Leonard
10 & Over Club
http://www.advancedaquarist.com/blog/reefkeeping-is-not-under-attack
I rarely post links to my own articles, but it's high time hobbyists, experts, and industry people discuss this issue with facts and integrity.
Reefkeeping is NOT under attack
- Thread starter Leonard
- Start date
I rarely post links to my own articles, but it's high time hobbyists, experts, and industry people discuss this issue with facts and integrity.
gone fishin
New member
Thank you for the insightful article. I am going to go back and read the links you made available. I was pretty sure the sky was not falling.
Peter Eichler
New member
Thank you! It's about time people wise up on this matter and start looking at is differently and not through the eyes of a panicking industry or personal agenda.
Also, I'm happy that someone acknowledged Justin Bieber and the diabolical threat he is to our coral reefs.
Also, I'm happy that someone acknowledged Justin Bieber and the diabolical threat he is to our coral reefs.
MondoBongo
Obligate Feeder Obsessed
gone fishin
New member
Yes the Bieber is the cause of many bad things and should be stopped.
Squidmotron
New member
Stop attacking the people who say reefkeeping is under attack.
asylumdown
New member
You are right on the mark that the NOAA shouldn't care whether or not we get to keep our fishbowls, and I hope that's not the content of the majority of the comments hobbyists are leaving.
However, the NOAA has opened up a comment period for a set proposed rules to the public, so one would hope they were actually intending to at least read them. I agree that the comments should have more substance than 'these are my toys, you can't have them', but I hope you're not trying to dissuade people from participating in the process.
Also, the effect a no-take provision would have on this hobby are as yet unknown. You can't claim to know whether our hobby would be imperilled by these decisions as we don't know what the downstream effects will be. The NOAA might not be our enemy, but the emergent effect of Fish & Wildlife officers interpreting a no take provision in thousands of individual interactions involving corals that you need a doctorate and a microscope to tell apart might be considerable collateral damage, regardless of the NOAA's intent. Hopefully the effect won't be too significant, but it has every potential to severely limit the availability of a range of common corals with whatever ripple effects that will have on people's desire to join this hobby and invest absurd amounts of money on the equipment companies and vendors make their livelihood selling. You are correct in stating that this has nothing at all to do with whether or not something is or should be listed as threatened under the ESA, but it's reason enough for people involved in this hobby to care and want some input.
The ESA is probably the most forward thinking pieces of environmental legislation ever crafted by the US government, and it's had some incredible successes. But it wasn't written with corals like Acroporids, or even reefs in general, in mind. The tools available in it's conservation tool-kit are blunt instruments with no jurisdiction in the vast majority of where reefs are declining. Even listing every coral in the sea as critically endangered tomorrow would do very little to meaningfully reverse the global forces that have lead to these species being threatened. While the NOAA is most certainly not our enemy, the choices they make with these 20 species will have more of an effect on us than they will on the health of the world's reefs, so it's not unreasonable for some people to perceive this as an attack. If we trace the application to list these species back to the original sources and examine their motives, it sort of was.
I've been trying to work my way through the list of references the NOAA said it based it's decision on, and while I've not read each paper yet (it's a doctoral dissertation's worth of citations), there are only a handful of references that directly examine the aquarium industry, and a couple of them actually come to pretty positive conclusions about the coral trade - though there's definitely scathing criticism to be found. However, the trend of the science behind these listings is overwhelmingly weighted towards describing the current and potential consequences of anthropogenic modifications to the atmosphere and what that means for climate. The kicker is that the ESA in it's current incarnation cannot stop climate change. It can't stop ocean acidification. It can't stop irresponsible coastal development and dredging in Indonesia and the Philippines. It's the wrong solution for a different problem. All it really can do is shut down the trade in stony corals in US territories and legally require everyone within its jurisdiction to destroy an unknown (but likely large) percentage of some of these species entire global populations. That doesn't advance the goals of reef conservation. It does, however, advance the goals of people who are ideologically opposed to aquariums, who just so happen to be the people who brought the original petition to have these species listed.
What we need is regulatory tools like you mentioned in your article that recognize the fact that "taking" a chunk of an Acropora doesn't have to be anything like "taking" a bald eagle, and that an entire reef being decimated by a temperature induced bleaching event does not have anything to do with a Fijian mariculture facility supplying aquacultured coral to the US market. Maybe you know of cases where the ESA has exhibited such nuance in the past, but I can't think of any off the top of my head.
However, the NOAA has opened up a comment period for a set proposed rules to the public, so one would hope they were actually intending to at least read them. I agree that the comments should have more substance than 'these are my toys, you can't have them', but I hope you're not trying to dissuade people from participating in the process.
Also, the effect a no-take provision would have on this hobby are as yet unknown. You can't claim to know whether our hobby would be imperilled by these decisions as we don't know what the downstream effects will be. The NOAA might not be our enemy, but the emergent effect of Fish & Wildlife officers interpreting a no take provision in thousands of individual interactions involving corals that you need a doctorate and a microscope to tell apart might be considerable collateral damage, regardless of the NOAA's intent. Hopefully the effect won't be too significant, but it has every potential to severely limit the availability of a range of common corals with whatever ripple effects that will have on people's desire to join this hobby and invest absurd amounts of money on the equipment companies and vendors make their livelihood selling. You are correct in stating that this has nothing at all to do with whether or not something is or should be listed as threatened under the ESA, but it's reason enough for people involved in this hobby to care and want some input.
The ESA is probably the most forward thinking pieces of environmental legislation ever crafted by the US government, and it's had some incredible successes. But it wasn't written with corals like Acroporids, or even reefs in general, in mind. The tools available in it's conservation tool-kit are blunt instruments with no jurisdiction in the vast majority of where reefs are declining. Even listing every coral in the sea as critically endangered tomorrow would do very little to meaningfully reverse the global forces that have lead to these species being threatened. While the NOAA is most certainly not our enemy, the choices they make with these 20 species will have more of an effect on us than they will on the health of the world's reefs, so it's not unreasonable for some people to perceive this as an attack. If we trace the application to list these species back to the original sources and examine their motives, it sort of was.
I've been trying to work my way through the list of references the NOAA said it based it's decision on, and while I've not read each paper yet (it's a doctoral dissertation's worth of citations), there are only a handful of references that directly examine the aquarium industry, and a couple of them actually come to pretty positive conclusions about the coral trade - though there's definitely scathing criticism to be found. However, the trend of the science behind these listings is overwhelmingly weighted towards describing the current and potential consequences of anthropogenic modifications to the atmosphere and what that means for climate. The kicker is that the ESA in it's current incarnation cannot stop climate change. It can't stop ocean acidification. It can't stop irresponsible coastal development and dredging in Indonesia and the Philippines. It's the wrong solution for a different problem. All it really can do is shut down the trade in stony corals in US territories and legally require everyone within its jurisdiction to destroy an unknown (but likely large) percentage of some of these species entire global populations. That doesn't advance the goals of reef conservation. It does, however, advance the goals of people who are ideologically opposed to aquariums, who just so happen to be the people who brought the original petition to have these species listed.
What we need is regulatory tools like you mentioned in your article that recognize the fact that "taking" a chunk of an Acropora doesn't have to be anything like "taking" a bald eagle, and that an entire reef being decimated by a temperature induced bleaching event does not have anything to do with a Fijian mariculture facility supplying aquacultured coral to the US market. Maybe you know of cases where the ESA has exhibited such nuance in the past, but I can't think of any off the top of my head.
joshky
Acros & Wrasses
I agree wholeheartedly, but your last paragraph directed at NMFS is my main concern.
More specifically:
If they don't give some wiggle room for us, it could potentially be the end of keeping some of our favorite corals. I think mariculture and aquaculture facilities should be able to get a license or something to have the right and sell their cultured corals. Even if it's only 2" frags like you've suggested, it would be better than nothing.
More specifically:
If they don't give some wiggle room for us, it could potentially be the end of keeping some of our favorite corals. I think mariculture and aquaculture facilities should be able to get a license or something to have the right and sell their cultured corals. Even if it's only 2" frags like you've suggested, it would be better than nothing.
asylumdown
New member
The problem is that the ESA doesn't have those mechanisms built in to it. Section 1539 of the Endangered Species Act describes the possible exceptions to a no-take restriction. It specifically excludes anything intended for commercial purposes. If they list these species as 'no-take', I don't think they have the legal option to provide us with any wiggle room at all.
CITES is where such wiggle room exists. The people who brought the petition to have these species listed knew that. That's why they're trying to get them listed under the ESA.
Leonard
10 & Over Club
@asylumdown
I'm definitely not dissuading participation in this process. On the contrary, we need to play a bigger role. However, that role has to fall within the scope of what NMFS is seeking. Inside sources tell me the comments made on behalf of hobbyist thus far hasn't made a good impression, which is a big reason I felt compelled to write this article today.
When I trace the newly listed species back to the original CBD petition, I don't sense any motive to "attack" marine ornamentals. We are really an afterthought in the original petition. Can you cite reasoning for your conclusion?
The fact that the ESA has no power to stop the largest stressors on these corals has not escaped me. But can you fault them for doing what's within their scope? The United States is the world's largest consumer of marine ornamentals, so curbing a big chunk of demand for species that are deemed to require additional protection plays a positive role. Some US-based wholesalers/retailers may have to destroy existing stock of a few species, but that's a short term outlook. The long term outlook advances conservation. If data dictates that these species are truly under threat, should we allow the harvest of wild specimens simply because we aren't the most guilty party?
I'm definitely not dissuading participation in this process. On the contrary, we need to play a bigger role. However, that role has to fall within the scope of what NMFS is seeking. Inside sources tell me the comments made on behalf of hobbyist thus far hasn't made a good impression, which is a big reason I felt compelled to write this article today.
When I trace the newly listed species back to the original CBD petition, I don't sense any motive to "attack" marine ornamentals. We are really an afterthought in the original petition. Can you cite reasoning for your conclusion?
The fact that the ESA has no power to stop the largest stressors on these corals has not escaped me. But can you fault them for doing what's within their scope? The United States is the world's largest consumer of marine ornamentals, so curbing a big chunk of demand for species that are deemed to require additional protection plays a positive role. Some US-based wholesalers/retailers may have to destroy existing stock of a few species, but that's a short term outlook. The long term outlook advances conservation. If data dictates that these species are truly under threat, should we allow the harvest of wild specimens simply because we aren't the most guilty party?
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Leonard
10 & Over Club
The ESA has wiggle room for species listed as threatened but not endangered. But you are right in that they do not make a habit of allowing exemptions to no take prohibitions.
Another conservation measure they can adopt is to simply prohibit import of any of these species but still allow interstate trade, which has the same effect as a no-take policy.
However, one of ESA's concerns with exemptions is that it fuels black markets. Whether this concern is applicable and valid for Acroporas is open to debate.
BTW, the way species are nominated for CITES and ESA protection are very different processes. I don't see any Machiavellian reasons why the CBD chose ESA over CITES ... because that's not how CITES works.
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asylumdown
New member
I might have gotten my wires crossed on where this all started, but these species seem to be the same ones that showed up on the Centre for Biodiversity's original petition to list 83 species of stony corals under the ESA back in 2010. They've not much love for us.
It's sad that the comments have painted us in a bad light. And I 100% agree with you that wild collection of corals is a problem. But is that how most of these corals are arriving in US tanks these days? My whole point is that the ESA has no ability to differentiate. There's no language anywhere in the act that recognizes a difference between a coral who's ancestor left the ocean 20 years ago, and one that was poached from a threatened reef last night. They can't make an exception for 2" frags if that frag is intended to be sold, because the act prohibits exceptions for commercial purposes.
My whole point is that a no-take provision is like a blunt hammer. Yes, it will likely halt some wild harvesting, but whether or not that was even a threat to a particular species in all the places where harvesting is occurring in the first place is not established at all in the research they're using to make this decision. It also completely ignores our ability to culture these organisms in captivity.
I'm all about protecting reefs. I'm all about severely restricting/halting wild collection of threatened corals, but the ESA as it currently exists will just halt it all period, whether or not that will actually do anything to protect the reefs.
It's sad that the comments have painted us in a bad light. And I 100% agree with you that wild collection of corals is a problem. But is that how most of these corals are arriving in US tanks these days? My whole point is that the ESA has no ability to differentiate. There's no language anywhere in the act that recognizes a difference between a coral who's ancestor left the ocean 20 years ago, and one that was poached from a threatened reef last night. They can't make an exception for 2" frags if that frag is intended to be sold, because the act prohibits exceptions for commercial purposes.
My whole point is that a no-take provision is like a blunt hammer. Yes, it will likely halt some wild harvesting, but whether or not that was even a threat to a particular species in all the places where harvesting is occurring in the first place is not established at all in the research they're using to make this decision. It also completely ignores our ability to culture these organisms in captivity.
I'm all about protecting reefs. I'm all about severely restricting/halting wild collection of threatened corals, but the ESA as it currently exists will just halt it all period, whether or not that will actually do anything to protect the reefs.
Leonard
10 & Over Club
The origins of these 20 species is from the CBD petition. They have no love for the aquarium trade but I also do not believe they are motivated by our downfall either. We are a very small contributor (the aquarium trade is usually listed pretty far down their petitions if at all), and it is my belief they act in good faith for species that feel warrant investigation by the NMFS. The Wildlife Guardians, OTOH, seems a lot more dogma-based.
It's true the ESA has no ability to differentiate origin, but I think it could be as simple as enforcing no-take at the ports of entry rather than interstate commerce.
But if it boils down to all or nothing, do we really opt for nothing for corals facing threat?
Agree with everything you wrote. Aquarium trade may not be 'under attack' per se, but the consequences of banning certain animals will affect it. However, I suppose one would hope that any restrictions that occur are for the greater good and are of higher priority than the availability of a few corals to the hobby. BTW, the suggestion that coral restrictions be excepted for smaller fragments, thus preserving the hobbyist trade of acro frags is a very good suggestion and makes a lot of sense. So much so, in fact, that of course it won't happen 
mussel and hate
New member
I believe that protecting endangered species is a noble pursuit, but to claim that the NMFS/NOAA does not have a vested interest in hurting the ornamental coral industry is silly. Of course the NMFS/NOAA has a vested interest. Anyone employed by the NMFS/NOAA derives their very livelihood from the imposition of such restriction. That is by definition a vested interest... Furthermore restricting trade in aquacultured corals on the ban list does nothing to protect wild colonies, quite the opposite actually. If the language of the proposed ban were revised to do what it actually is intended to the ESA might see more support from aquarists. Just some food for though.
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reefkeeper2
Premium Member
Some tips for anyone who wishes to make a comment.
http://http://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf
It might be a good idea that since the ordinary reefer/hobbyist does not have the facts or eloquence to submit a persuasive comment, individual reef clubs should step in and provide some leadership to help. Each club in the country could be asked to submit a comment on behalf of their membership. This would organize the effort. With the knowledge and expertise available to us, I think the results would be far superior and could make a real contribution . It would go a long way to improving our image as well.
http://http://www.regulations.gov/docs/Tips_For_Submitting_Effective_Comments.pdf
It might be a good idea that since the ordinary reefer/hobbyist does not have the facts or eloquence to submit a persuasive comment, individual reef clubs should step in and provide some leadership to help. Each club in the country could be asked to submit a comment on behalf of their membership. This would organize the effort. With the knowledge and expertise available to us, I think the results would be far superior and could make a real contribution . It would go a long way to improving our image as well.
Spyderturbo007
New member
I'm still at a loss as to why it has to be a blanket buy, sell, trade ban. There should be no reason why I can't break off a piece of my Frogspawn and sell it to Jim Bob down the street. If not, I'm going to have to break it off and throw it in the trash when it gets too big.
I am 100% for protecting our reefs, but meddling into my ability to buy aquacultured corals from my buddy down the street is just asinine.
I am 100% for protecting our reefs, but meddling into my ability to buy aquacultured corals from my buddy down the street is just asinine.
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