ground bumblebee is a widespread species in Europe, which in its original range creates 9 subspecies, which are adapted to local conditions and differ in their behavior.

The importance of bumblebees as efficient pollinators of plants is great. Unlike bees, they fly even in cold weather and rain. The decline of bumblebees caused by inappropriate farming practices (growing monocultures, using chemicals, establishing sterile lawns, etc.) is obvious.

Bumblebees are mainly used in greenhouses to provide pollination services. This limits their movement in the wild. The applicant wants to release bumblebees in the wild and not limit their range in any way. In Europe, the bumblebee subspecies B. t. dalmatinus, originally native to southern Europe, or its hybrids with B. t. terrestris, which are stronger, more efficient, and have larger queens than pure B. t. terrestris, are most commonly used for pollination purposes. In the event of the spread of a geographically non-native subspecies or its hybrid, it could displace the native bumblebee species. Due to warming and the onset of milder winters, queens of subspecies that would not survive the winter in colder conditions may also survive in the wild 

Various subspecies of the ground bumblebee have been introduced as pollinators since at least the first half of the last century and, for example, in South America, they have spread rapidly beyond their original locations. According to Rasmont et al. 2008 3 , the ground bumblebee as a whole is not an endangered species, but rather an invasive species. All subspecies of the ground bumblebee can interbreed. Some subspecies are very difficult to distinguish from each other, even genetically. In addition to their appearance, they also differ in physiology, e.g. diapause period, vision, susceptibility to the insect pest
(Nosema sp.), and in behavior – aggressiveness, colony size, speed of collection. Currently, the most widely bred subspecies is B. t. dalmatinus. Some authors fear that if released from greenhouses, it may interbreed with or replace the original population of the species.

Only bumblebees with a clear genetic origin should be used to provide pollination services in the wild. In the proceedings, the applicant did not sufficiently prove the geographical and genetic origin of the bumblebees in question. In response to the call to supplement the application to prove the origin of the source population of the breeding of the common bumblebee, the place, method and time of capture or purchase and the number of captured or purchased individuals of the source population, the applicant sent a document from which it can only be inferred that this is a commercial laboratory breeding of bumblebees with a seller based in Poland. More detailed information is missing. This certificate says nothing about the origin of the mothers from the breeding where they were captured, nor their genetic affiliation to the subspecies. The submitted certificate is therefore insufficient to prove the subspecies. However, the evidence was sufficient from the point of view of the requirement of Section 54(1) of the Act, i.e. the legality of the origin of the individuals, which was addressed by the administrative authority as a preliminary question, and which was also the reason for the suspension of the proceedings, and therefore it was possible to continue the proceedings. 

To establish a de novo bumblebee breeding, it is necessary to capture queens from the wild (in the Czech Republic, an exception is required according to Section 56, paragraph 1 of the Act). Subsequently, a pedigree should be kept for each queen to prevent inbreeding. In such cases, it is necessary to provide pedigrees, which state the locations where the original queens were captured. In order to allow exceptions for this species, the taxonomic affiliation of the individuals kept to one of the nine subspecies should also be clearly documented.

Although the same subspecies of bumblebee occurs in Poland, this may not be the case with laboratory-bred individuals. They may belong to another subspecies, commonly bred for use in pollination of crops in greenhouses – Bombus terrestris subsp. dalmatinus, or to hybrids of both subspecies, which are commonly designated as B. t. terrestris. These can then be distinguished only by genetic analysis. B. t. dalmatinus is visually very similar to B. t. terrestris, but differs in its behavior – it creates larger, stronger nests, has greater pollination activity, and queens do not hibernate. Its original range is northern Italy, the Balkan Peninsula, Turkey, and the Caucasus. The spread of genes from non-native bumblebee species could change the behavior of ours, for example, disrupt the ability to hibernate, which is necessary in our conditions, and thus threaten the viability of native populations in the Czech Republic.

However, even in the case of the same subspecies bred in captivity, but originating from more distant areas, there are serious doubts about the safety of their eventual release into the wild and the absence of impact on existing populations in the Czech Republic. Local populations may have local adaptations that best suit the given environment. Moreover, laboratory-bred individuals inevitably undergo domestication and selection for traits that may then affect survival in the wild.

Genetic analysis confirms that the individuals belong to the pure line of Bombus terrestris terrestris and the pedigrees of the original mothers documenting the previous breeding and place of origin are therefore important data for decision-making.

The plan does not include an assessment of the current status of populations in the release areas or an analysis of the causes of their threat, which would justify the need for their artificial reinforcement from breeding. The plan does not consider the risks of releasing reared individuals for the original populations. However, releases outside the original area often have very significant harmful consequences that are difficult or impossible to predict.

The ground bumblebee (Bombus terrestris terrestris) is an endangered species, but among the bumblebees it is one of our most widespread. The ground bumblebee population in the Ústí nad Labem Region currently does not show signs of such a state that it would be necessary to systematically introduce its reinforcement by releasing additional individuals from the perspective of the protection of this species.

Moreover, their release would increase competitive pressure on less represented species, for which the newly released bumblebees could be food competitors. The intention could disrupt the genetic stability and behavior of native bumblebee species, or even displace them. Given that the existence of most of our bumblebee species is seriously threatened, it is highly undesirable to endanger the population of one of the few abundant and stable species.

If bumblebees are dying out in the wild, as the applicant mentions, due to the expansion of agricultural land and its management with monoculture crops, planting additional, even genetically suitable, bumblebees will probably not help the original population, since the causes of their decline will not be eliminated. A more suitable way to preserve original bumblebee populations and, as a result, to strengthen their pollination "function" is to plant suitable and diverse crops, establish bumblebee colonies, etc.

According to Section 56(1) of the Act, an exception may be granted only in cases where another public interest prevails over the interest of nature conservation, or in the interest of nature conservation. At the same time, according to Section 54(3) of the Act, the release of specially protected animals raised in human care into the wild is possible only if there is no risk of deterioration of the state of the wild population and if the release is in the area of ​​the original occurrence of the species in question for the purpose of restoring its population or stabilizing or strengthening existing populations. The proceedings did not prove that the plan is in the interest of nature conservation, nor was any other overriding public interest in the plan proven, and the plan carries the risk of endangering the original population of the common bumblebee in the Czech Republic.

For these reasons, the office did not grant the request in question and decided as stated in the ruling