NOAA to Propose Ban on import of Bangaii Cardinal

[Tony Thompson]

Just out of interest and in comparison to figures detailed by @Jay Hemdal , I have evidenced a USA collector in the waters of Florida reporting an average mortality rate of around 6 % in just Collection to Shore. Those collectors are highly skilled well equipped and highly regulated. So blaming the Indonesian fishers for high rates of mortality seems very unfair.

 

[EeyoreIsMySpiritAnimal]

So blaming the Indonesian fishers for high rates of mortality seems very unfair.

But if the point of the proposed ban is to keep the cardinals from being over-fished, regardless of who's to blame, shouldn't the mortality rate still matter? (i.e. they'd have to catch even more to keep up with demand...?)
*And I'm not even going to try to weigh in on whether or not the fish are still endangered. But I'm enjoying following this conversation among those more knowledgeable

 

[EeyoreIsMySpiritAnimal]

Really? Blame the people who actually do the hardest work? Reprimand and whip any collector who nets a fish too violently! Only crucifixion is truly suitable for his execution!

Again, if the point of the proposed ban is to keep the cardinals from being over-fished, shouldn't the mortality rate be taken into account regardless of who's to "blame"?

 

[Tony Thompson]

But if the point of the proposed ban is to keep the cardinals from being over-fished, regardless of who's to blame, shouldn't the mortality rate still matter? (i.e. they'd have to catch even more to keep up with demand...?)
*And I'm not even going to try to weigh in on whether or not the fish are still endangered. But I'm enjoying following this conversation among those more knowledgeable

Hi, sorry for any confusion, my comment you quoted was in response to the other posters broadcast claim of applying blame directly on one part of the chain. I used the one USA collectors figures to make a comparison with Jays findings. My figures have nothing to do with Banggais.

I must point out as a UK citizen I will not be participating directly in the regulation process of the proposed ESA NOAA.

In fairness to both sides, I think it important to remember in the case of import of the Banggai to the USA 90% 'EST' of those are aqua cultured in Thailand, not collected from the wild.

My point in the discussion is more to do with the rhetoric used, the relationship and roles between hobbyists and the Trade, especially Trade lobbying groups and media.

This is a very complex case covering nearly a decade or more. A great dal of positive steps have been taken to protect this species, including regulations set up by the Indonesian Government. If anyone wants a more detailed viewpoint, I suggest the read at minimum, the two documents the proposed appendix II listing CITES and the 5 year periodic review by NOAA regarding ESA.

I have attached both below in pdf.

 

[Bruttall]

Really? Blame the people who actually do the hardest work? Reprimand and whip any collector who nets a fish too violently! Only crucifixion is truly suitable for his execution!

I guess you missed a few things in my post, I'll detail that for you. I started with the sentance, "If the Majority of these fish die in captivity BEFORE being exported out of INDONESIA," Meaning if we can believe what this article says to be true, that 70 to 90% die during catching/netting, then the rest of my statement is true, but typical of media-saturation, you cherry pick what to focus on. I think you did a better job of illustrating the manipulation of media by your response than I ever could.

 

[Jay Hemdal]

Just out of interest and in comparison to figures detailed by @Jay Hemdal , I have evidenced a USA collector in the waters of Florida reporting an average mortality rate of around 6 % in just Collection to Shore. Those collectors are highly skilled well equipped and highly regulated. So blaming the Indonesian fishers for high rates of mortality seems very unfair.

Yes, and my 40 day quarantine mortality rate for fish from Hawaii and Florida ran about 9% in one study I did. That equates to a total rate of about 15% from reef to display tank. I think that is a very good rate for handling delicate animals like this.

Jay

 

[Tony Thompson]

Yes, and my 40 day quarantine mortality rate for fish from Hawaii and Florida ran about 9% in one study I did. That equates to a total rate of about 15% from reef to display tank. I think that is a very good rate for handling delicate animals like this.

Jay

I agree, 15% seems very reasonable. I just checked my records again and the mortality for Florida Fishery Capture to Landing facility was actually 8%, that figure is quoted from the fishery owner himself.

Good thing about fisheries' like this is the excellent recording of data and willingness to give full access of information to the hobbyists as well as the retailer. The certification, licencing and regulation in Florida Fisheries is excellent.

Just out of interest, all fish at my store where collected by hand by myself at the wholesalers and transported to my store personally. I Quarantined and Conditioned all my fish for 60 days, before they could be collected by my customers.

Customers could place reserve on the animals and view them through the whole process. Each animal also had a record on display of any medicine used and food eaten. Each customer would be placed in order on the reserve list for any particular specimen. That way no monetary deposit was needed. If the first on the list changed their mind the next on the list would get the choice and so on.

80% of my livestock would be captive bred, Unfortunately I can not buy direct from the breeders and as the wholesaler in the UK TMC hold all captive bred in the same system as wild collected I would have to hold them in QT also.

PS for clarity my store was Marine only specialist. No Freshwater. I also concentrated on Inverts and my small coral farm, rather than fish so not a huge stock of fish, around 20 individual tanks for fish stock.

 

[EeyoreIsMySpiritAnimal]

Hi, sorry for any confusion, my comment you quoted was in response to the other posters broadcast claim of applying blame directly on one part of the chain. I used the one USA collectors figures to make a comparison with Jays findings. My figures have nothing to do with Banggais.

I must point out as a UK citizen I will not be participating directly in the regulation process of the proposed ESA NOAA.

In fairness to both sides, I think it important to remember in the case of import of the Banggai to the USA 90% 'EST' of those are aqua cultured in Thailand, not collected from the wild.

My point in the discussion is more to do with the rhetoric used, the relationship and roles between hobbyists and the Trade, especially Trade lobbying groups and media.

This is a very complex case covering nearly a decade or more. A great dal of positive steps have been taken to protect this species, including regulations set up by the Indonesian Government. If anyone wants a more detailed viewpoint, I suggest the read at minimum, the two documents the proposed appendix II listing CITES and the 5 year periodic review by NOAA regarding ESA.

I have attached both below in pdf.

Thank you

 

[AP Fishkeeper]

This 70% to 90% pre-export mortality estimate was published in one paper in 2008. Not only are there some questions to author of the paper's research methods, but the none of the more recent studies looking at the trade have found this. Even if this was the case 15 years ago (which it probably was not), the supply chain has changed significantly since then and it is certainly not the case now.

 

[Tony Thompson]

Update on information with reference aquaculture farm banggai in Thailand.

Below is the submitted comment by the aquaculture farm in Thailand, in opposition to NOAA proposal.

"Nautilus Park (exporter) and Octopus Farm (producer) are the largest existing aquaculture operation of Banggai Cardinalfish. Our sea-based farm is located in Southern Thailand, where we have established 15 years ago, in collaboration with the Department of Fisheries of the Thailand’s Ministry of Agriculture, a new disease-resistant Banggai population in a controlled farm environment. Our operations and exports are fully certified by Department of Fisheries.

US is our main export market. From March 2012 to August 2023 (11.5 years), we have exported to US a total of 1,059,068 aquacultured Banggai (details in the attached White Paper).
With an average export of 92,000 fish per year, and given that NOAA estimates the import into US of Banggai Cardinalfish at 120,000 specimen per year, it is evident that in average the majority (76%) of Banggai entering the US since 2012 is coming from us.

We have been closely monitoring all the diverse regulatory processes for Banggai Cardinalfish (IUCN, CITES, ESA, etc.), but we have never participated directly, limiting ourselves to provide background papers to our partner importers. Being aquaculture producers, we believed that aquacultured specimen would be clearly acknowledged by regulatory and scientific authorities separately and outside of the contest on wild Banggai, and we have always preferred to keep a low profile.

With NOAA’s proposed rule that “The import and export of wild caught and captive-bred Banggai Cardinalfish into and from the United States and its territories would be prohibited”, we are compelled to submit our comments on the significantly adverse impact on our aquaculture activities in Thailand and on the negative impact that will result if pressure reverts on wild-caught specimens when the largest aquaculture operation in the world loses its major market and will be likely forced to cease operations.

The prohibition of captive-bred imports appears in NOAA proposed rule out of the blue and without any specific justification. The NGO petition of April 22, 2021 and all current NOAA papers on the proposed rule focus only on the assessment of wild Banggai population in Indonesia and its fisheries and trade. S.E. Asian aquaculture is not mentioned, quantified and discussed, only abruptly proposed to be banned.
At the same time the proposed rule will allow only domestic US aquaculture. From the draft NOAA EA: “Alternative B of the proposed NOAA rule has been selected because still allowing interstate commerce of domestically-bred Banggai Cardinalfish”.

This is a highly unfair, uninformed and biased decision, marking the first time ever in the history of the regulatory framework of the aquarium industry that “foreign” aquaculture is considered as negative as wild capture.
Aquaculture, wherever conducted, has always been considered as the main accepted path to improve the environmental sustainability of the aquarium industry. The proposed ban will undermine this path in S.E. Asia, putting a huge responsibility on NOAA side.

We established our farm in Thailand because the Government of Thailand totally prohibits the export of wild marine ornamental fish and invertebrates, and only certified aquaculture is allowed (only for fish) under very strict licensing and monitoring protocols.

If approved, the proposed ban of “foreign” aquaculture of Banggai Cardinalfish will:

•Raise huge issues on key Conservation, Legal, Environmental Justice and International Trade matters, leading to multiple litigations and closer scrutiny of the NOAA process leading to the rule;

•Cause the closure of our farm (for the loss of its main US market) and the forced culling of our 10,000 strong broodstock bank, since we are not allowed to release Banggai Cardinalfish in open Thai waters;

•Create a very dangerous precedent, discourage other current and future marine ornamental fish aquaculture efforts in S.E Asia, home of the original biological resources, and cast a shadow also on freshwater ornamental fish, mostly produced by aquaculture in Asia.

We attach below our “White Paper on the Proposed Rule on Banggai Cardinalfish NOAA-NMFS-2023-0099”. The paper details openly our work and results, and includes all our comments on the negative impacts that will result if NOAA’s proposed rule is adopted.

We have also asked Department of Fisheries of Thailand to issue its own statement on the proposed NOAA rule and on our operations, and the official statement will be posted on NOAA comment page soon."

Phuket, Thailand – October 9, 2023
•Apinya Songpradit, Export Manager, Nautilus Park
•Prasert Khaewin, Farm Manager, Octopus Farm
•Alessandro Montaldi & Paolo Montaldi, Technical & Marketing Advisors

 

[Tony Thompson]

Below is the comment from Departmnet of Fisheries (DOF) Thailand as mentioned in the comment from the Thailand fish farm.

Comment From the Department of Fisheries (DOF) Thailand

According to the proposed protective regulations under Endangered Species Act that the importation of Banggai cardinalfish from foreign countries will be prohibited while the interstate commerce activities are still permitted. Similar to the US that presently in Thailand, the Banggai cardinalfish is already in place, however, in our case, the precise data of the current existing Banggai cardinalfish in domestic farm is recorded 15,000 individuals. All of these 15,000 fish are produced3

from the first generation of introduction from Indonesia since 2012. The production from the farm are for both domestic and international trades, and the broodstocks are selected and maintained for further breeding. As a consequence, the additional importation of broodstock from Indonesia for breeding has not taken place after then.

Therefore, we have the precise information to suggest that whether domestic or international commerce activities from the farm certified by the government authorities certainly is not associated with threats to Banggai cardinalfish or would negatively affect any efforts aimed at the recovery of wild populations of the species.

Even though Department of Fisheries (DOF Thailand) supports the enforcement of the proposed protective regulation as to protecting fish in a wild, we have the strong view that there should have some rooms for inter trading of Banggai cardinalfish from the farm which are certified by the state authorities that those fish are not associated with threats to Banggai cardinalfish or would negatively affect any efforts aimed at the recovery of wild populations of the species.

We believe without any doubt that the permit for international trading with that condition will not only significantly reduce demand and pressure to the wild population but also to enhance the recovery of wild populations of the species.

Last but not least The Department of Fisheries of Thailand certify that the farm follows the Aquaculture Control System and the export control as following.

The Aquaculture Control System

Aquaculture farmers are required to register with the department of Fisheries then to receive the Good Aquaculture Practice (GAP) certification.

In the process of inspection for GAP Certification, the farm will be inspected for good farm management, the use of fry of known origin.

Also feeds, medicines, chemicals, and production factors must be properly registered with government agencies.

The quality of water used for raising is within the appropriate criteria and farmers must keep records of fish farming activities on their farm regularly.

When the results of the farm assessment pass, farm will be certified with GAP standards for 3 years and the Department of Fisheries will inspect farm at least once after receiving certification.

The traceability system for the products from coastal aquaculture farms can be obtained from the Aquatic Animal Fry Movement Document (FMD) and the Aquatic Animal Movement Document (MD).

The farm must prepare the FMD and MD every time aquatic animals are traded. This is to ensure that aquatic animals banggai cardinalfish from this farm are all from aquaculture with are efficiency and responsibility and follow the traceability system.

The procedure for export control

Pre-export procedure

1. The exporter will submit an application for aquatic animal export and attached with required documents via the Department of Fisheries electronics system

(1) Copy of Invoice

(2) Copy of Packing list

(3) Copy of documents to identify the origin of aquatic animal (Aquaculture)


2. The officer considers and examines the export application and attached
documents. If they are in accuracy, consistency and meet requirement, the officer will issue export permit to the applicant. Each export permit is applicable only to the shipment requested and can be valid within 15 days.
Export procedure

1. The exporter informs the departure of the shipment and present the export permit which issued by the Department of Fisheries as well as the original documents mentioned above to the officer.

2. The officer inspects species and quantity of fishery goods to verify their compliance with the data specified in all attached documents.

3. Fishery goods will be systematically assessed under risk management. If it is correct the officer will release goods to export to destination.

To accompany our comment, the files of the overview information on the Aquaculture Control System and export control system are also attached herewith for your consideration. We are more than pleasure to provide additional data and information if needed.

 

[Tony Thompson]

As a matter of interest the public comments submission to NOAA has been extended to Dec 15 2023

There will be a informational meeting and public hearing on November 17, 2023

"The informational meeting and public hearing on November 17, 2023, will be conducted online as a virtual meeting, as specified in the ADDRESSES above. More detailed instructions for joining the virtual meeting are provided on our web page (see https://www.fisheries.noaa.gov/action/proposed-protective-regulations-banggai-cardinalfish )." NOAA.

 

[Tony Thompson]

Action​

Notice; informational meeting and public hearing.

Summary​

The public comment period was extended to December 15, 2023.

Dates​

An informational meeting and virtual public hearing will be held online on November 17, 2023, from 7 to 8:30 p.m. (Eastern Standard Time).

Addresses​

The informational meeting and public hearing will be conducted as a virtual meeting, and any member of the public can join by internet or phone regardless of location. You may join the virtual meeting using a web browser, a mobile app on a phone (app installation required), or—to listen only—using just a phone call, as specified at this link:

https://www.fisheries.noaa.gov/action/proposed-protective-regulations-banggai-cardinalfish.

You may submit comments verbally at the public hearing.

 

[Magnapinna]

That’s their new catch phrase to get their way on what they want.

The irony is fantastic. Climate change + habitat loss -- which are very real and pressing concerns -- will continue with or without wild import/export, and are both unrelated and dramatically more impactful to the population at large than the aquarium trade. Depending on the severity and progression of these issues, the fish may struggle to repopulate regardless.

One could argue that without captive populations, a given species may cease to exist outright. Many specimens in captivity means many research opportunities --- and should a means of captive reproduction be introduced, many individuals with which to replenish and potentially rewild the species. Should they succumb to environmental threats in nature, collection will be much more difficult, and attempts to repopulate much less successful. Is success guaranteed? Of course not. But failure is guaranteed when your laissez-faire approach to conservation leads to critical endangerment