by Carey Morishige Martinez, Executive director, AIC Secretariat
Today, the U.S. All Islands Coral Reef Committee (AIC) submitted information and comments in response to NOAA Fisheries’ request for information (NOAA-NMFS-2014-0158) regarding rule-making for the 20 newly listed coral species under the Endangered Species Act (ESA).
This issue has and continues to be an important topic for the AIC for several years now. The AIC’s coral reef jurisdictions depend upon coral reef ecosystems for their economic, ecological, and social value. Coral reefs provide key ecological services valued in the billions of dollars that help define jurisdictional economies. Coral reefs are also an integral part of everyday life in these places.
The AIC recognizes that there must be a balance between resource protection and use. We understand that there are mandates and legal aspects behind resource protection, just as we know there are economic costs and traditional/cultural values behind use. This is what makes achieving balance between the two so difficult and yet so very important.
Towards that end, the AIC provided the following recommendations (exceptions to 4(d) rule) to NOAA as we believe they are not necessary and advisable for the conservation of the 20 listed corals:
- Accidental take associated with common, non-commercial fishing practices, specifically hand gathering, spearing, netting, angling, and trapping.
- Accidental take associated with minor accidental impacts (i.e., we don’t want to make innocent people guilty). Thresholds should be defined for what constitutes the maximum allowable impact under this exemption.
- The collection, maintenance, and use of listed species for research and educational purposes approved and permitted under the authority of the appropriate State/Territorial/Commonwealth resource agency.
- The collection, maintenance, and use of listed species for cultivation projects and programs (including restoration, the aquarium trade, and transplantation) approved and permitted under the authority of the appropriate State/Territorial/Commonwealth resource agency.
- Minor routine maintenance of commercial ports and harbors, as allowed under the authority of the appropriate State/Territorial/Commonwealth resource agency.
Additionally, NOAA should highly consider the operational efficiency of any ruling (4(d) or critical habitat) as a critical component to the implementation and administration of that ruling and ultimately conservation of the 20 listed corals.
Understandably, a prudent approach must be taken when determining critical habitat. The AIC recommends that NOAA conduct assessment surveys, prior to any critical habitat ruling, in areas such as ports, harbors, and marinas to determine presence or absence of listed corals as those locations in particular are economically critical to the states, territories, and commonwealths where these corals are found.
We know a lot of hard work and manpower has gone into this effort already, with likely much more to come. The AIC greatly appreciates NOAA and their staffs’ efforts on this issue. We look forward to continued communication and collaboration!