From: Dr. Peter J. Rubec

Organization: East Asian Seas and Terrestrial Initiatives (Philippines NGO active in the Philippines and Indonesia).

Address: 2800 4^th Street North, Suite 123, Saint Petersburg, FL 33712, USA.

Telephone: 727-327-9226, Cell. 727-242-3629

As described in the Federal Register Notice published February 10, 2010, NOAA/NMFS requested information to assist in reviewing the status of 82 coral species for which they made a positive 90-day finding under the ESA in response to the petition from the Center for Biological Diversity (CBD). The types of information solicited included:

(1) Historical and current distribution and abundance of these species throughout their ranges (U.S. and foreign waters);

REPLY: The petition from CBD briefly summarizes the description, taxonomy, natural history, distribution, and status for each petitioned species, and discusses the status of each oceanic basin's coral reefs. Most of the CBD submission was taken from Corals of the World (Veron and Stafford-Smith 2000) and from the IUCN Red List. Much of this information is qualitative rather than quantitative, since only a very small proportion of the coral reefs have received quantitative underwater surveys.

The maps presented in the petition show that many of the Indo-Pacific species have very broad ranges stretching from east Africa in the Indian Ocean to the western Pacific. Some also extend to the Hawaiian Islands. While the spatial distributions of the various species are known in general terms, detailed quantitative data concerning the spatial distributions and relative abundances of each species across the geographic ranges of each coral species in the Atlantic, Pacific, and Indian Oceans does not exist. Historical versus current distributions is also qualitative (based on the opinions of various scientists familiar with the species in various regions).

(2) Historic and current condition of these species and their habitat;

REPLY: The petition provides a summary of published and grey-literature information. It is generally believed that many coral reefs are becoming degraded and are in poorer condition now in comparison to the conditions that were observed by various scientists back to the 1950’s. On a species-specific basis most of the information concerning the condition of the petitioned coral species appears to have been taken from the IUCN Red List. The paper in Science by Carpenter et al. (2008) is the collective opinions of a number of coral reef scientists, knowledgeable about the species in various geographic regions. They also used information from the IUCN Red List. The IUCN classifications (Endangered, Threatened, Vulnerable etc.) are based on expert-opinions rather than quantitative data derived from surveys over the respective ranges of each species.

Many factors that could contribute to declines in the condition of coral species are very localized and cannot account for the widespread declines in the condition of so many species reported by Carpenter et al. (2008). "Of the 704 species that could be assigned conservation status, 32.8% are in categories of elevated risk of extinction. Declines in abundance are associated with bleaching and diseases driven by sea surface temperatures, with extinction risk further exacerbated by local-scale anthropogenic disturbances….The Caribbean has the largest proportion of corals in high extinction risk categories, whereas the Coral Triangle has the largest proportion of species in all categories of elevated extinction risk".

(3) Population density and trends;

REPLY-My understanding is that there is very little data available on population densities and trends for many of these coral species. Most data that does exist comes from localized studies which are not representative of densities and trends across the geographic ranges of the petitioned species.

Many species of corals never were abundant. Some are quite cryptic making it difficult to know whether they are present or not. It may be normal for the species not to be abundant. Without quantitative surveys over time across the species range, it is difficult to know whether a coral species has declined in abundance over time.

(4) The effects of climate change on the distribution and condition of these
coral species and other organisms in coral reef ecosystems over the short- and
long-term;

REPLY- El Ninos have contributed to localized sea surface temperature (SST) warming (hot spots) monitored by NOAA’s National Weather Service and presumably other agencies worldwide. The warming of the sea surface (SST anomalies) at varying times have been shown to lead to bleaching of coral reefs in many parts of the world. Hence, there is good data to support the assertion that climate change is contributing to changes in the distributions and conditions of these species. I leave it to the coral reef scientists involved to provide bibliographic documentation to support this assertion.

Carpenter et al. (2008) noted "In the eastern tropical Pacific, a high proportion of corals have been affected by warming events. However, subsequent monitoring has shown reefs are recovering in most areas across the region. Indian Ocean corals were the most affected by the 1998 warming event with two subsequent bleaching events in some places…. Other reefs are recovering their structure, but the time to complete recovery may range to decades and will be highly dependent on future climatic and local disturbance regimes."

The effects of declines in the condition of the coral reefs on associated organisms (e.g., fish) were not discussed by Carpenter et al. (2008). It is well known that healthy coral reefs support higher standing crops of fish, invertebrates, and other organisms than degraded coral reefs (Rubec 1988, DeVantier et al. 2004).

(5) The effects of other threats including dredging, coastal development,
coastal point source pollution, agricultural and land use practices, disease,
predation, reef fishing, aquarium trade, physical damage from boats and anchors,
marine debris, and aquatic invasive species on the distribution and abundance of
these coral species over the short- and long-term; and

REPLY-There is no doubt that the other threats mentioned above can impact coral reefs. But, most of the impacts are usually very localized. So, it is doubtful that they can be used to designate any of the coral species under consideration as threatened or endangered under the ESA. The only case where one could argue that such threats could impact any of the coral species under consideration would be where the species in question is known to only occur in a very limited area (limited range) that would be impacted by various anthropogenic practices (e.g., dredging, coastal development, point source pollution etc). To my knowledge, none of the 82 species of corals under review meet this criterion (limited range in area of high anthropogenic impact).

The CBD (2010) noted "The burgeoning live fish trade poses a serious threat to coral reef ecosystems worldwide (Vincent 2006). Most of the species sought after for the live fish market come directly from reefs. Targeted species are long-lived and late maturing, rendering them particularly vulnerable to high harvest levels. Cyanide poisoning is a very common method of live fish harvest, despite its associated high mortality rates during capture, holding, and transport. Global trade in live food fish was estimated to be 30,000-50,000 tonnes per year in the late 1990s, with total estimated extraction of roughly double that amount due to high handling and transportation mortality (Vincent 2006)."

The CBD (2010) also noted "As demand has increased, wild fish populations [mostly grouper species] have declined dramatically and fish extraction efforts are now occurring in most countries of the Indo-Pacific and at ever greater distances from the consumption hub of Hong Kong. Live fish are also increasingly exported to Australia, the United States, and many Southeast and Eastern Asian countries with large ethnic Chinese populations. Current levels of live fish production throughout Southeast Asia and the Maldives significantly exceed estimates of sustainable extraction."

The use of cyanide for the capture of marine aquarium fish (MAF) (Rubec 1986) and live reef fish (LRF) (Johannes and Riepen 1995, Pratt 1996, Barber and Pratt 1997, Rubec 1997) is believed to have markedly contributed to the degradation of coral reefs in the Philippines, Indonesia, Vietnam, and Malaysia. Other countries mentioned by Barber and Pratt (1997) may also have been affected by the use of cyanide in the LRF trade. Scientific evidence that cyanide kills corals is provided by Cervino et al. (2003). The use of cyanide in the MAF and LRF trades appears to have had widespread geographic effects that could have affected certain species of corals (some of which may be ones listed by the CBD in the present petition).

REPLY-Cyanide testing conducted by the International Marinelife Alliance (IMA) from 1993 to 2001 under contract to the Philippines Bureau of Fisheries and Aquatic Resources (BFAR) needs to be reinstated to help stop cyanide fishing in the countries where cyanide fishing is rampant (Rubec et al. 2003, Rubec et al. 2008).

If the 82 species of corals under review by NOAA/NMFS get listed under the ESA, the import of all corals (alive and/or cured) to the United States may become illegal. Most of the corals listed under the CBD petition are difficult to identify to species. Hence, the ESA listing may limit the import of all coral species (because it is not feasible for USFWS and/or US Customs to distinguish the species protected by ESA from other coral species).

While the trade in corals is covered under CITES, putting these coral species under the ESA could create a bureaucratic nightmare that unfairly penalizes the aquarium trade. It could become illegal to farm corals in the USA, and illegal to ship corals into or within the USA. Retail stores and even aquarium hobbyists could be prosecuted for possessing any of these coral species.
With respect to Indonesia and Vietnam and other countries in the South Pacific, efforts to farm corals to support exports for the aquarium trade to the USA will most probably be affected. I believe that corals are a resource that needs to be managed by the host countries where corals occur. Local people can benefit from the sale of corals to the aquarium trade. Income obtained from the export of corals and other coral reef related products are important for local communities in the host countries.

Indonesia is in the process of legalizing coral farming and making wild harvest illegal. Legalizing coral farming can only work if the corals reared from fragments can be exported to provide income to local communities. Regulations need to be put in place, which require communities to rehabilitate coral reefs using excess corals from the coral farms.

I think it is unfair for the USA under ESA to deprive the host countries of their right to manage the coral trade through CITES quotas. If these species are threatened and endangered (due mostly to climate change) actions to deal with the problem need to come from the countries of origin where these species occur.

Barber, C.V., and V.R. Pratt. 1997. Sullied Seas: Strategies for Combating Cyanide Fishing in Southeast Asia and Beyond. International Marinelife Alliance, 15 pp.

Carpenter, K.E., M. Abrar, G. Aeby, R.B. Aronson, S. Banks, A. Bruckner, A.Chiriboga, J. Cortes, J.C. Delbeek,, L. DeVantier, G.J. Edgar, A. J. Edwards, D. Fenner, H.M. Guzman, B.W. Hoeksema, G. Hodgson, O. Johan, W.Y. Licuanan, S.R. Livingstone, E.R. Lovell, J.A. Moore, D.O. Obura, D. Ochavillo, B.A. Polidoro, W.F. Precht, M.C. Quibilan, C. Reboton, Z.T. Richards, A.D. Rogers, J. Sanciangco, A. Sheppard, C. Sheppard, J. Smith, S. Stuart, E. Turak, J.E.N. Veron, C. Wallace, E. Weil, and E. Wood. 2008. One-third of reef building corals face elevated extinction risk from climate change and local impacts. Science 321: 560-563.

Cervino, J. M., R. L. Hayes, M. Honovitch, T. J. Goreau, S. Jones, and P. J. Rubec. 2003. Changes zooxanthellae density, morphology, and mitotic index in hermatypic corals and anemones exposed to cyanide. Marine Pollution Bulletin 46: 573-586.

Johannes, R.E., and M. Riepen. 1995. Environment, Economic, and Social Implications of the Live Fish Trade in Asia and the Western Pacific. Report to the Nature Conservancy and Forum Fisheries Agency. 83 pp.

DeVantier, L., A. Alcala, and C. Wilkinson. 2004. The Sulu-Sulawesi Sea: environmental and socioeconomic status, future prognosis, and ameliorative policy options. Ambio 33(1-2): 88-97.

Pratt, V.R. 1996. The growing threat of cyanide fishing to the Asia Pacific Region, and the emerging strategies to combat it. Coastal Management Tropical Asia 5: 9-11.

Rubec, P.J. 1988. The need for conservation and management of Philippine coral reefs. Environmental Biology of Fishes 23(1-2): 141-154.

Rubec, P.J. 1997. Testimony to U.S. Subcommittee on Fisheries Conservation, Wildlife & Oceans concerning House Resolution 87, Washington, D.C. http://www.house.gov/resource/105cong/fishery/may06.97.rubec.htm

Rubec, P. J., and J. Palacol. 2002. Farming Coral Reef Invertebrates for Reef Rehabilitation and the Aquarium Trade. Pp. 107-113, In: J. Breman (ed.), Marine Geography, Environmental Systems Research Institute, ESRI Press, Redlands, California, U.S.A.

Rubec, P.J., V.R. Pratt, B. McCullough, B. Manipula, J. Alban, T. Espero, and E.R. Suplido. 2003. Trends determined by cyanide testing on marine aquarium fish in the Philippines. Pages 327-340, In: J.C. Cato and C.L. Brown (eds.), Marine Ornamental Species: Collection, Culture & Cultivation, Iowa State Press, Ames, Iowa.

Rubec, P.J., M. Frant, and B. Manipula. 2008. Methods for detection of cyanide and its metabolites in marine fish. Pages 43-63, In: A.W. Bruckner and G.G. Roberts (eds.) Proceedings of the International Cyanide Detection Testing Workshop, held 6-8 February 2008 in Orlando, Florida, U.S. Dept of Commerce, NOAA Technical Memorandum, NMFS-OPR-40, August 2008.

Rubec, P.J., F.P. Cruz, T.V. Jamir, and A. Ruwindrijarto. 2009. Use of Remote Sensing and Geographic Information Systems To Support Spatial Management and Conservation of Marine Resources In Tropical Countries. Paper presented at International Ocean, Science and Policy Symposium held in Manado, Indonesia, May 12-14, 2009, 10 pp.

Veron, J.E.N., and M. Stafford-Smith. 2000. Corals of the World. Vols 1-3, Australian Institute of Marine Science, Queensland, and CRR Qld Pty Ltd., Townsville, Australia.

Vincent, A.C.J. 2006. Live food and non-food fisheries on coral reefs, and their potential management. In Cote, Isabelle M. and John D. Reynolds, editors. Conservation Biology 13: Coral Reef Conservation. Cambridge University Press, New York, pp. 183-236.