CORAL Featured Video: Shane Canellis’ SPS Reef

http://www.youtube.com/watch?v=pqNA0gYWRpw Here’s a very nice SPS reef with thriving corals in a 4x2x2 footprint. (Approximately 120 gallons or 450 L, 120 x 60 x 60 cm.) Interesting sound track is a bonus. Credit: Shane Canellis | YouTube “You can find more info on the tank at www.masa.asn.au Profile ssbk23. ”

Algagen Announces PhycoPure Zooxanthellae

Algagen announced today their new live Zooxanthellae under the Phyco Pure product line.  As you know, Zooxanthellae has a symbiotic relationship with many corals and this product is aimed at potentially bringing older reefs and corals back to a healthy...

Aussie Hammer Varieties

Lots of new colors and patterns showing up in recent Australian Euphyllias, evidenced by this photo from Todd Cherry.  He’s even got the Aussie Yellow Splatter in there for good measure.  It’s hard to believe that corals like this, which grow so well in...

ESA Testimony of Christopher P. Jury

26 Apr, 2013 Testimony for listing 66 coral species under the Endangered Species Act Background In principle, I find that listing many of the proposed coral species under the ESA is warranted, is based on the best available science, and is of value. I commend the biological review team and the other team members involved in this process for undertaking the huge amount of work involved in this process, and for navigating the monumental task of responding appropriately to the proposed listing. However, a variety of new scientific information has come to light since the period when the proposed listing was drafted which should be taken into account and, in my view, should affect the listing of several species. In addition, I must stress several critically important aspects of implementing the ESA if or when any of these species are listed. Last, coral taxonomy is in flux and I can say with certainty that much of the taxonomy will change within the next few years. These changes need to be anticipated and mechanisms thought out to accommodate substantial changes in what constitutes recognized species, and their listing status. First, allow me to make specific comments about several of the species proposed for listing which, in my view, should change the proposed listing status. Other than the species specifically discussed below I am either supportive of listing as proposed (either as Endangered or Threatened) or do not have specific views on the proposed listing of the species. As a primer to this discussion I will point to several recent studies which support a change in the proposed listing status. The first is a study by van Woesik et al. (2012). This study used an a priori trait-based analysis to estimate coral extinction risk and then compared the estimated extinction risk to actual coral extinction events in the Caribbean. They found that, rather than a random or unpredictable event (as would be expected under Neutral Theory) both extinction and persistence (i.e., the lack of extinction) were highly predictable using their trait-based analysis. The authors further applied these criteria to estimate the extinction risk for extant, modern corals. Based on these results, several modifications to the proposed listing status of several species are warranted. Second is a pair of studies by Maynard et al. (2008) and Guest et al. (2012). Chief among the threats to corals is bleaching due to thermal stress, as related to climate change. However, very few data are available to evaluate the potential for corals to adapt or acclimatize to elevated temperatures. It is often assumed that corals cannot adapt or acclimatize fast enough to keep up with climate change, but this assumption is based on shockingly little data. Maynard et al. (2008) and Guest et al. (2012) provide some of the only datasets available to assess whether this assumption is actually true. In fact, in both datasets many types of coral show surprisingly large (~0.5-1°C) increases in thermal tolerance after a single mass bleaching event, due to either adaptation or acclimatization. Importantly, genera such as Acropora and Pocillopora which are often among the most thermally sensitive genera, showing severe mortality after thermal stress, were among those showing the greatest increase in thermal tolerance (i.e., the greatest adaptability). These datasets demonstrate that if we assume that coral thermal tolerances will remain the same into the future, under conditions of thermal stress, we will substantially overestimate their extinction risks. Given this background, I will now discuss each species whose listing I propose should be changed and give reasons for this change based on these new data. Species-specific comments Atlantic/Caribbean Montastraea annularis, faveolata, and franksi; Dendrogyra cylindrus: Based on the criteria developed by van Woesik et al. (2012) (which proved highly effective at predicting both extinction and persistence of corals in previous geologic time) these four species are very unlikely to go extinct as compared to other corals. Therefore, these four species do no warrant designation as Endangered but should be listed as Threatened. Agaricia lamarcki: Based on van Woesik et al. (2012) the genus Agaricia, including A. lamarcki, is expected to be vulnerable to extinction. This species should be listed as Endangered, and not as Threatened. Likewise, other members of the genus Agaricia and Undaria as well as Helioceris cucullata should be seriously considered for listing as Threatened or Endangered in the future. Acropora palmata and cervicornis: Based on recent evidence of recovering populations of these species, and prehistoric declines followed by rebounds of these species, I have mixed feelings about listing these species as Endangered, though I feel the action would be justifiable. Pacific Acropora jacquelineae, lokani, and rudis: Recent evidence, such as that shown by Guest et al. (2012) shows that many Acropora spp. have far greater potential to adapt or acclimatize to climate change than has been previously recognized. Futhermore, data from van Woesik et al. (2012) suggests that Pacific Acropora like these species are unlikely to go extinct, even when they occur over a limited range. Afterall, a variety of mounting evidence shows that many marine populations (including coral populations) are largely closed and show only moderate levels of gene flow with other reefs. Hence, range size is much less of a significant issue in describing extinction risk. These species should be listed as Threatened and not as Endangered. Euphyllia paradivisa, cristata, and paraancora: Based on criteria established by van Woesik et al. (2012) we would expect that species of the genus Euphyllia should be highly resistant to extinction, and most especially these three branching species. I have personally witnessed thousands of individuals of each of these species being grown in captivity across the world. Each of these species, and the genus generally, shows very high resilience to bleaching and to ocean acidification as compared to most other corals. All of these species show very high rates of recovery after bleaching, rapid growth rates, and, due to the relatively small quantity of skeleton produced in combination with large amounts of tissue, very high tolerance to low pH. Based on these scientifically robust criteria and my firsthand experience with these species I am confident in suggesting that these species are likely to be among the most tolerant corals to both global and local stressors. Therefore, in my view none of these species warrants listing either as Threatened or Endangered species. However, if these species are ultimately listed it should only be as Threatened species and not as Endangered. To be clear, E. paradivisa absolutely does not warrant listing as Endangered. Considerations for implementing the ESA There are two critical areas in which I strongly urge NOAA to enact a “4d rule” for the coral species listed as threatened. The first purpose is for scientific research. Clearly new scientific knowledge is needed to protect and effectively manage these species for recovery. The second purpose is in situ and ex situ mariculture or aquaculture of these species. These activities are of great value to the goal of protecting and restoring these corals for four reasons: (1) Mariculture activities are rapidly spreading across poor, coral reef nations, for example Indonesia and the Marshall Islands and provide the people in these areas a source of income that is both sustainable and does not damage the reef. The vast majority of alternative sources of income directly damage reefs, imperiling corals. (2) Placing a high dollar value on protecting coral health provides a major incentive to local communities not only to take an alternative route of mariculture, but to engage in active enforcement and protection of their reefs. For example, my Ph.D. advisor was recently in Bali contributing to a NOAA-sponsored workshop on coral mariculture. He related to me that all the reefs where people are mariculturing coral are in great shape because people police the areas whereas other, nearby reefs where no aquaculture occurs were in poor condtion. (3) More than half of the Pacific species proposed for listing under the ESA are currently being actively propagates in Indonesia and other countries. In Indonesia the mariculturists are required to restock the reef with a minimum of 10% of their total production of corals, though I have heard (again, from my Ph.D. advisor who was recently in Bali) that most operations are exceeding this 10% minimum requirement. Thus, mariculture has another direct benefit to these corals, helping them to increase in population and grow in nature. (4) Maricultured or aquacultured corals are sold mostly to marine aquarists in the USA, Europe, Japan, and other countries to be grown in coral reef aquariums. Over the last 12 years I have personally interacted with thousands of aquarists around the world. The vast majority of these aquarists are much more aware of the problems facing coral reefs, much more concerned about these problems, and much more determined to solve them than the average citizen, in my experience. Allowing coral mariculture, especially of the proposed Threatened species, strongly encourages the type of concern and environmental ethic that is sorely needed to protect and preserve coral reefs. By far the most important predictor of the future of coral reefs is societal concern for their well-being. Mariculture and the live coral trade are among the most effective tools available to foster this concern. Changing taxonomy Last, as mentioned above, there is mounting evidence that substantial portions of current coral taxonomy are completely wrong. Many well-recognized species are not real species at all, but rather various growth forms of a variety of species. Likewise, many supposedly wide-ranging species are actually made up of a series of highly distinctive species which simply appear similar. Coral taxonomy is going to change drastically in the next few years and many of the species proposed here likely do not constitute real species and will need to be delisted. Likewise, many species which are not listed here will turn out to be quite rare and vulnerable as we get better data and will be important candidates for listing at that time. Mechanisms to cope with these changes should be considered carefully and structured now. Sincerely, Christopher P. JuryHawaii Institute of Marine BiologyUniversity of Hawaii at Manoa ReferencesGuest JR, Baird AH, Maynard JA, Muttaqin E, Edwards AJ, et al. (2012) Contrasting Patterns of Coral Bleaching Susceptibility in 2010 Suggest an Adaptive Response to Thermal Stress. PLoS ONE 7(3): e33353. doi:10.1371/journal.pone.0033353 Maynard et al. 2008. Major bleaching events can lead to increased thermal tolerance in corals. Coral Reefs. 155:173-182. van Woesik et al. 2012. Hosts of the Plio-Pleistocene past reflect modern-day coral vulnerability. Proceedings of the Royal Society B. doi: 10.1098/rspb.2011.2621 – As publicly submitted byChristopher P. Jury, posted Apr 12, 2013, at http://www.regulations.gov/#!documentDetail;D=NOAA-NMFS-2010-0036-1296 View or Download original PDF version

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.