IPAA and API Joint Comments to the U.S. Fish and Wildlife Service on its 90-Day Finding on a Petition to List the Rusty-Patched Bumble Bee Under the Endangered Species Act

IPAA and API Joint Comments to the U.S. Fish and Wildlife Service on its 90-Day Finding on a Petition to List the Rusty-Patched Bumble Bee Under the Endangered Species Act

The Independent Petroleum Association of America (IPAA) and the American Petroleum Institute (API) respectfully submit the following comments on the U.S. Fish & Wildlife Service’s 90-Day Finding on the petition of Xerces Society for Invertebrate Conservation to list the rusty-patched bumble bee (RPBB) as an endangered species under the Endangered Species Act. 80 Fed. Reg. 56,423, 56,429 (Sept. 18, 2015).