16 Apr, 2013 Re: Listing of 66 Reef-Building Coral Species; Reclassification of Elkhorn Acropora palmata and Staghorn Acropora cervicornis

I  had  been  following  the  proposed  listing  for  several  years.  It  was  not  until  the  proposed  rule  was published that I had time to fully read the Biological Review Team’s (BRT) Status Review Report (SRR). I  must admit I made the assumption  that NMFS  would  do a fine job reviewing  the topic at hand. It become apparent in my review of the BRT’s assessment that they had little to no knowledge of one of the key areas upon which the SRR is based, namely the trade in corals (including those for home aquariums, as well as dried curio items). I am writing to; 1) provide additional background  and information  on the trade in corals, noting some dramatic  changes  particularly  regarding  live specimens,  that has been omitted  from this review,  2) to question and express my concern over listing of species as endangered with almost a complete lack of any data or information. While it cannot be understated, this process is an enormous task for any agency to undertake.  Reviewing the status of 82 species with ranges cover two vast regions of the World’s oceans presents challenges the authors of the ESA likely never envisioned. Corals are often not discrete populations and thus some of the petitioned “species” are of questionable status.  Our current understanding of the topic is lacking and this lack of understanding makes it nearly impossible for anyone to determine with a level of certainty what a population, species or hybrid is. Our knowledge of Pacific corals is so limited that the MORE: Comments on Endangered Species Act and Corals