Listing of Corals
Comments to the U.S. Fish & Wildlife Service
by birdfish, 2013

There was a recent open public comment period regarding the U.S. Fish & Wildlife proposal to list many species (even genera) of corals, as well as fish in the damsel and clownfish families, as threatened or endangered. Following are the comments I sent to USF&W about the proposed listing. I found out about it via a PIJAC (Pet Industry Joint Advisory Council) notice, and had all of a day or two to attempt to throw some ideas together before the deadline for public comment.

Hobbyists should stay attuned to the PIJAC happenings (via their website) as they are often the front line in attacks on our hobby. Many voices of reason can make a difference, and each one of us can be part of that many, as individuals. It is up to us to be informed and take inititive and action when needed. We should stay attuned to threats on our hobby, and keeping up on PIJAC news and information is a great way to do that.

Here are the comments I submitted ...

To whom it may concern:

Regarding the proposal for listing of many species of corals as endangered or threatened ... these comments from one whom at one time held USF&W research permits for endangered species (Golden-cheeked Warbler and Black- capped Vireo), a lifelong environmental activist, and one that has kept marine aquaria since the 1970's, as well as selling corals and fish.

It seems to me very likely that with the exception of species endemic to one island, or a small group, it is incredibly unlikely USF&W could make accurate population estimates of most of these species, at a level within 10,000 animals, and very possibly 100,000, probably a million for some species.

Of the tens of thousands of islands in the Indo-Pacific, most have never been collected. I think most have not been thoroughly properly surveyed at a level that accurate populations could be more than guessed at. As one that has done bird surveys for 40 years, I know how hard that is on the ground, in America. I can't imagine such an effort as say Christmas Bird Counts, Breeding Bird Surveys, etc., under water, all over the world. How do you count the corals on over 7,000 islands each, just in the Philippines or Indonesia? I'd like to see the estimated numbers of how many of each of these there are. Wouldn't they be just wild guesses? Extrapolations from single sites?

Listing something for which we have no real solid data of worldwide populations of, more than speculation, I think does more damage to the people's belief in or trust of the listing system than it helps the animal. Listing will not stop the primary causes of threat to coral reefs.

Other than highly endemic species, I don't see how any reasonable number can be offered for most corals. They certainly aren't in the category of "less than 10,000." As we know, vertebrates like Gray Whale and Bald Eagle were de-listed when populations reached that point. I'd bet there are a million of some of the corals proposed for listing. It borders on ridiculous.

Collateral damage in listing, the farmers, collectors and hobbyists, are not the problem. Like many times before in history, it is the zoos and private collectors, that have the last few of something left of a gene pool that the species is saved from. Arabian Oryx to Bali Starling to Socorro Dove. I see it as very likely hobbyists will be that when the fit hits the shan on the world's reefs. The problems corals potentially face are real, but collection is not the threat, any more than listing is the solution.

Carbon usage, wood burning, fossil fuel consumption, pollution, siltation from deforestation, dynamite fishing, dredging for limestone for construction material, U.S. Navy Minesweepers, etc., are all bigger problems the reefs face. And yes, warming seas. Collecting or studying and often farming corals as a hobbyist or business is not the cause of the warming seas; and, in fact, no one loves the coral, knows the coral, gets others more excited about corals and reefs, than these folks. These folks just might save the day for the corals, unless that opportunity is taken away by USF&W by listing them.

When the ESA was enacted there were no, zero, species of marine fish available captive bred, much less corals, clams, etc., of which now there are dozens and dozens of fish and corals farmed and bred, and all of the clams. This is incredible progress in little over 20 years, a major worldwide industry, especially in less developed areas where coral farming has provided not just income for the people, but an education that gives them a vested interest in protection of the reefs.

This is what USF&W should be doing, promoting the building and teaching of coral farming all over the world, so the locals have the knowledge and reason to protect their reefs. It has to be grassroots, and the listing creates more dissention through loss of jobs and income than it will create enforcement at a level that really truly protects them. Mostly it will merely stop the hobbyists.

The hobby is the outlet for that farmed product, this should be protected. There is no other way to potentially save or protect as many species. In captivity elsewhere only costs more. No government or institution can afford to do what the hobbyists are already doing. Collecting gene banks that we may need one day. Economically it is not feasible to do it any other way.

Drastic measures at the last minute are incredibly expensive, with no guaranty of results. Considering the number of species on any reef, it is not an option as we generally think of saving and restoring a species. This is an ecosystem, and that is what you are listing. It seems a bit odd to one that spent a great deal of time dealing in this sort of thing with terrestrial vertebrates.

Since the service knows true enforcement of what are really the biggest threats to the reefs (big energy, big ag, big lumber, illegal logging, etc.) are not likely to happen, they should not list anything that is not truly highly endemic. Small population, single island type endemics should be listed only, at most. Meanwhile, figure out a way to keep those whom are doing the right things for the animals (farming them) in business; there is not a lot of work where most of the corals are farmed. I guess they could go back to dredging and blowing up the reefs.

If what the service says might happen, happens, then the ones in captivity in the hands of collectors will be needed more than ever. This is what the service should protect as a hedge against the worst case scenario of worldwide reef collapses. Gene pools in other places. Getting as many as possible out of harms' way, in a second place for protection of the gene pools, is as important as doing something to save the reefs themselves if saving the corals is truly the goal.

The listing of damselfish and clownfish in a wholesale generic manner is virtually ludicrous, many of these fish are captive bred, and only the truly rare, highly localized endemics should even be considered, not species that are widespread and common to abundant. It borders on misuse of listing.


Note: Some minor correctons of typos and punctuation have been made in this copy of the letter.

Here is the link to the PIJAC home page, which is mostly assorted pet issues (heavy on dog and cat); covers everything, including reptiles, but when an aquarium related issue comes up, there will often be word of it here.

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