If you’ve been following my recent writings about the marine aquarium trade and the Endangered Species Act (ESA), you know I have recently been somewhat critical of the Pet Industry Joint Advisory Council (PIJAC). I have been most critical of their silence and their lack of response to media inquiries about major issues facing a trade they represent. I have suggested their actions, while on the one hand dramatically benefitting trade in relation to both attacks in Hawaii and the listing of 20 species of coral as “threatened” under the ESA, have also polarized the situation and, as a result, spawned much misinformation spread by industry leaders and general aquarists via trade and social media. Much of that misinformation was followed by a direct solicitation to support PIJAC. Media outlets and individuals seeking to address the false statements did not have a clear source expressing PIJAC’s position with which to counter the hyperbolic rhetoric. That lack of information and clarity from PIJAC has mired the situation, and so I was thrilled to see PIJAC go public today and put both the scope of their work and strategy on the record.
Today, PIJAC sent a letter to the Marine Aquarium Societies of North America (MASNA), making, for the first time, their position clear and public. MASNA is a non-profit organization composed of marine aquarium clubs and individual hobbyists from North America and abroad, totaling several thousand individuals. The letter is straightforward, relatively concise and generally an accurate portrayal of the situation. Most important, it avoids oversimplification and data-poor incendiary statements; it redirects the dialog to data and science and away from the polarizing effects of unsubstantiated and false claims. It is to PIJAC’s credit they released this statement, which will help aquarists and trade leaders make informed, critical decisions concerning how they will respond to these and future ESA listings.
The letter was authored by the recently rebranded “Aquatics Committee” (previously the “Marine Ornamental Defense Committee”), which includes Sandy Moore, Chris Buerner, Julian Sprung, Dustin Dorton,* Kevin Kohen and Laura Reid.
Several highlights form the letter include:
NMFS had originally proposed to list 66 reef-building species as threatened and endangered in December, 2012. However, based upon substantial scientific information submitted by the Pet Industry Joint Advisory Council (PIJAC) and other parties, NMFS determined only 20 of these species warranted listing as threatened species. Such scientific information included the submission of a scientific report developed by Dr. Charlie Veron, a world-renowned coral expert. PIJAC participated in the development of Dr. Veron’s work, and provided financial support enabling completion of this work.
PIJAC believes it likely that NMFS will apply the ESA Section 9 “take” prohibitions to the newly-listed coral species in the near future, consistent with prior agency actions. Application of these take prohibitions by NMFS could severely restrict or eliminate trade in these species. Such prohibitions may apply to both corals in the wild, as well as farm-raised corals. Such actions would be devastating to the marine aquarium hobby.
While we await further regulatory actions, anti-aquarium organizations will surely strive to create a social stigma for the aquarium industry by claiming, for example, that we are “trafficking in threatened and endangered species.” The emotion surrounding the subject will likely inflame public opinion and could motivate NMFS and the U.S. Fish and Wildlife Service to enact stricter importation rules on all corals.
NMFS’ action to list these species was driven by a petition filed by CBD. CBD indicated in its petition that climate change presents a significant risk for these species, requiring listing of these species under the ESA. CBD, effectively, is attempting to use the ESA as a tool to regulate greenhouse gas emissions. NMFS, likewise, relied on the effects of climate change to justify listing these 20 species. However, scientific information developed by world-renowned scientists indicate that none of the 20 listed coral species warrant listing under the ESA. These experts have stated in recent comments that NMFS’ final rule is not supported by the best available scientific information.
Most important, I think, are the final few paragraphs, which define the scope of PIJAC’s work and their strategy moving forward. They write: “PIJAC must continue to work with the scientific community to develop and submit scientific information regarding marine species. PIJAC must also remain engaged in the legal and policy issues arising now that these 20 coral species have been listed by NMFS under the ESA.”
Toward the very end of the letter, they pick up what I have suggested is an important aspect of the trade fighting ESA listings. While a lobbying organization’s central mission may well be to fight legislation, rule-making and litigation detrimental to the constituency they represent, I have argued they must also address the bigger picture. The marine aquarium trade can provide real economic incentive to conserve and play a leading role in recovery plans for embattled species. As such, I was pleased to see PIJAC address this point in the penultimate paragraph of the letter.
Many eminent coral reef scientists are dismayed by the listing. ESA take prohibitions may be at odds with the best plan for the recovery of any coral species that might ever need a recovery plan– coral farming and restoration. ESA prohibitions may dramatically limit or eliminate conservation and education programs.
In the final equation, it’s important to place PIJAC’s letter in context. PIJAC’s letter to MASNA is a letter by a pro-trade, lobbying organization to its constituents. It’s primary role is to both inform and solicit support. It is not an objective, fact-checked, unbiased, comprehensive news release or feature article about the listing of species under the ESA. That piece will be forthcoming in the next issue of CORAL Magazine. As the author of that piece, I am very appreciative of PIJAC’s public pivot toward transparency and science. I look forward to following up with them in an in-depth interview and bringing their important and thoughtful perspective to this ongoing issue. Stay tuned, as there will be much more to come.
* In an earlier version of this article I accidentally omitted Dustin Dorton’s name from the list of PIJAC Aquatics Committee members.