NOAA solicits Comments 82 Species Coral Report


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NOAA Invites Comment on Coral Status Review Report and Draft Management
As part of our ongoing process to evaluate 82 species of coral from the
Caribbean and Pacific for listing under the Endangered Species Act (ESA),
NOAA is inviting public review of two reports, a scientific Status Review
a draft Management
Our review of these 82 species of corals has been the most complex ESA
listing process NOAA Fisheries has ever undertaken. NOAA will use the
additional input to ensure that the best scientific information available
will be considered as we develop our 12-month finding. Please note that
releasing these documents is not a part of the normal rulemaking process –
it is an engagement process that allows us to be transparent and open in
our decision making. Should NOAA Fisheries determine that a listing is
warranted, we will publish a proposed rule in December 2012 for additional
public comment.

*Important Dates*
The public review process began on April 13, 2012, and ends on July 31,
2012. Instructions on how to submit comments and/or information is listed

*What Additional Information is NOAA Interested In?*
We are particularly interested in receiving information on the following:

- Relevant scientific information collected or produced since the
completion of the Status Review Report in 2011, or any relevant scientific
information not included in the Report.
- Relevant management information not included in the draft Management

*Engagement Opportunities*
As part of this review, NOAA also plans to host two regional public
listening sessions and two scientific workshops focused on corals this
summer. The specific dates, times, and location for the regional listening
sessions and scientific workshops will be announced in May.

*Corals Reports*
Status Review Report – this report examines the biology of, threats to, and
extinction risk of 82 coral species.

- Executive Summary<>
Status Review Report of 82 Candidate Coral Species (pdf)
- Full Document<>
Status Review Report of 82 Candidate Coral Species (pdf) Note: This file is

Draft Management Report – this report describes existing regulatory
mechanisms and ongoing conservation efforts to manage and conserve the 82
coral species throughout the Caribbean and Indo-Pacific.

- Executive Summary<>
Draft Management Review document (pdf)
- Full Document<>
Draft Management Review document (pdf) Note: This file is 2.3 MB.

*Other Materials*

- Federal Register
- Center for Independent Experts reports
- Report #1—Hughes<>
- Report #2—McManus<>
- Report #3—Riegl<>
- Review team

*How to Submit Comments*

You may submit comments on the Status Review Report and the draft
Management Report and/or additional papers, reports, and information by any
of the following methods. If possible, comments should be grouped according
to the heading of the relevant section of the reports.

- Electronic Submission— submit all electronic information via
electronic mail to:
- Mail—submit written comments to:

Regulatory Branch Chief
Protected Resources Division
Attn: 82 coal species
National Marine Fisheries Service
Pacific Islands Regional Office
1601 Kapiolani Blvd., Suite 1110
Honolulu, HI 96814
- or -
Assistant Regional Administrator for Protected Resources
Attn: 82 coral species
National Marine Fisheries Service
Southeast Regional Office
263 13th Avenue South
St. Petersburg, FL 33701

- Fax—808-973-2941; Attn: Protected Resources Regulatory Branch Chief,
or 727-824-5309; Attn: Assistant Regional Administrator for Protected
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From: Eugene Shinn
To: coral-list <>
Sent: Wed, May 30, 2012 11:20 am
Subject: [Coral-List] 82 Corals Status Review under the US Endangered Species Act
Well here we go again! The Center for Biodiversity has masterminded
yet another misuse of the Endangered Species Act by suing
NOAA/National Marine Fisheries Service to list 82 species of corals.
It wouldn't be an unwarranted move if there were scientific certainty
about what is causing their demise. Common sense says, "If you don't
know what's killing something, then what do you protect it from?"
That was the case back when CBD forced endangered status on Acropora
species several years ago. Did listing of Acropora stop the demise of
that genus in the Florida Keys National Marine Sanctuary where all
coral species are protected? The answer is no. Ironically, even then
there were areas in the Caribbean where the genus flourished, and
there are still areas where it flourishes. Curiously, A. cervicornis
is growing magnificently suspended in the water column on lines in
Ken Nedimyer's coral nursery within FKNMS. They and other acroporids
just do not grow well on coral reefs where they flourished until the
late 1970s. There is also good evidence now that the white-band
disease that wiped out Acropora is caused by a bacterial infection.
Unfortunately listing did not get rid of the mystery microbe. Quite
likely it is disease-resistant genotypes that have remained resistant
to the disease. That would explain why geological research indicates
there have been two major extinctions of A. cervicornis and rebirths
in the FKNMS during the past 6,000 years (Shinn et al. 2003; Shinn
2004). Acropora growth rate, if unchecked, would have allowed it to
grow as much as 600 ft. vertically during the period that Florida
reefs have existed.
So now it is 82 coral species the CBD is using to advance their
cause, eight of which are Caribbean species. Since I have conducted
geological and growth-rate research in the Caribbean, it is best that
I restrict my comments to those species. First, I think we can all
agree that dredging or ship groundings can smother any of the species
of concern. Such incidents are of limited extent, and they are
preventable and can be controlled. Unfortunately, listing them as
threatened or endangered cannot abate the widespread death of
Caribbean coral species due to disease. Listing is therefore a
totally useless act that likely may have unintended or sinister
preplanned consequences.
Black-band disease has devastated the Montastraea group of
corals, yet we do not know the causes both in Florida and around
sparsely populated islands of the Caribbean. Listing certainly will
not bring those species back to full health. The same can be said
about Dendrogyra cylindrus that is distributed throughout the
Caribbean but never in great abundance. Colonies of that coral still
grow in the FKNMS where all corals are protected. That species never
was abundant in the 50+ years the author has been diving there (Shinn
2011). Dichocoenia stokesii is a minor component on reefs that
automatically dies when it reaches the size of a soccer ball. Many
died from what was called white plague (a form of bleaching that
started at the base of the coral) in the 1980s. One can still find
healthy Dichocoenia, and there is little disease today. Furthermore,
it is not a significant reef builder. I have no idea why Agaricia
lamarcki or Mycetophyllia ferox are included on the list. They
certainly are not keystone reef builders, and I am certain they are
not threatened throughout their range. As I remember from the first
attempt to list D. cylindrus back in the 1970s, a species must be
threatened throughout its range to qualify for E.S.A listing. One has
to wonder about the benefit of listing these corals since it simply
creates more rules and regulations, not to mention paper, time, and
effort, and be ineffective at saving these species. We can all
remember the Caribbean-wide demise of the urchin Diadema antillarum
in the early 1980s some 30 years ago. Diadema remains rare and
nowhere near its former abundance. Had that pivotal coral reef
organism been listed in the 1980s, would it have been brought back to
pre die-off levels? Of course not! Acropora cervicornis died off at
roughly the same time as Diadema. If A. cervicornis had been listed
back in the 1980s, would it be flourishing today? One has to wonder
what the coral reef and the CBD benefits from listing of these corals?
I suspect what is behind the proposed listing is coral bleaching
that may be caused by a warming ocean that the IPCC and Al Gore say
is caused by increasing levels of CO2 that have been rising and
currently approaching 0.004 percent of the atmosphere. That is a
worldwide highly contentious political issue that will not be
resolved soon. Is that why the CBD wants these corals listed? Or is
it the threat of alkalinity shift, a.k.a. ocean acidification? All
thinking people know that CO2 will stay in the atmosphere and oceans
for many years if anthropogenic sources ceased tomorrow. The lawyers
at CBD surely are aware of that. Maybe their action is a way to
squeeze tax-exempted funding from gullible and frightened citizens?
What is their motive or motives? Why is CBD doing this? Is there some
collusion between CBD/lawyers and the government agencies that will
squeeze more money from Congress to administer the extra burden of
enforcement? I do know that whether they win or lose their lawsuit
against NOAA, our taxes pay their legal fees. Now that's a pretty
cynical motive but as they say, "follow the money." And finally, why
is National Marine Fisheries involved with coral protection,
especially within NOAA Marine Sanctuaries where all corals are
already protected? If there is government waste and overlap, then
this may be a poster-boy example. Gene

Shinn, E.A., Reich, C.D., Hickey, T.D., and Lidz, B.H., 2003,
Staghorn tempestites in the Florida Keys: Coral Reefs, v. 22, p.

Shinn, E.A., 2004, The mixed value of environmental regulations: Do
acroporid corals deserve endangered species status? Marine Pollution
Bulletin, v. 49, p. 531-533.

Shinn, E.A., 2011, Are we loving 'em to death? Marine Pollution
Bulletin, v. 62, p. 2581-2583.


No Rocks, No Water, No Ecosystem (EAS)
------------------------------------ -----------------------------------
E. A. Shinn, Courtesy Professor
University of South Florida
College of Marine Science Room 221A
140 Seventh Avenue South
St. Petersburg, FL 33701



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-----Original Message-----
From: Jennifer Moore <>
To: coral-list <>
Sent: Tue, May 22, 2012 8:45 am
Subject: [Coral-List] 82 Corals Status Review under the US Endangered Species Act
As part of an on-going status review of 82 species of coral under the US
Endangered Species Act, NOAA Fisheries has opened an additional information
solicitation period. We will hold two scientific workshops and two public
listening sessions, one each in Honoulu, Hawaii and Dania Beach, Florida,
to gather information. Please refer to the Federal Register notice at ... -12368.pdf for details
on dates, times, and locations. If you would like to submit written
information, please send it to If you have
questions, please contact Lance Smith (Hawaii) at or
Jennifer Moore (Florida) at



*Jennifer Moore
ESA Coral Coordinator | Protected Resources Division
NOAA Fisheries Service
263 13th Ave South
Saint Petersburg, FL 33701
727-551-5797 phone | 727-824-5309*


To those who sacrificed careers of adventure in the wide-open spaces
to wrestle for conservation in the policy arena.*
Coral-List mailing list


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We have been following the discussions about the 82 coral species that are
being considered for protection under the US Endangered Species Act. Based
on the questions that have been raised, we posted a factsheet on what
Endangered Species Act protection would mean for these corals. This sheet
addresses questions on why the Center for Biological Diversity petitioned
NMFS to protect 83 corals under the Endangered Species Act (ESA), how we
chose these 83 corals, the protections that the ESA can provide to listed
corals, how the ESA helps endangered species including threatened elkhorn
and staghorn corals in the Caribbean, how ESA protection would affect
research activities, and how you can comment on the NMFS Status Review for
the 82 candidate corals.
Corals face severe, ongoing threats ranging from habitat destruction,
pollution, overharvest, and disease-and now ever-increasing ocean warming
and ocean acidification. Endangered Species Act (ESA) protection provides a
set of strong conservation tools that complement and add to existing
management tools for corals, which will help corals better survive and
recover. That is why, in 2009, the Center submitted a 198-page scientific
petition to NMFS requesting ESA protection for 83 corals. We chose corals
that occur in US waters (and thus can benefit most from ESA protection),
with estimated population declines of 30% or greater over 30 years according
to the IUCN.

What benefits can ESA protection provide to these corals?

ESA protection would make it unlawful for US citizens to harm or kill listed
corals. It would lead to the protection of critical habitat areas for corals
in US waters. It would also require science-based recovery plans for the
corals with specific management and research actions aimed to help them
survive and recover.

Perhaps most significantly, US government agencies would need to consult
with federal biologists to ensure that their actions do not harm listed
corals. Through this consultation process, federal permits for activities
that could harm corals and their habitat--such as water pollution, dredging,
commercial fishing, and coastal construction--must analyze their impacts on
corals and take steps to reduce or eliminate them, thereby minimizing
stressors on coral reefs. The consultation process would also apply to
federal actions that harm corals through significant greenhouse gas
emissions that increase global warming. This could result in emissions
reductions that help protect corals. Finally, the listing process promotes
greater awareness about threats to corals, and provides public outreach

Has ESA protection benefitted listed species?

The ESA has prevented the extinction of 99% of species that have been listed
to date. One study estimated that 227 listed plants and animals would have
disappeared by 2006 if not for the ESA's protections. A recent analysis
concluded that the ESA has been very successful in recovering listed
species; 90 percent of sampled species are recovering at the rate specified
by their recovery plans

Has ESA protection helped listed elkhorn and staghorn corals in the

Elkhorn (Acropora palmata) and staghorn (A. cervicornis) corals, which were
listed as "threatened" in 2006, have received a number of important ESA
protections. These include the designation of almost 3,000 square miles of
protected critical habitat in US waters. US federal agencies have been
required to modify a wide range of projects to reduce harms to these corals,
including mitigation to harbor construction projects, the laying of undersea
cable, and fisheries management plans. ESA protection also allows citizens
to challenge government actions that are harming corals. For example, the
Center is challenging NMFS's authorization of targeted parrotfish fishing
that threatens the health of these listed corals.

How would ESA protection affect research activities?

ESA listing typically directs more research attention and funding to listed
species. The number of published studies on a species often increases
significantly following a petition and/or listing. In the case of the
82-petitioned corals, the listing petition spurred the development of NMFS's
581-page Status Review, one of the most comprehensive scientific reviews on
corals to date. The listing process has also led to new studies to fill
knowledge gaps on candidate corals. Although researchers will need to apply
for an additional permit for work on listed corals, NMFS grants permits for
a wide range of research and restoration activities on listed species.

What did the NMFS Status Review determine?

The NMFS status review team determined that 56 of the 82 candidate coral
species are "likely" or "more likely than not" to fall below a critical risk
threshold for extinction by 2100

How can you comment on the Status Review?

NMFS is soliciting information from scientists, government agencies, and
other interested parties on the status and threats to these corals
throughout their range. Submit comments by July 31, 2012 to

The NMFS status review report and supporting information are here:

http://www.nmfs.noaa.govstories/2012/04 ... ition.html

The Center's petition, factsheet, and other information on our coral
conservation efforts are here: ... index.html

The factsheet, the Center's petition, and other information on our coral
conservation efforts are here:

<> ... index.html ... fs/Fact_Sh

We provided a summary of the main points of the factsheet below, but please
see the factsheet for more information.

Thanks for your interest in this topic! Many of you have important
information on the status and threats to the 82 candidate corals. Submitting
this information to NMFS during the current comment period would be helpful
to the status review team and this process.

Shaye Wolf, Ph.D.

Climate Science Director

Center for Biological Diversity

Miyoko Sakashita

Oceans Program Director

Center for Biological Diversity