[Coral-List] What agency should list corals under the Endangered species act?

Will Nuckols wnuckols at erols.com
Thu Mar 28 11:12:50 EDT 2013

DOC has commerce/trade as a mission, yes, but DOI has extraction based
bureaus whose oil and gas and mining interests are often at odds with the
interests of the NPS or USFWS. 

The oddity of the NOAA in DOC and USFWS in DOI split has to me to do more
with efficiencies which might be less effective through things like
MOAs/MOUs than having combined staffs. The arguments about keeping the
DOC/NOAA and DOI bureaus separate have many facets, but rather than delve
into those public policy issues, to your specific question about DOC vs. DOI
I believe at the end of the day what matters primarily is who the
Secretaries are in those Departments.  The President has tapped Sally
Jewell, known for positions on terrestrial issues and largely untested about
her positions on ocean issues (other than some questions asked in her
nomination hearing in Committee in the Senate on oil and gas drilling
offshore), to be the Secretary of the Interior.  Her nomination has passed
out of Committee en route to the floor, but a date for a floor vote is not
yet announced. 
At DOC the Department has lacked a Secretary since last summer, and as of
yet no nominee to fill the vacancy has been announced. And with Dr.
Lubchenco having left her post NOAA's top slot is vacant too (as are other
NOAA political Senate confirmed positions). 

Perhaps rather than where corals' protection resides, a focus on who runs
those Departments is a course of action that concerned coral lovers could
take. Looking to the Administration to select nominees who will protect the
resources, and to the Senate to inquire about the nominees intentions, is
something the community can do this year. 

Looking to move agencies or alter the jurisdiction of agencies over coral
resources requires specific actions by Congress, and in addition to the
general gridlock problem it also treads into areas that require multiple
Committees to work together in both Houses of Congress. That bar may be too
high and take too long, especially for species who are on, or dangerously
near, the brink of no return. 

A focus on getting quality people into the political leadership positions
for the second term may be the best investment of one's time. 

Will Nuckols 
W.H. Nuckols Consulting

-----Original Message-----
From: coral-list-bounces at coral.aoml.noaa.gov
[mailto:coral-list-bounces at coral.aoml.noaa.gov] On Behalf Of Dennis Hubbard
Sent: Wednesday, March 27, 2013 12:22 PM
To: Eugene Shinn
Cc: coral-list at coral.aoml.noaa.gov
Subject: Re: [Coral-List] What agency should list corals under the
Endangered species act?

Gene makes an excellent point. I've always been uncomfortable placing any
environmental oversight into an agency in which economy has any significant
priority. This is not to say that there are not many intelligent and
well-motivated individuals within that group. However, this association
necessarily monetizes nature.

Certainly we scientists might benefit from occasional fiscal reality, but it
seems more appropriate that an agency tasked to oversee commerce (i.e., to
see that it proceeds smoothly) should be one of the commenting parties and
not the one setting natural-resource policy.... unless of course we see
corals and the like as entities that primarily contribute to healthy


On Tue, Mar 26, 2013 at 2:58 PM, Eugene Shinn
<eugeneshinn at mail.usf.edu>wrote:

> *What agency should list corals under the Endangered Species Act?*
> Dear Listers,
> Because of a petition from the tax exempt Center for Biodiversity, 
> NOAA National Marine Fisheries Service (NMFS) will in all probability 
> list 7 common Atlantic corals as threatened and upgrade /Acropora/ 
> species to endangered.My question is, should the listing be 
> accomplished by an agency under the Deparment of Commerce? Is there a
conflict of interest?
> Should instead the Department of Interior, e.g., National Park Service 
> or Fish and Wildlife, be the official listing agency? Why do I bring 
> this up?
> My concern is because any agency under the Department of Commerce that 
> also supports research is not likely to ban or regulate products, or 
> activities, that may negatively affect commerce and/or economics. For
> example: suppose the "gold standard" 96-hr LD-50 bioassay demonstrated 
> that the mosquito pesticides Dibrom, Nalid, and Malathion, commonly 
> sprayed in the Florida Keys, is detrimental to corals?
> That finding would present a problem if not an onerous catch-22 
> situation because banning these substances could have a huge negative 
> effect on the Florida Keys economy, especially the all-important 
> tourist economy.Ironically, after all these years of coral reef 
> research, no one has yet performed this straightforward bioassay, even 
> though it is well known that these pesticides affect marine life as 
> well mosquitoes and butterflies. Note that the Department of Interior 
> does not allow spraying of these toxic substances in their parks or on 
> park-owned property on Key Largo. Such spraying is also not allowed 
> over the State-owned Florida Keys Marine Laboratory on Long Key. The 
> toxic effects there are well known to marine scientists. I won't bring 
> up the endangered Key Largo Wood Rat that is used to curtail 
> commercial activities on State lands on North Key Largo .
> But not to worry, if /Acropora/ status is elevated to "endangered," it 
> will likely be impossible to conduct those needed bioassays because by 
> its very nature the LD-50 test requires the sacrificing of some 
> organisms. This bioassay basically determines the level of a substance 
> required to kill 50 percent of the organisms in a 96-hr period. That 
> badly long-needed information could then be used to determine if such 
> levels are present in marine waters off the Florida Keys, including 
> the saline groundwater beneath the keys that ultimately upwells 
> offshore. I have to wonder why this simple test has never been done? 
> Since these tests have not been attempted after all the years of 
> concern about dying corals, it seems unlikely the tests will likely 
> happen while it may still be legal to conduct them. Catch-22?
> On the other hand, if the Department of Interior were to be in charge 
> of listing (they already have control of corals under their 
> jurisdiction at Dry Tortugas National Park, Biscayne National Park, 
> and Everglades National Park), there would be no conflict. Because of 
> their philosophy, the Park Service is generally not constrained by effects
on commerce.
> One might add that similar LD-50 bioassays should be conducted on 
> sunscreens. Sunscreens are banned from use by swimmers in coral reef 
> marine parks in Mexico. Do the Mexican authorities know something we 
> do not?
> One can only imagine other activities that will be affected once these 
> new endangered species acts go into effect. One might also wonder why 
> we presently have 3 federal and 1 state agency protecting corals?
>   Gene
> --
> No Rocks, No Water, No Ecosystem (EAS)
> ------------------------------------ 
> -----------------------------------
> E. A. Shinn, Courtesy Professor
> University of South Florida
> College of Marine Science Room 221A
> 140 Seventh Avenue South
> St. Petersburg, FL 33701
> <eugeneshinn at mail.usf.edu>
> Tel 727 553-1158
> ---------------------------------- -----------------------------------
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Dennis Hubbard
Dept of Geology-Oberlin College Oberlin OH 44074
(440) 775-8346

* "When you get on the wrong train.... every stop is the wrong stop"*
Benjamin Stein: "*Ludes, A Ballad of the Drug and the Dream*"
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