Although the object of the Endangered Species Act of 1973 (ESA) is to protect endangered species and their habitats, many endangered pollinators are not recognized as candidate species for two reasons. First, Congress directed that listing of species requires a scientific determination of a species’ continued existence as threatened or endangered, but data on many pollinators are sketchy. Second, a 1981 congressional revision of the ESA specifically exempted any “species of the Class Insecta determined by the Secretary to constitute a pest whose protection under the provisions of this Act would present an overwhelming and overriding risk to man.” Some caterpillars and carpenter bees, for example, can cause economic damage. Thus, it might be difficult to present sufficient evidence to list them.

Recommendation: Congress should not consider any ESA amendment that would create additional barriers to listing pollinator species as endangered.