[Coral-List] Impact of listing 66 coral species on coral research

[Douglas Fenner]

      I was interested in reading what NOAA said was the basis for raising
the status of the two Caribbean Acropora from "threatened" to "endangered."
 The "Status Report" only deals with the 82 species that were petitioned,
and did not include the two Acropora in the Caribbean, since they were not
in the 82 species that were petitioned.  However, the Federal Register
notice does include the scientific basis for raising the listing of the
Caribbean Acropora.
     The URL for the Federal Register notice is
www.federalregister.gov/articles/2012/12/07/2012-29350/endangered-and-threatened-wildlife-and-plants-proposed-listing-determinations-for-82-reef-building#h-68
  To find the section on the Caribbean Acropora, look in the table of
contents, and go down below the list of all the individual 82 species, and
the next item is "Reclassification of Acropora palmata and Acropora
cervicornis."  Click on the blue type, and it will take you directly to the
right section in the document.
      So for those who are concerned about whether the scientific basis for
that change was adequately covered or not, this is the place to read what
that basis was.  Further, this comment period is the time to point out any
inadequacies or errors in that section of the Federal Register.  I suspect
that while comments of the type "I don't like this decision and I don't
think it will save the corals" may not have much sway in the final
decision, comments of the type "The science that was used to base this
decision on was incomplete and even wrong in some critical areas, and here
are the details" may have considerable sway in the final decision.  If the
science NOAA presents leads to the wrong conclusions because it excludes
the best available science, a consideration of all the information might
lead to a different decision.  Like I say, I suspect that, but I've never
been involved in these decisions and never will, so that is just my guess.
      This is a time for doing some homework.  Some may feel that experts
have been discussing this on coral-list, but frankly, everything said is
second-hand.  If you really want to know, you need the info from the
horse's mouth, you need to read these documents and decide for yourself.
 There is no substitute for that, if you want something done right,
sometimes you have to do it yourself.  It's called "scholarship."  So I
urge people to read the document (this section is not long).  It is
important to make sure that this decision really was made based on the best
available science.

      Cheers,  Doug


On Mon, Dec 17, 2012 at 6:34 AM, William Precht <william.precht at gmail.com>wrote:

> Just an FYI for those involved in the *Acropora* thread.
>
> In response to Sarah's post - I have long been a proponent for
> science-based resource management.  Accordingly, I was coauthor on a number
> of peer-reviewed manuscripts that helped to set the path for the original
> ESA listing of the two acroporid species.
>
> These included the following:
>
> Aronson, R. B., & Precht, W. F. (2001). White-band disease and the changing
> face of Caribbean coral reefs. *Hydrobiologia*, *460*(1), 25-38.
>
> Precht, W., Bruckner, A., Aronson, R., & Bruckner, R. (2002). Endangered
> acroporid corals of the Caribbean. *Coral Reefs*, *21*(1), 41-42.
> Precht, W. F., Robbart, M. L., & Aronson, R. B. (2004). The potential
> listing of Acropora species under the US Endangered Species Act. *Marine
> Pollution Bulletin*, *49*(7-8), 534-536.
>
> I was also on the IUCN Coral Red-List team (with Jennifer Moore) that
> placed the two Caribbean acroporids in "critically endangered" status
> (based on the IUCN Red-List criteria).
>
>
> Aronson, R.B., A. Bruckner, J. Moore, B. Precht, and E. Weil. (2009a)
> *Acropora
> cervicornis* (staghorn coral). *IUCN Red List: The IUCN Red List of
> Threatened Species*, version 2009.1.
> http://www.iucnredlist.org/details/133381/0.
>
>
>
> Aronson, R.B., A. Bruckner, J. Moore, B. Precht, and E. Weil. (2009a)
> *Acropora
> palmata *(elkhorn coral). *IUCN Red List: The IUCN Red List of Threatened
> Species*, version 2009.1. http://www.iucnredlist.org/details/133006/0.
>
> Because of the 2006 ESA listing we have learned a lot about these two coral
> species.  We know much more today than when these species were first listed
> -- much of which was either funded or permitted through NOAA.  The point of
> my post the other day was that there is more than just threats that need to
> be considered in reclassifying the status of these two corals (nevermind
> the other 66).  We now have actual population numbers, genetic diversity,
> forward looking population models, a better understanding of the causes of
> mortality (and resistance to mortality), and we have made giant strides in
> developing restoration strategies (including a number of incredibly
> successful pilot projects).  All these new data need to be carefully
> considered as we move forward.
>
> As for the threats -- coral bleaching, white diseases and syndromes,
> predator outbreaks, hypothermic stress (esp. Florida), hurricanes, etc. are
> all still with us.  Unfortunately, there is little that scientists,
> managers, or the ESA can do to stop a regional pandemic, cold
> front, hurricane, or the main threat in Alina's post -- human population.
>
> On a more positive note, my view from the bridge is that things look better
> today for the acroporids than they did in 2006.
>
> But then again - maybe I'm just an optimist.
>
> Happy holidays,
>
> BP
>
> On Mon, Dec 17, 2012 at 11:00 AM, Sarah Garvin <sarah.e.garvin at gmail.com
> >wrote:
>
> > Dennis, thanks for your response. I was not assuming an agenda, nor
> taking
> > any animosity from your original post. I used it more by way of example
> of
> > the trends I've seen in discussions about this topic here on Coral-List.
> >
> > As for the proposed change in status from "threatened" to "endangered"
> for
> > Caribbean acroporids, I can offer one theory. I no longer work for NOAA
> > Fisheries, so I cannot comment on the true ins and outs of this
> particular
> > rulemaking. I did work for the agency when the Caribbean acroporids were
> > listed originally. The status evaluation methods used when these species
> > were listed originally were similar to the methods used for the 66
> species
> > proposed for listing; however, the determination tool used for the 66
> > species (
> >
> >
> http://www.nmfs.noaa.gov/stories/2012/11/docs/82_corals_determination_tool_web.xlsx
> > )
> > was not used for the Caribbean acroporids. It seems to me that it would
> > only make sense to look at what would happen if you fed all the data we
> > have for Caribbean acroporids into the determination tool to see what
> would
> > happen. Would the determination tool come up with a "threatened" status
> or
> > an "endangered" status based on the demographic, spatial, and threats
> data
> > we have for these two species? Clearly it seems the tool popped out
> > "endangered" as the agency is proposing uplisting the status for these
> > species. To me, it seems reasonable to consistently apply the methodology
> > developed for the 66 species to 2 species already listed.
> >
> > The uplisting of Caribbean acroporids, should it be finalized, would not
> > really result in too many additional regulations for these species.
> Because
> > of the special 4(d) rule already in place for these species that extends
> > all of the ESA's prohibitions on take to these species, nothing much in
> > terms of prohibited activities would change. The one significant change
> > would indeed be the process for research permitting. Currently, existing
> > federal, state, and territorial permits are sufficient for conducting
> > research; however, should uplisting to endangered occur, folks would
> need a
> > federal ESA research permit. That is why staff at the Southeast and
> Pacific
> > Islands Regional offices for NOAA Fisheries are reaching out to all of
> you
> > and asking you to get involved in the process. If active researchers on
> > these species become informed and involved now, it is more likely that
> they
> > will face fewer hurdles in the federal ESA permitting process.
> >
> > Last, (and this is for Bill Precht's post) in my years of working for
> NOAA
> > Fisheries on these species, I can attest to the great weight we
> biologists
> > place on data -- it mattered to us and it guided us in making policy
> > decisions. The people working on these rulemakings are not nameless or
> > faceless, and they are not simply cogs in a government machine. Great
> > amounts of deep thought and consideration go into these rulemakings,
> often
> > under tight, court-ordered deadlines, which leaves little time for
> getting
> > everything done *exactly* right on the first go-round. Thus, the proposed
> > rule and the public comment process.
> >
> > Thanks again,
> > Sarah
> >
> >
> >
> > On Mon, Dec 17, 2012 at 6:59 AM, <coral-list-request at coral.aoml.noaa.gov
> > >wrote:
> > Message: 3
> > Date: Sun, 16 Dec 2012 14:46:04 -0500
> > From: Dennis Hubbard <dennis.hubbard at oberlin.edu>
> > Subject: Re: [Coral-List] Impact of listing 66 coral species on coral
> >         research
> > To: Sarah Garvin <sarah.e.garvin at gmail.com>
> > Cc: "coral-list at coral.aoml.noaa.gov" <coral-list at coral.aoml.noaa.gov>
> > Message-ID:
> >         <CAFjCZNbZC=
> > >
> > > CnOLzQYjeN8BgUMpkE9q9CGyuiraRxbt2f08=Dng at mail.gmail.com>
> > > Content-Type: text/plain; charset=ISO-8859-1
> > >
> > > Thanks Sarah:
> > >
> > > My questions weren't actually tied to any specific agenda or concern.
> As
> > I
> > > tried to lay out in my first posting on the issue, it was explained to
> me
> > > and others at the original posting discussion that listing Acropora as
> a
> > > threatened species was far more effective than listing it as
> > "endangered" -
> > > and would more likely lead to a better outcome for the two. I did not
> > > challenge this view then, and I'm not challenging the opposite one now
> as
> > > I'm not qualified to comment on the political and policy vagaries of
> such
> > > decisions - and don't claim to be an expert on Acropora. I am all for
> > > protecting these and other species. My question was simply a request
> for
> > > information on why this position had apparently changed. I can think of
> > > three likely scenarios. It could be based on a change in the condition
> of
> > > the two corals and that would be of interest to me. ALternately,  the
> > > people who explained the net advantages of "threatened" over
> "endangered"
> > > were unfortunately wrong and this is an effort to correct an earlier
> > > mistake. Or,  political or legal conditions may have changed in ways
> that
> > > made "threatened" the right choice nearly a decade ago but now make
> > > "endangered" the right one.
> > >
> > > My intent is not to challenge either decision. My interest is simply to
> > > have a better understanding of the process by which decisions are made
> to
> > > propose such changes to the public. I am motivated by the fact that a)
> > I'm
> > > sure my students will ask this, and b) I'm too lazy to do all the work
> > when
> > > I have experts at my fingertips. So, I thought this was a good idea. I
> > > apologize if my post implied any animosity; it was certainly not
> > intended.
> > > So, if it is possible to generally explain the changes in the landscape
> > > regarding Caribbean Acropora, I'd love to have an idea of what
> triggered
> > > the decision as it will provide what I think are valuable insights to
> how
> > > policy makers make decisions. I look at this as quite different from
> the
> > > legal background and bureaucratic workings of the Endangered Species
> Act.
> > > I've read through the very helpful exerpts that have been posted and
> that
> > > has been a valuable process. I'm more interested in the "backstory" at
> > this
> > > juncture.
> > >
> > > Thanks again,
> > >
> > > Dennis
> > >
> > >
> > > On Sat, Dec 15, 2012 at 1:52 PM, Sarah Garvin <
> sarah.e.garvin at gmail.com
> > > >wrote:
> > >
> > > > Greetings Coral-Listers!
> > > >
> > > > I read with interest the various viewpoints raised by the proposed
> > > listing
> > > > of 66 species of corals, and I wonder if we would be having the same
> > > > conversations and asking such difficult questions without the
> perceived
> > > > "threat" of listing these species as endangered or threatened?
> > > >
> > > > Does the proposed listing raise such divergent (and impassioned)
> > > reactions
> > > > because it challenges "business as usual"? Do we feel threatened as
> > coral
> > > > enthusiasts (whether aquarium curators, biologists, geologists, etc.)
> > > > because it forces us to question the underlying assumptions that
> drive
> > > our
> > > > work and opinions? Or are the ranges of opinions expressed driven by
> > the
> > > > fact that this is legally-mandated POLICY process, which must use the
> > > best
> > > > science AVAILABLE in a polarized governmental environment? Perhaps
> its
> > a
> > > > combination of all of the above.
> > > >
> > > > I don't have firm answers to any of these questions. Regardless, I
> urge
> > > all
> > > > of you to PARTICIPATE in the public process by *thoughtfully*
> > evaluating
> > > > the use of science in what is, unfortunately, an imperfect (yet
> > > > legally-mandated) government process. There is no "out" once the U.S.
> > > > Endangered Species Act (ESA) ball gets rolling. The best and most
> > useful
> > > > way to express your concerns about the proposal is through practical,
> > > > thoughtful, and applicable commentary on the methods used to develop
> > the
> > > > proposed rule. These types of comments HAVE changed the outcome of a
> > > > proposed rule in the final rulemaking. As a former federal employee
> > that
> > > > had the pleasure(?) of reading and cataloging EVERY. SINGLE. COMMENT
> > that
> > > > came in on a proposed species listing (and critical habitat) rule, I
> > saw
> > > > firsthand how those comments impacted a final rule.
> > > >
> > > > I grant you that the ESA is not perfect; however, it is a powerful
> law
> > > and
> > > > I believe it forces us to confront some uncomfortable concepts. I
> > wonder
> > > > where we might be in the U.S. without the ESA and the questions it
> > forces
> > > > us to attempt to answer as citizens and as scientists. It definitely
> > > points
> > > > out that no discipline operates in a vacuum and every discipline can
> > > > default to tunnel vision. That, perhaps, is the most humbling fact of
> > all
> > > > -- no one person or school of thought has a perfect understanding of
> > our
> > > > surrounding environment and the changes we observe over time.
> Further,
> > > this
> > > > fact is not an acceptable excuse for inaction. We simply must do the
> > best
> > > > we can within the confines of the situation by working together and
> > > > acknowledging our inherent limitations.
> > > >
> > > > Happy Holidays to you all,
> > > > Sarah Garvin
> > _______________________________________________
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> >
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