Have You Heard the Buzz About the Bumble Bee CBA?

The Bumble Bee Conservation Benefit Agreement (Bee CBA) promotes habitat conservation efforts for 11 species of North American bumble bees, primarily in energy and transportation rights-of-way (ROW). This voluntary agreement is currently under U.S. Fish and Wildlife Service (USFWS) review, and proponents want the agency to see this Bee CBA as an alternative to restrictions that could be applied under the Endangered Species Act.

Like the existing Nationwide Candidate Conservation Agreement with Assurances (CCAA) program for the monarch butterfly, the Bee CBA is stakeholder-developed, incentive-based conservation offered in exchange for increased regulatory certainty during normal operations. Bumble bees are critical pollinators for agricultural crops and wild flowering plants. Severe population decline has led to federal protection of some bumble bee species under the Endangered Species Act along with efforts to foster population recovery through habitat conservation.

What is the USFWS Considering?

The USFWS published an Enhancement of Survival (EOS) permit application under the Endangered Species Act on January 23, 2026; the 30-day public comment period closed on February 23, 2026.

The University of Illinois at Chicago (UIC), which developed the “National Conservation Benefit Agreement for Bumble Bees on Energy and Transportation Lands” (Bee CBA) with partners from the Wisconsin Department of Natural Resources and energy and transportation organizations, submitted the application. More information about the effort is available on the UIC website. The application requests a 35-year Enhancement of Survival permit with the UIC serving as administrator of the conservation program.

If approved by USFWS, the Bee CBA would provide assurances to participating non-federal landowners and managers of maintained energy and transportation corridors in the contiguous 48 states of the U.S. that the USFWS would not require additional or revised conservation measures without their consent. In return, the enrollees would be permitted to continue approved ongoing operations and implement conservation measures to provide net benefit to the species. Davey Tree, WSSI’s parent company, is a supporter of the Bee CBA effort.

Examples of conservation actions include:

• Establishing and using native seed mixes containing a diversity of native wildflowers
• Avoiding nest sites
• Promoting grassland habitats by removing incompatible vegetation (i.e., invasive and woody species)
• Sustaining idle lands with bumble bee-suitable habitat
• Using conservation mowing to enhance floral resources and habitat

Which Bees are Protected?

Bee CBA participants would be protected from any incidental take of these 11 species in the course of their normal operations:

1. Rusty Patched Bumble Bee (Bombus affinis), federally endangered
2. Franklin’s Bumble Bee (B. franklini), federally endangered
3. American Bumble Bee (B. pensylvanicus)
4. Variable Cuckoo Bumble Bee (B. variabilis)
5. Western Bumble Bee (B. occidentalis)
6. Suckley’s Cuckoo Bumble Bee (B. suckleyi)
7. Crotch Bumble Bee (B. crotchii)
8. Southern Plains Bumble Bee (B. fraternus)
9. Morrison Bumble Bee (B. morrisoni)
10. Yellow Banded Bumble Bee (B. terricola)
11. Ashton’s Cuckoo Bumble Bee (B. ashtoni)

How Does This Impact Me?

ROW managers and landowners could be challenged with future operations and maintenance of ROW through additional regulatory burden and costly delays given the existing and potential listing status of the 11 bumble bee species as well their widespread occurrences across the lower 48 U.S. states. The Bee CBA is a means to provide regulatory certainty, avoid setbacks, and provide a net benefit for bumble bees. ROW managers and landowners are eligible to participate in the Bee CBA.

Think you may benefit from the Bee CBA program? WSSI can develop, manage and monitor for the program, much like we do for the monarch butterfly CCAA. This includes helping you first identify and evaluate options for participation that are a best-fit for your organization. Please contact our team listed below to get started or ask questions.

Resources

1. University of Illinois Sustainable Landscapes: Bumble Bee CBA website
2. University of Illinois Sustainable Landscapes: Monarch Butterfly CCAA website
3. “Application for Enhancement of Survival Permit, University of Illinois at Chicago; Draft Conservation Benefit Agreement for Eleven Bumble Bee Species,” Federal Register, Vol. 91, No. 15, January 23, 2026