Reef Hobby needs YOU: call for comments regarding ESA coral listing

[Gatortailale]

http://reefbuilders....-coral-listing/

 

Could really use everyone's help on this one which is incredibly important to any of us that owns a reef aquarium. This proposed ESA listing could have a detrimental impact on all of us. I encourage everyone to please submit your comments no later than tomorrow evening. Thank you!

 

 

Commentary here:

http://www.reef2rainforest.com/2013/04/04/commentary-noaas-20122013-66-coral-esa-proposal/

 

OPINION

By Matt Pedersen,

CORAL Magazine Senior Editor

[Chad]

MASNA's formal response, which looks pretty good to me. My recommendation would be for public comments to hammer on some of the same points.

 

http://www.reef2rainforest.com/wp-content/uploads/2013/04/MASNA-response-letter-ESA-listing-v3.pdf

[Chad]

My letter.

 

Dear Sir or Ma'am,

 

I write this letter in opposition to Proposed Listing Determinations for 82 Reef-Building Coral Species; Docket No. 0911231415-2625-02; 77 Fed. Reg. 73219.

 

I oppose the proposed rule because the Status Review Report upon which the rule is based contains insufficient data, the method underlying the Status Review Report does not make scientific sense, and the rule does not thoughtfully consider the impact of mariculture methodology.

 

Reviewing the Status Review Report, one phrase particularly sticks out: "The lack of adequate information on complex coral ecology and interactions between threats made the assessment of extinction risk for each of the 82 nominal coral species extremely challenging and uncertain." Bluntly, how can any rule be based on such a lack of supporting scientific data?

 

Additionally, the two-time, anonymous voting by members of the National Marine Fisheries Service was based on non-quantified methods and the large disparity in results does not show adequate convergent to meet any scientific standard. Also, expert non-Governmental marine biologists were not included in the team writing the Status Review Report, although many such educated personnel exist. This absence likely contributed to the poor methodology used by the team.

 

Finally, the rule does not consider the impact of ongoing mariculture methods to any of the coral species identified in the rule. Any review that does not consider these ongoing efforts is incomplete.

 

Based on the severity and number of problems associated with the Status Review Report, the proposed rule is not authorized under the Endangered Species Act. Instead, these corals should be designated as "species of concern" until such a time when the above concerns can be adequately addressed.

 

Sincerely,

[YHSublime]

Done.

[Gatortailale]

Thanks for your draft Chad! I made a few tweaks to make mine a little different and submitted to add a +1 to number of people commenting.

[Chad]

No problem!

 

Glad to see it got some more use!

[sachabballi reef]

ok done...

[Kingumar]

Done!

[mling]

Does anyone know what the Smithsonian's ( Nat Zoo Invert folks ) stand is on this matter ?

Edited April 6, 2013 by mling

[LCDRDATA]

I just posted my comment.

[jimlin]

done