[Coral-List] Delayed Ruling on proposed ESA coral may wipe out 2014 summer field work in US waters?

[Delbeek, Charles]

Hi All,
I have been reading NOAA's web page on the proposed coral listing and the process for applying for an ESA 10(a)(1)(A) permit and it struck me that, if I am reading this correctly, there may be implications for working with Acropora spawning in the FL Keys next summer. Namely, any field work will require this permit and since it takes a year to get one according the web site (http://www.nmfs.noaa.gov/pr/permits/corals.htm) it may be too late already for this coming field season.
My questions would be since the ruling has been delayed until June 2014, can you apply for an ESA permit even though the animal is not yet listed? If yes, would the process start when the permit is received or do you have to wait until the coral is actually listed?
It appears that if the answers above are no, and the ruling is approved, there will be no way to get a permit in place to allow coral spawning work to take place with Acropora in the Keys next summer. It seems counterproductive to create a ruling that will actually prevent conservation work on an endangered species for at least one year.
Hopefully there will be some sort of mechanism in place to allow for the rapid approval of permits to allow this critical work to continue next summer in the Keys.
My hope is that even if the ruling is approved and both Caribbean Acropora species are listed, it would not go into effect until after the 2014 Acropora spawning season is over.
If anyone can offer any insight into this process, it would be greatly appreciated.
Best regards,

J. Charles Delbeek, M.Sc.
Assistant Curator, Steinhart Aquarium
California Academy of Sciences

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cdelbeek at calacademy.org<mailto:cdelbeek at calacademy.org>
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