I am curious, why not? Is it because we have more "oversight" in Hawaii?Can we please not compare Hawaii with Indo?
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I am curious, why not? Is it because we have more "oversight" in Hawaii?Can we please not compare Hawaii with Indo?
The reasons for the bans (real and proposed) are completely differentI am curious, why not? Is it because we have more "oversight" in Hawaii?
The deadline is not up as NOAA has extended the comment period to December 15th.
The fact that wild Banggai Cardinalfish are being sold in the US is not a secret, nor is it a problem. While most (85% or so) of the Banggai Cardinalfish imported into the US are sold through one company that sources its specimens from an aquaculture facility in southeast Asia but outside of Indonesia, the other 10% or so is a mix of wild fish and aquaculture specimens. Of the wild fish, some come from introduced populations in Indonesia outside the native range and some come from the managed fishery in the Banggai Islands. The fish from the Banggai Islands are subject to permit requirements, quotas, and marine protected areas and collection is prohibited during peak breeding seasons. This fishery has been under CITES oversight since 2016 and there are several studies documenting the recovery of overfished populations in that native range. Buying fish from this fishery, which the Indonesian government and locals have spent significant resources reforming, is not a bad thing for US importers choosing to do so. In fact, this is one of the most important fisheries to support as doing so shows that investing in reforming fisheries with problems pays off in the long run! It should also be noted that one of the studies (Ndobe, et al., 2018. Study to access the impact of international trade on the conservation status of Pterapogon kauderni (Banggai Cardinalfish).) conducted on the Banggai Cardinalfish fishery stated concern that ex situ breeding programs removed benefits of the species to local communities in the Banggai Islands and had the potential to reduce incentive for in situ conservation of wild fish in the endemic range as well as reduce incentives to conserve associated habitats and microhabitats. The importers bringing in wild Banggai Cardinalfish from the endemic range are only complicit in supporting the livelihoods of local Indonesians and providing dollars to incentivize conservation of the resource and the habitats that support it.
Despite the potential downsides, aquaculture is likely overall a good thing for this species as it supplements supply to fill demand that may not be sustained completely without overfishing the wild population. The reformed wild fishery is also good because it provides for livelihoods and sustainable development in remote parts of Indonesia as well as provides tangible value to the natural resource and its habitat.
The reason Hawaii is relevant here is because the same groups that are litigating in Hawaii are the ones who petitioned NOAA for the Banggai Cardinalfish listing, despite the mountain of evidence showing the current level of harvest and trade to be sustainable. They indeed have a radical agenda and have built a lucrative business suing the US government under the ESA and recovering settlements through the ESA and EAJA. While maybe not widely known about outside those of us with a background in administrative law, this information is generally publicly accessible and is not a deep-state conspiracy. The history of EAJA and the ESA and the abuses of such legislation are well documented. The method these groups use to fund their campaigns is often colloquially referred to as "sue-and-settle." There is also the issue of regulatory capture and the revolving door of politics. Many executive branch employees eventually get plush executive jobs at some of these 501(c)3s (Several former Directors of USFWS come to mind).
As far as their goal to end the aquarium hobby, they usually don't say it in such terms. More often they will speak of eliminating the wildlife trade, with the understanding this includes tropical fish. This is because they do recognize on some level that banning aquariums is currently outside the overton window. So they tend to frame their campaigns claiming a conservation issue and not an animal liberation issue. You can go to CBD's website and see where they are asking their members to tell NOAA that banning import of Banggai Cardinalfish is not enough encouraging them to write to NOAA to ban all sales of Banggai Cardinalfish in the US. This means not only do they want to cut off the US market to the now well managed Indonesian fishery and cut off the US market to the largest aquaculture producer of Banggai Cardinalfish in the world, but CBD wants to ban all trade in the species even from domestic aquaculture sources. To put it simply, they don't believe Banggai Cardinalfish should be in captivity, period.
As to legality and Congress, yes, many people do not understand how the US government works. Congress delegated power to the Department of Commerce to regulate marine species under the ESA. However, Congress also explicitly stated in the ESA that the administrative agencies to which the delegated power must use the best available scientific data in support of promulgating regulation. It is hard to argue that the most up to date science supports NOAA's current proposed rule.
Although I'm not quite sure what you're asking as far as the difference between the NOAA proposal and the CBD petition, it should be noted NOAA likely wouldn't even be making the proposal without the threat of litigation from CBD. On the NOAA text, the proposal and accompanying documents did a relatively poor job outlining the issues and one has to dig into the citations to get a clear picture of what's going on. Unfortunately, NOAA seemed to ignore much of what it cited as the conclusions NOAA drew and the conclusions of those studies were substantially different.
Curious, how do you know this "one company" only has one source? And how does that one source actually define aquaculture? Aquaculture does not assume captive breeding.While most (85% or so) of the Banggai Cardinalfish imported into the US are sold through one company that sources its specimens from an aquaculture facility in southeast Asia but outside of Indonesia
Jay,As a side note: The problem with wild caught Banggai, the pen cultured ones, and any tank raised ones that pass through the same SE Asian systems is the high mortality caused by the iridovirus. With good biosecurity, domestically raised ones avoid that problem.
I’m working on longevity data on these, and it isn’t pretty. Of 100 Banggai acquired by professional aquarists, 30% did not survive the first 60 days. The longevity is on average only 1.8 years due to the harvesting effect of that early mortality. Since these 100 fish were a mix of wild caught and captive raised, it is probable that the actual mortality rate would be much higher if the domestically raised fish were excluded from that data.
For years, I would only acquire domestic Banggai, or raise them myself. I think that is the only sustainable option.
Jay
Curious, how do you know this "one company" only has one source? And how does that one source actually define aquaculture? Aquaculture does not assume captive breeding.
What all of my calls found was that the Indo numbers and data could be lies, manipulated or otherwise inaccurate. The whole "Indo is going to do the right thing to keep US business" appears to be wholesale inaccurate. The different entities are supposed to be sorting this out. They should be able to get it right.
The NOAA research says 90% import by the same company, so 85 could be right. That importer is also trying to distribute 85-90% of the narrative.
Jay,
How recent is your data? 10 years ago I would have agreed with you on the mortality numbers. However those aren't the trends I'm seeing now. I've recently seen several batches of imports from Indonesia doing well 4-6 months post import. That wasn't something I was seeing 5-10 years ago when every wild shipment I saw seemed to be a total loss within a month, usually less. We know the iridovirus isn't present in the endemic range and is picked up somewhere along the supply chain. It seems that supply chain in the past few years has changed in a way that has reduced mortality significantly from what it was for this species. I don't think any research has been able to pinpoint the exact source of BCI yet other than it is present pre-export from Indonesia, but not present in the Banggai Islands, and likely hopped from another species that acted as a carrier. I'd definitely be interested in looking at your data sets and seeing what can be parsed out so I hope you publish this data.
While mortality rates are absolutely a major issue for wholesalers, retailers, and consumers, it doesn't necessarily factor into the ESA determinations. A fishery is removal from population regardless of the destination and most fisheries, including the vast majority of sustainable fisheries, are 100% mortality almost immediately. For the ESA the scope of the consideration is limited to the impact on the wild population. Post-collection, pre-export mortality is factored into most recent studies on the fishery as well, so this is not overlooked either.Mortality once the fish reach the US is completely outside the scope of data applicable to anything to do with the ESA.
While there can sometimes be definitional issues, the meaning of "aquaculture" in this case is pretty straightforward. It means offspring produced in a controlled environment from broodstock that are raised and held in a controlled environment. This means bred and raised in a tank, vat, or possibly net pen. No one is disputing the fact that these fish are captive bred. NOAA states it in their report. All of the stock produced at the breeding facility you are referencing would qualify for CITES source code "C" (bred in captivity). So yes, at least 85% of Banggai Cardinalfish imported to the US are indisputably captive bred. In fact, with imports from other smaller scale producers, that number is probably closer to 90% or more.
Your calls to who? Did you talk to any of the scientists actually involved in this research? And again, you are attempting to discredit the importer, but do you have any information to dispute the substance of what the importer is saying?
Also, you don't have to trust the Indonesian government. Indonesia unquestionably has fisheries issues that need to be fixed, particularly the elimination of destructive fishing methods. However, in the case of the Banggai Cardinalfish, most of the data sources showing the sustainability of the Banggai Cardinalfish fishery are not from the Indonesian government. The US and EU taxpayers funded a lot of the research and much of it was conducted by researchers from Indonesian and Canadian Universities. There was also oversight from the international community through the CITES Animals Committee. This is much more significant than a few government reports. This issue has been closely scrutinized by people from all over the world. The Banggai Cardinalfish is a conservation success story for Indonesia. There is real potential to build on that momentum to improve other fisheries in the country. But that won't happen if the US essentially punishes Indonesia after Indonesia put so many resources into doing the right thing in this case.
The data was extracted from a larger set of group acquisitions and ranged from 1996 to 2020. Looking at longevity data is tricky. I didn't include any fish from 2020 on because you cannot measure a mortality rate on a data set where some cohorts are still alive. The data seems to show an increase in the mortality rate starting around 2000 and then remaining pretty constant, with an odd larger drop in 2017 to 2018.
I'm confident that the data shows an on-going, unacceptable mortality rate. I wish I could get get finer detail, specifically if it could be sorted by wild caught vs. domestic captive raised. Also, I can only look at fish that were tracked as individuals. Larger public aquariums track this species as "groups", but then, you cannot easily see longevity trends. Smaller aquariums are the ones who tend to track their fish as individuals. However, these smaller aquariums do not have the husbandry resources that the larger ones do, so their specimen longevity may be lessened. Still, I think it is safe to assume that home aquarists would have even fewer resources, so the data can stand as a "best case" surrogate.
Jay
Jay,
Am I misunderstanding that the sample size here is 100 fish over 23 years, giving a mean sample size of <5 a year? If so, one bad shipment (or even one particularly good shipment) could really skew results. Data from 1996 to 2016, and maybe even more recent data than that, is not a good indicator of current mortality rates. Supply chains, sources, and handling practices have changed dramatically in recent years. In addition, it sounds like this data set does not differentiate sources. There does not seem to be any controls on this data set to mitigate the effects of husbandry practices at the final destination factoring into early mortality, reliance on a particularly source of fish for an outsized portion of the dataset, and other factors that could significantly skew results. These controls would seem to be essential to interpret and extrapolate this particular dataset, especially with a sample size that is relatively small as a whole and extremely small when distributed over time. Having a bit of a window into that world, zoos and public aquariums vary widely in experience and skill levels of staff, so I do not agree that it is safe to make the assumption you do, particularly with a sample size that can represent only a small handful of institutions. While this data set may have some value for other purposes, it does not seem to be a sound predictor of current trade mortality rates.
I agree this is an important conversation for aquarists to have. However, I have to reiterate it is for the most part totally irrelevant to the question at hand of ESA regulation.
In the late 2000s, most wild imports of Banggai Cardinalfish I saw had close to complete mortality. They all seemed to exhibit the same symptoms very soon after import: The fish would stop eating, their fecal material would turn white, and then the fins would clamp. Soon after, the slime coat would slough off, and the fish would be dead quickly after that. However, today I am seeing wild shipments that have close to 100% survival rates, even months after import for trackable specimens. The mortality I do see does not display the symptoms mentioned above. I have been to several facilities that buy large quantities of Banggai Cardinalfish. A couple of these facilities are retailers that quarantine their fish for several weeks, and even after the quarantine period, they are buying in quantities in which, despite the sell through, many individuals in a batch are there for several months post import. While obviously the value of these anecdotes has limits, it is noteworthy and there is no doubt something has happened that is decreasing mortality. I'm not sure if this is a result of the training done in Indonesia by LINI to improve fish collection and handling practices, increased sourcing from introduced populations closer to export centers, changes in the path through the supply chain from the Banggai Islands, better biosecurity measures pre-export, evolution of BCI, an unknown factor, or a mixture of several factors, but something has definitely changed. While I would love to know exactly what is going on here, most Banggai Cardinalfish research is currently focused on the state of the species in its endemic range, and for good reason, so I'm not sure we'll get that answer anytime soon.Yes - the good data is over that time frame, do you have better data? I've reviewed it carefully for "outliers" and other causes, but it is what it is.....
Jay