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

Juan Levesque shortfin_mako_shark at yahoo.com
Mon Dec 17 19:18:12 EST 2012

FYI. Federal agencies are required to abide by the Data Quality Act; they take the DCA serious.

Juan C. Levesque
Sent from my Verizon Wireless 4G LTE Smartphone

-------- Original Message --------
Subject: Re: [Coral-List] Impact of listing 66 coral species on coral	research
From: Sarah Garvin <sarah.e.garvin at gmail.com>
Date: Mon, 17-Dec-2012 11:00
To: coral-list at coral.aoml.noaa.gov

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 (
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,

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
To: Sarah Garvin <sarah.e.garvin at gmail.com>
Cc: "coral-list at coral.aoml.noaa.gov" <coral-list at coral.aoml.noaa.gov>
> 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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