Can unusual suspects reform the aquarium livestock trade?

CORAL Senior Editor Ret Talbot, lead author of THE BANGGAI CARDINALFISH, coming soon from the Banggai Rescue Project. Opinion By Ret Talbot Excerpt from CORAL, May/June 2013 I was having a conversation last night with a person who knows his way around the marine aquarium livestock trade and hobby. We were discussing the future of both trade and hobby in light of the increasing number of potential restrictions to keeping fishes and other marine animals. Any of these—the current NOAA proposal to list 66 species of coral under the Endangered Species Act or the Invasive Fish and Wildlife Prevention Act, recently reintroduced in the U.S. Congress, for example—could end the aquarium trade as we know it. So could recent, well-funded efforts by, amongst others, the Environmental Defense Fund and the Defenders of Wildlife. I suppose the stunned outrage and anger with which some aquarists have responded to these threats—real and perceived—on social media and in online forums is understandable, but should we really be stunned or outraged? Collection live aquarium fishes with cyanide, a practice still rampant in the Philippines and Indonesia, according to many observers. Image by Lynn Funkhauser, from The Conscientious Marine Aquarist. While there are plenty of solid arguments against many of the anti-trade initiatives that seem to keep popping up like Xenia in a reef tank, the fact of the matter is that aquarists may well be better served by focusing our efforts inward on the aquarium livestock trade itself. Stunned or dead or dying reef fishes after exposure to cyanide. Image by Lynn Funkhauser, from The Conscientious Marine Aquarist. After all, the trade has made itself a viable target for anti-trade activists. Let us not forget recent import data shows the aquarium trade still depends primarily on countries where destructive and illegal fishing techniques are the norm rather than the exception (think cyanide use in Indonesia and the Philippines). Let us not forget that smuggling of species remains commonplace (think illegal wild Banggai Cardinalfish exported from Indonesia or Clipperton Angelfish coming into California). Let us not forget that carelessness and ignorance have led to invasive species introductions that have had significant ecosystem impacts (think Volitans Lionfish in the Caribbean and Caulerpa introductions in Europe and the U.S.). Many important voices have advocated for trade reform over the past two decades, and many positive steps have been taken in the right direction. Nonetheless, none of these efforts have resulted in the type of systemic change required to remove—or at least reduce in size—the bullseye from the back of the aquarium trade. Why is this? Does the trade lack the will? The resources? The imagination? The incentive? Whatever the reason, as my colleague with whom I was having this conversation pointed out, “The same approaches from the same people haven’t worked in 20 years.” Maybe it’s time to look to some unusual suspects as the drivers of change. Game Changers? An important paper was published about a year ago in the journal Zoo Biology that suggests a new group of players may be the ones to effect real change in the aquarium trade. Titled “Opportunities for Public Aquariums to Increase the Sustainability of the Aquatic Animal Trade” (Tlusty et al., 2012), the paper contains an intrinsic premise: the aquatic animal trade is currently deficient when it comes to sustainability. More important, however, the paper points out that it doesn’t have to be, and public aquariums have an opportunity to play an important leadership role in transforming the trade from a threat to a positive force for aquatic conservation. While there are other entities that also have the opportunity to play a significant role in reforming trade, I’d like to take a moment here to explore the potential role of public aquariums. Aquatic tunnel at the Georgia Aquarium, Atlanta: Can public aquariums, using some of the same sources that supply animals to the marine aquarium hobby, help lead the way toward a more sustainable livestock trade? Image: Sean Pavone Photo/Shutterstock. Public aquariums have always had an uneasy relationship with the aquarium hobby. While many curators at public aquariums are home aquarists themselves—and although many of the researchers on staff will credit their passion for all things aquatic to keeping a fish tank as a kid—the overall institutional sentiment has too often been “it’s probably best if you leave it to the professionals.” After all, the aquarium hobby and the trade that supplies it with animals have been responsible for all manner of all-too-public mishaps and missteps that make the institutions—the professionals—want to distance themselves from the “hobbyists.” Gone, some say, are the glory days of late-nineteenth-century amateur scientists seriously engaged with professional scientists in the parlors and conservatories of Victorian homes. As the Zoo Biology paper shows, public aquariums, however, cannot quite so easily distance themselves from home aquarists and the aquarium trade that supplies both with live animals. Public aquariums have a complex relationship with home aquarists and the livestock trade whether they want to acknowledge it or not. The reality is that aquarists visit public aquariums in significant numbers, and visitors to public aquariums are more likely to begin keeping fishes and other aquatic organisms at home than the general public. Put another way, the authors of the paper present data showing public aquariums make new home aquarists. In addition, public aquariums often rely on the same trade networks of collectors and importers as do home aquarists. While some public aquariums mount their own collecting expeditions, almost all rely to a greater or lesser extent on the same importers who supply the animals in our home aquariums. The necessary conclusion of this analysis is that, if the aquarium trade is deficient when it comes to sustainability, then public aquariums are complicit in that deficiency. To be fair, this complicity is offset at the best public aquariums through messaging about conservation and educational initiatives, but the fundamental truth remains that as long as the aquarium trade exists, public aquariums, either directly or indirectly, will play a significant role in supporting that trade by creating new home aquarists, encouraging existing aquarists, and directly acquiring animals through established trade networks. It follows that public aquariums, given this overlap with the aquarium trade, should increasingly be incentivized to take an active role in effecting trade reform, and this should be very good news for the home aquarist. Not Reinventing the Wheel Public aquariums, unlike many of the people and organizations that have attempted trade reform over the past two decades, have resources and expertise giving them a very good chance of actually effecting positive systemic change. Unlike the “same approaches from the same people,” public aquariums are in a unique position to improve the sustainability ethos in the trade. Take, for example, the role public aquariums have adopted when it comes to sustainable seafood (and let’s recall that the seafood trade didn’t make a move until that trade was threatened). In a little over a decade, some public aquariums (such as Monterey Bay Aquarium and New England Aquarium) have, in essence, become non-governmental environmental organizations that have played a leading role in promoting sustainable fisheries and environmental stewardship. They have provided invaluable technical knowledge to the seafood industry through their own research initiatives. They have launched educational initiatives within their institutions that have put the topic of sustainable seafood on the front page and above the fold, and they have taken that message to the general public through a bevy of outreach programs. What if public aquariums did the same for the aquarium trade? As the Zoo Biology paper points out, “…given that public aquariums exist to exhibit aquatic organisms for educational purposes, it is ironic that fish species destined for the plate currently have more sustainability efforts directed at them than do live fishes kept by private aquarists and public aquariums.” Is it too much to argue that the seafood industry’s past could be the aquarium trade’s future? There are many other strengths beyond public aquariums’ engagement in sustainable seafood that could easily be applied to promoting a sustainable marine aquarium trade. Public aquariums, for example, are already educational leaders and have become trusted sources for important conservation messaging on a whole host of environmental concerns from global climate change to conservation of habitat. Think of the ways public aquariums could leverage this educational strength toward developing and teaching best practices for the aquarium trade and informing the public about the risks and benefits associated with aquarium keeping. Through already established social pathways, public aquariums are in a unique position to help educate aquarists about sustainable options for purchasing fishes and other aquatic organisms, and they can be instrumental in creating market-based initiatives linking sustainable aquarium fisheries to retail outlets. Despite government regulations, illegal poaching and uninspected exports of the Banggai Cardinalfish from Indonesia place severe pressures on a species listed as Endangered by the IUCN. Image by Matthew Wittenrich for the Banggai Rescue Project. As respected leaders in sustainability and conservation, public aquariums can accomplish a lot simply by actively supporting sustainable (or, in some cases, withdrawing support from unsustainable) initiatives in the trade. Whether these are specific fisheries, trade routes, wholesalers, or retailers, the support of public aquariums can give credence and bring attention to those elements of the trade that are “doing it right.” Conversely, as trusted thought leaders, public aquariums can marginalize those elements of the trade that are not achieving or at least moving toward sustainability. Likewise, staff researchers at public aquariums are in a unique position to provide much-needed impartial oversight and data analysis of the trade, which may lead to important public-private partnerships including, but not limited to, serving in an advisory capacity to the trade and participating in multi-stakeholder processes toward developing best practices. Of course there are many other areas in which public aquariums can engage the trade in an effort to promote sustainability. Perhaps the most public of these has been the role public aquariums have played in valuable research that can have a direct impact on the trade. For example, through the well-known Rising Tide Initiative and similar programs rearing fishes from eggs collected at public aquariums, public aquariums are playing an active role in closing the life cycle on the captive culture of more species of marine fishes. Increasing the number of captive-bred fishes available to home aquarists—especially beginning aquarists—is a critical effort when it comes to sustainability.  This is, however, a double-edged sword, as too often captive-bred animals are held up as the gold standard of a sustainable aquarium trade. The much more complex story—and one public aquariums are well positioned to tell—is that continuing to support sustainable wild fisheries in addition to increasing captive breeding can provide invaluable economic incentive to conserve aquatic ecosystems. Is it a mandate for public aquariums to reform an aquarium trade that is viewed by many as a threat to aquatic conservation? Of course not, but as the Zoo Biology paper makes clear, public aquariums do have an opportunity here, and engaging in that opportunity does make good sense from an economic and environmental standpoint. While it may not be public aquariums’ responsibility to reform the trade, it should be acknowledged that their failure to act would perpetuate the status quo and potentially even allow the situation to become worse. Conversely, an approach similar to that which aquariums took with seafood a decade ago has the power to effect real change and empower a consumer-driven conservation initiative that will benefit species, habitat, and people. Sea Change Kelp Forest exhibit at the Monterey Bay Aquarium. Image: Sky Collins/Shutterstock. As my colleague remarked last night, “The same approaches from the same people haven’t worked in 20 years.” What has worked, however, are anti-trade activists’ campaigns to end the marine aquarium trade (consider the mounting efforts to ban livestock collection in Hawaii). Isn’t it time aquarists stopped adopting the victim mentality in the face of these threats to the aquarium hobby? Isn’t it time aquarists supported real and substantive reform? Before criticizing those who are criticizing the trade, aquarists would be wise to do some introspection and decide on which side of history they want the trade to fall. Will the aquarium trade and hobby be viewed as a force for good? Will aquarists be seen as standing in the trenches on the front line of ocean conservation? Or will the aquarium trade be seen as little more than wildlife trafficking with a “get it while you can” mentality? As someone who has covered sustainability issues in the aquarium trade for several years now, I believe the necessary trade reform is going to be driven by some new players—entities that have the incentive, resources, and imagination to achieve what others have been unable or unwilling to achieve. As discussed above, public aquariums and, by extension, the American Association of Zoos and Aquariums (AZA) and the World Association of Zoos and Aquariums (WAZA) will play a leading role in positive reform, but so will others. Home aquarists and many in the trade have not traditionally embraced many of these “new” players. In fact, some would be hard pressed to even identify them as players, but their efforts and engagement in the issues that will make or break the aquarium trade have already proven they are the ones with the incentive, the resources, and the will to make a change. Expect, along with public aquariums, to see the Petcos and Disneys and Sea Worlds of the world define the agenda in the coming months. Expect the Pet Industry Joint Advisory Council (PIJAC) to engage on behalf of, and in conjunction with, these entities. Aquarists and individuals involved with the trade have a choice here—will the likes of public aquariums, Petco, Disney, and Sea World be embraced or shunned? Will aquarists become fractured and segmented over petty arguments about who really knows best and what the best path forward ought to be, or will aquarists support these emerging thought leaders and enter into a constructive dialogue with them? Will those in the trade expand their relationships with these players and actively collaborate to increase the sustainability of the trade, or will they insist on a business-as-usual approach that will only push the trade closer to the abyss? The marine aquarium hobby and livestock trade is at a crossroads. It finds itself at the intersection of outdated models and new approaches, resistance to change and openness to new possibilities. Society is becoming “greener,” and while some of that is no doubt little more than greenwashing, there are real steps being taken toward a more sustainable future. A growing number of consumers are not only familiar with sustainability—they are now demanding it. Corporate responsibility initiatives, often born of enlightened self-interest, are on the rise. The aquarium trade can and should be part of this. What if, for example, we could hold the aquarium livestock trade accountable by walking into the local fish store and knowing which fishes were collected with cyanide in the same way DNA testing can insure accountability for the seafood industry? The aquarium industry is going to change; the only question that remains is who will be responsible for that change. Will it be a change from within, driven by those of us who understand the trade, or will it come from anti-trade activists and Draconian measures levied by those who know little about the real impacts and educational rewards of keeping an aquarium? It’s not difficult to imagine that we are on the brink of an important sea change, and I, for one, embrace this new direction. References Tlusty, M.F., A.L. Rhyne, L. Kaufman, M. Hutchins, G.M. Reid, C, Andrews, P. Boyle, J. Hemdal, F. McGilvray, and S. Dowd. 2013. Opportunities for public aquariums to increase the sustainability of the aquatic animal trade. Zoo Biol 32 (1): 1–12. doi: 10.1002/zoo.21019. Epub 2012 May 1.

Comments on Endangered Species Act and Corals

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 BRT resorted to what can only be called guessing in the absence of data to make assumptions as to what the Critical Risk Threshold (CRT) might be in the next 100 years. There is no doubt that the impacts of anthropogenic activities on the oceans and global climate present challenges to the survival of many marine and terrestrial species.  Indirect impacts are compounded by the effects of direct impacts. Is the mere threat from anthropogenic impacts sufficient for ESA listing? Will listing the species in question provide them protection and benefits? These are important questions that must be considered. For the past 7 years I have been heavily invested in several projects with the aim to better understand the global trade in live aquatic animals  (referred to as the “aquarium  trade”).   We have published several papers that outline the rapid changes that the aquarium trade has undergone in the past two decades. Most recently with funding in part from NOAA we have investigated the importation of marine aquarium fish and invertebrates  into the United States. This undertaking  is the largest effort of its kind.   We raised numerous issues with the current level of understanding of the aquarium trade and mode of monitoring this trade at the federal level. Beginning in 2011 at the request of the Ocean Foundation & NOAA, I attended two coral mariculture workshops in Bali Indonesia. During the workshops I gave an overview of the global trade in marine ornamental species with a focus on the coral trade.  The outcome of this report has been published in the peer-reviewed literature and I would like to highlight a few key points with a focus on the current listing proposal. Indonesia had developed  an advanced coral maricutlure  industry, with rigorous standards of operation. These rigorous standards clearly define what a maricultured coral is, how corals are to be produced and the rules that govern an aquaculture operation. This includes labeling of colonies to provide an auditable paper trail. So in contrast to the BRT’s assessment that there is no documentation, there actually is a well- documented maricutlure standard for corals published in 2008.  Furthermore, after review of the BRT’s supporting documents, I am under the impression that the BRT is unaware of the standards that CITES requires for the export of listed species with codes C, F, or R, indicating a general unfamiliarity with the trade in live corals. I would like to take a few moments to clarify these requirements.    Exporting countries such as Indonesia must develop guidelines for listing export source codes for species with the source codes C, F or R.  This is not something exporters can simply do themselves.   In the absence of such guidelines, and in contrast to Indonesia, coral aquaculture operations in the Solomon Islands have been exporting maricultured corals under their wild quota (Source Code W) for several decades even through it is maricultured product. It is simply easier to export cultured products under wild quotas than deal with additional layers of paper and governmental  support  that  is  not  available.  Interestingly,  cultured  corals  from  the  Solomon  Islands represent about half of the total volume of corals exported from this country, yet the CITES database lists all trade as wild. It was only after visiting several coral farms and examining the CITES trade database that we were able to accurately document in our paper published in Conservation Letters, a striking and rapid change in the coral trade.  For most corals, the trade is rapidly shifting from a wild fishery to aquaculture.  This process is neither ambiguous nor modest.  It is nothing short of industrial in nature. Numerous exporters have closed distant collection stations throughout Indonesia in favor of near shore farming  operations.  This  change  is  important  on  several  fronts.    While  there  are  examples  of  well managed wild coral fisheries (ex. Fiji and Australia), there was little argument that the wild coral harvest within Indonesia had caused localized impacts to coral populations and associated habitats.  Indonesia has importantly recognized this, in part due to the efforts of Dr. Andrew Bruckner (at the time with NOAA) and made a fundamental shift in policy.  It is now national policy to support an aquacultured coral trade. They have begun phasing out the wild quota for many taxa. In essence Indonesia has made it national policy to support a more responsible trade.  As part of this effort Indonesia requires 10% of the coral production from these aquaculture operations to be out-planted in restoration efforts.   Most impressively nearly every exporter at the two NOAA funded workshops,  even those that did not have coral farms, recognize the need for a more responsible coral trade. Most are eager to be part of the solution and put behind them several decades of destructive fishing. The changes in the coral trade could spark a more positive movement within the broader fish trade as exporters are more connected to their habitats through their coral farms. Likewise the Philippines and several other countries have begun aquaculture-based operations. These operations could easily become the largest coral enhancement projects ever undertaken. At present, Indonesia exports over 400,000 cultured corals per year, over 75% of all Acropora sp. are now cultured.  This level of production requires that over 40,000 fragments will be available for restocking to the wild on an annual basis.  This number will increase and I would forecast that annual production in the next 5 years to likely exceed a million corals. Out planting requirement provides enormous opportunities for the  stock  enhancement  of corals  designated  as species  of concern,  threatened  and/or  endangered. Coral farmers could be engaged to produce 10,000s of fragments annually for a given species solely for the purpose of out-planting on near by reefs.  If properly coordinated these efforts could mitigate decades of destructive fishing practices. This opportunity is of course contingent on a thriving coral trade. It is very clear that the BRT omitted the use of experts in the trade of corals from their SRR and other documents.   The BRT makes several unfounded comments in their SRR and omits important areas of wild  collection.    Comments  from  Queensland,  Australia  provided  some  details  about  the  scope  of Australia’s trade during the SRR’s comment period.  This omission in the SRR again calls into question’s the  BRT’s  ability  to  properly  review  the  coral  trade.  Furthermore  there  are  misleading  statements included in the SRR. The BRT should cite supportive documentation  for the following statement (page 73, quoted below, underlined and in bold). If unable to support this statement, NMFS should remove or retract the following statement from their documents. From the reefs of Kāne`ohe Bay, Hawai`i, the average number of feather-duster  worms (Sabellastarte sanctijosephi) collected per year for the aquarium trade was reported to be 43,143  (Friedlander  et  al.,  2008).   As  each  feather  duster  worm  is  obtained  by breaking away the coral, the total coral and habitat damage can be significant. I looked into this allegation  and could find no evidence  for such a statement.   I do not know of any literature  or  communication  that  can  support  such  outlandish  urban  legends.  This  again  serves  as examples of the SRT’s unfamiliarly with the aquarium trade. It is abundantly clear that the BRT failed to use current science and/or commercial information available about  the  coral  trade  in  the  SRR.    The  BRT  suggests  they  cited  commercial  data  by  presenting information from the CITES database. However, this should be not construed as an evaluation or ‘use’ of commercial data.  The BRT merely cut and pasted numbers from a data query and failed to interpret such information. Therefore, it is in my opinion that the BRT arbitrarily used the CITES database to form an opinion of the trade and its impact on the corals in the petition.     In large part due to their failure to consider  both  scientific  and  commercial  data  the  BRT  made  serious  errors  in  their  CRT  values.  An example  of  this  is  found  for  Euphyllia  paradivisa,  where  “trade”  appears  to  be  the  sole  factor  in evaluating  this  species  to the  endangered  status  when  compared  to the  BRT’s  CRT  values  for other members of the genus.  From the BRT’s SRR page 436: Factors that increase the potential extinction risk (higher likelihood of falling below the Critical  Risk  Threshold)  for  Euphyllia  paradivisa  include  its   heavy  involvement  in international   trade   combined   with   its   rare   existence   but   conspicuous   colonies, suggesting it is vulnerable to overexploitation. The species appears bleaching-susceptible. Its geographic distribution is also somewhat restricted, centered in the threat-prone Coral Triangle Region. Narrow geographic distribution increases the likelihood that changing conditions  or  a  local  impact  in  a  particular  location  can  push  the  species  below  the Critical  Risk  Threshold.  No  known  factors  were  noted  by  the  BRT  to  reduce  the extinction risk of this species. The risk from the international trade is only near term due to exploitation by the trade in wild harvested corals.  Indonesia’s change in coral sourcing from wild to maricutlure will eliminate this threat in the near future. I have personally visited a coral farm with 1000s of colonies of this species in production and they are expanding their production yearly. Because of the changes in sourcing, there is no reason to consider the coral trade a long-term threat to this species survival.   It is likely the species could benefit from the coral trade in the near future.   If the BRT had consulted with trade experts, their conclusion may have differed. With respect to the ‘science-based’ determination of this proposed listed, I am not the first nor will I be the last scientist to raise a red flag that the ‘science’ based determination is highly flawed.   The review team itself notes these flaws.  The external reviewer Dr. Terry Hughes questions the validly of the method and use of the literature. Examples include but are not limited to: The methodology is weak, as illustrated by the disparity in scoring by different members of the BRT. A major weakness of any analysis of coral vulnerability to extinction is the paucity of species-level abundance data at regional scales. 1. Are the results of the Extinction Risk Analysis supported by the information presented?  Generally,  no. Page 3, third paragraph,  line 4 states: The petition asserted that all of the petitioned species have suffered population reductions of at least 30% over a 30–year period, relying on information from the IUCN. Here, “asserted” is indeed the appropriate verb, since there is very little species-specific data on abundance. It would be worth explaining here how the various IUCN categories relate to different levels of population decline, and how Carpenter et al. 2008 came to their conclusions. The BRT’s responses to this reviewer are not at the level that would be expected of a peer-review of this detail.  The BRT often dodges the reviewer’s comments. To this scientist, the simple act of voting probability of extinction risk based on the literature does not give credence to a process, regardless of the reasons for undertaking such endeavors. This is not to say the species  in  question  do  not  need  some  level  of  protection,  it  merely  states  the  obvious,  the  method employed is useless for the determination  of endangerment  for most species due to a lack of data. To highlight this I would like to focus your attention on two species presented in the report.  The Caribbean pillar coral Dendorgyra cylindrus is reasonably well studied, with detailed accounts of abundance and distribution throughout its range. The assessment is clear with its classification as “rare” but conspicuous, citing  population  lost,  accounts  of  bleaching  and  other  environmental  trauma.      The  species  is  well delineated and defined. There is a lot of information supporting the conclusion that its population is at least threatened. The BRT had access to these studies and rated this species probability of extinction as (CRT value) 74%.  In sharp contrast a poorly studied, little known coral, the deep water Pacific Acropora species  A. jacquelineae,  a species  with  questionable  taxonomic  status,  lacking  any  density  estimates, limited distribution information, and is only noted as uncommon or rare by at most a handful of reports received a higher rating.   The BRT assessment  of this species is marked with statements  such as “not much species-specific  information…”   and “are poorly known”.   Yet the BRT gives a CRT ranking of 76%, citing the “susceptibility  of the genus Acropora to common threats” such as bleaching. This fast growing species is rated 2% more susceptible than a very slow growing shallow water Caribbean species that has demonstrated to be highly susceptible to bleaching and is clearly a rare species. How the BRT could  make  a  determination  as  to  the  status  of  a  species  with  no  creditable  data  is  beyond  my understanding. Based on this logic, it would seem the BRT should make a genera level determination that all members of the Acropora are threatened or endangered; and yet some were not listed at all. The BRT used invalid studies in their assessment.  An example of the use of highly questionable literature is provided below.  While reviewing the literature cited in the BRT for the proposed endangered species Euphyllia  paradivisa,  I  had  an  opportunity  to  review  an  unpublished  Masters  Thesis  (SRR  citation Tibbits, 2009).   This Thesis, the only citation that provides data on this species beyond CITES import values or an ID book reference. A brief review of this thesis suggest it is highly flawed: While aquarium studies are necessary for understanding the impact of ocean acidification on species  in a controlled  manner,  results  are invalid  if the methods  used for control result in confounding variables. Current and expected acidification of ocean waters is a CO2 species controlled process.  Controlling pH of carbonate buffered saline waters with organic weak acids does not model this process, nor does it effectively isolate the one variable that was actually monitored in this study: pH. This weak acid does not fully dissociate in aqueous environments, setting up an additional buffer system and thus confounding what is known about the buffering capacity and constituencies of the water. Aside from the complexities  of organic  acid influence  on biomineralization  processes, adding acids to the water will inherently change the carbonate-bicarbonate  balance of the water  column.     This  balance  is  directly  related  to  the  mineralization  of  carbonate structures and is modeled by the saturation state (Omegacalcite-aragonite).  The climate change literature documents the interaction of this term on other species quite well.  Ignoring this fundamental   concept  effectively   invalidates   this  study.     No  water  quality  data  is presented, including parameters that would allow one to reconstruct Omega.   No pH timeseries  data  is  presented.     No  calibration  procedures  for  the  instrumentation   is discussed. In short, almost every one of the reporting guidelines in the National Research Council’s “Ocean Acidification: A National Strategy to Meet the Challenges of a Changing Ocean” have  not  been  met.    The  challenges  that  exist  regarding  pH  manipulation  and  data reporting  for  appropriate  analysis  of  results  are  many.    This  study,  while  valiant, contains too many oversights to be considered for policy decisions and should be approached with caution. In light of the current state of science any thoughtful review or reading of this Thesis would result in a similar conclusion, yet it is include by the BRT in the SRR numerous times. My comments in this letter are not to say that data poor species do not deserve attention or further study. However I must suggest that the entire process could be easily questioned with such examples scattered throughout the entire report.  It would appear that any species under NOAA’s purview that is under some recognized global threat (climate change / OA) and has little to no formal data on distribution could be listed  on  the  ESA  and  if  it  considered  “rare”  it  could  be  immediately  listed  as  endangered.  This  is regardless  of the taxon’s  status as a valid species  (i.e. rare species  are likely  hybrids, Richards  et al.2008). It would seem logical that the first step for data deficient species would be to study the species. NOAA’s listing of the Caribbean Acropora species is exemplary of this more measured approach. Considering the apparent reliance on the IUCN database for determination of status, I queried the IUCN database for species with similar threats and you quickly recognize that the BRT methods are a road map for the listing of hundreds if not thousands of species under the ESA.  The question is whether the current proposed   listing  or  future  listings  prevent  extinction   or  facilitate   recovery.   This  remains  highly questionable. The ESA is a static law, the authors of the Act likely never envisioned the present actions, and therefore is likely inadequate in its protection of most of the proposed species. The Act provides nothing more than a feel good listing for these foreign species. Especially when the nature of the current trade is taken into account.  The ability of the Act to prevent extinction is likely undermined by its impact on the reasonable coral trade. If the trade is lost, the economic incentive to restore damage habitats through industry out- planting would be lost.  If as a result of these listings, the US closes its borders to the coral trade, we will lose the influence of being the largest importer of corals.  This influence is the most likely reason for the impressive  changes  we  (members  of  the  NOAA  funded  coral  maricutlure  workshop)  witnessed  in Indonesia  over  the  past  two  summers.  While  NOAA  has  some  discretion  with  respect  to  trade  for threatened species, as presently interpreted, the Act prohibits ‘take’ for species listed as endangered.  It is my conclusion that the precautionary approach to protection of these species is to afford the protections to species that are truly threatened while giving the agency flexibility in its handling of trade. In closing I urge NMFS to reconsider the proposed rule to ensure they do not damage current and future conservation actions. Thank you for your time and attention. Sincerely, Andrew L. Rhyne, Ph.D.

To feed or not to feed?

I say yes provided you are watching PO4 and NO3 levels closely.  Feeding corals has been disputed and discussed for many years and it was once though that corals derive much of their nutrition from...

Long Overdue Review of the 1″ Multi Sea Swirl from Aquarium Currents

Before we get to talking about the Multi 1″ Sea Swirl in detail, we wanted to first apologize to Ed and the rest of the gang at Aquarium Currents, Inc. for taking such a long time to get this review underway. Unfortunately, life got in the way (new baby, moving homes, etc.) and we just never got the chance to give this product the proper un-boxing and review that it deserves. But, we’re rectifying all that with the following “first impressions” review of the Multi 1″ Sea Swirl, which we’ll be following up with a more in-depth look at the Sea Swirl in action. As with the Deluxe Sea Sweep we reviewed last year, the Multi 1″ Sea Swirl comes in a box full of all sorts of goodies. Everything was meticulously packaged and labeled, with various threaded and barbed fittings that will allow for the easiest incorporation into your aquarium setup. Speaking of easy installation, the mounting brackets on the Sea Swirl are super simple to use. They are basically nylon thumb screws that tighten down to secure the Sea Swirl to your aquarium. Adjusting these screws is about as easy as you could imagine, and the padding on the inside of the bracket keep all of that tightened hardware from scratching your delicate acrylic. As for assembly, the Sea Swirl comes pretty much ready to use right out of the box. All you have to do is pick the fittings of your choice and screw them on. Some PVC glue may be required on the outlet portion of the flow alternating device. All in all, there are several different options for combining the fittings. Barbed fittings allow you to attach flexible tubing from your feed pump to the Sea Swirl, and the PVC fittings give users the choice to hard plumb the device into their flow scheme. If you do hard plumb the Sea Swirl, we recommend using a union fitting so that you can take it off the tank for maintenance or moving things around. The fittings are all 1″ and 3/4″, which are the two most popular sizes of plumbing in the aquarium hobby. So, by now, you might be asking why the Sea Swirl is an important add-on to your aquarium. After all, you’ve already got powerheads and water pumps moving water all throughout your setup. Well, to start, we have to get the point across that water flow within a reef aquarium is extremely important. Some would even argue that water flow is up there on the same level of importance as reef aquarium lighting, but the laminar flow of water pumps doesn’t always cut it since the quality of the water flow is far more influential than the total amount of flow. With all of that linear water flow in the tank, having a source of alternating flow can have a big impact, and the Sea Swirl does just that. It rotates the water outlet a full 90 degrees every 30 seconds, giving a bit more randomness in your tank that the corals will just love. And it will help prevent detritus settling too. All in all, we were very pleased with the build quality of the Sea Swirl and can’t wait to see what long-term effects it will have on nutrient export in our test aquariums. Another big advantage to using the Sea Sweep and Sea Swirl from Aquarium Currents is they they require no maintenance. Just plug it in and you’ve instantly boosted the effectiveness of your once stationary powerheads.