To all Reefbuilders Readers:
The MASNA Industry, Legislation and Conservation staff has been hard at work preparing MASNA’s response to the proposed listing of 82 coral species under the Endangered Species Act (“ESA”). In connection with preparing the response, we have reviewed multiple scientific papers and reviews of the underlying Status Review Report (“SRR”), conducted an independent legal analysis of the proposed action under the ESA, and have worked closely with the legal and legislative issues staff of aligned organizations, including PIJAC (Pet Industry Joint Advisory Council).
The response letter will be submitted to the National Marine Fisheries Service today, with a copy to be made available on MASNA’s website.
Please remember that the deadline for submission of public comment on this critical issue is this Saturday, April 6, 2013. MASNA recommends that public comment be submitted by Friday April 5, 2013, as there may be some confusion as to what specific time on April 6 the public comment period expires.
MASNA’s position is that the ESA should be used as intended: to protect species at risk in all or a significant portion of the species’ range as solely determined on the basis of the best scientific and commercial data available. 16 U.S.C. 1533(b)(1)(A). Stated differently, MASNA supports science-based conservation, not politically motivated conservation.
In addition to many other deficiencies in the proposed action, the Biological Review Team that drafted the SRR admitted in multiple instances that insufficient data was available to make a determination that a particular species was at risk in all or in a significant portion of that species’ range. For these and other reasons, such as faulty methodology, the proposed action is not based on science, and it is not appropriate, or even authorized, under the ESA.
Murray W. Camp
MASNA ILOC Director
MASNA General Counsel