Head of DMWR echoes Governor's concerns regarding lists of endangered coral

The Department of Marine and Wildlife Resources has raised with the federal government “very serious scientific concerns” over the proposed listing as endangered or threatened several coral species found in American Samoa waters under the federal Endangered Species Act (ESA).


DMWR’s concerns cited by director Ruth S. Matagi-Tofiga are similar to those raised last month by Gov. Lolo Matalasi Moliga in a letter to the U.S. Commerce Department, which has jurisdiction over NOAA—the National Oceanic and Atmospheric Administration’s National Marine Fisheries Service (NMFS), the agency proposing the coral listing.


In her Apr. 6 letter, Matagi-Tofiga informed NMFS official Lance Smith that DMWR is aware of an initiative to list three hard coral species as endangered and 43 as threatened in American Samoa. However, she says they are against the proposal following “careful examination of available materials and communication with our scientists and various experts...”


Among the concerns is the hard coral being misidentified and Matagi-Tofiga pointed out that the “world’s top expert on branching coral has already confirmed that two of the hard corals species in American Samoa being proposed to be listed as endangered “have been misidentified”. (She referred to a report by the Western Pacific Regional Fishery Management Council, to back up DMWR’s claim).


Additionally, she notes the longer list of proposed threatened species needs additional scrutiny.


Given that the federal Endangered Species Act operates on a species level, it is critical that the identity of species is well-established even before proposing, she said.


“This is the main crux of our contention, where the agency should be careful in listing marine organisms such as corals that are difficult to identify,” she said and noted that “we need to have thorough surveys of coral species to be conducted by other multiple experts.”


She also says that there is an acknowledged severe lack or very limited scientific data on the proposed hard coral species, adding that there is very limited species-specific demographic information on abundance, size structure, recruitment and mortality rates.


“These scientific data are critical in establishing whether populations would decline or increase in the future,” she said.


She pointed out that previous species reviewed  for listing such as salmon have long-term abundance data, productivity, harvest rates and impacts and some extend the application of population viability analyses based on these data.


“This is glaringly lacking in the 46 coral species being proposed,” she said.


Like the governor, the DMWR director also has concerns with the voting process conducted by the Biological Review Team, saying that there is a need to review the voting process used by this team.


She said the team estimated the likelihood that a coral population would fall below the Critical Population Threshold defined as “a condition where a species is of such abundance, or so spatially disrupted, or at such reduced diversity, that the species was at extremely high risk of extinction with little chance of recovery.”


According to the director, such a definition already underscores the lack of data and the “voting process seems to be highly subjective due to the qualitative nature of the process.


“This is very much influenced by speculations and the underlying notion that corals are highly vulnerable and not highly adaptive, contrary to the numerous recent studies on coral physiology brought about by climate change,” she said.


“Therefore, the voting results may have stemmed from the individual scientist's perception of extinction rather than solid scientific data,” she pointed out. “Other scientists have already expressed concern that the results can be easily influenced by the membership of the team.”


Matagi-Tofiga went on to point out that the primary threats identified for coral species are impacts from climate change, namely ocean warming and acidification. Additionally, the ESA had surpassed its utility and is not an appropriate tool to address global climate change and ocean acidification impacts.


She noted that ESA provides protection of imperiled species through the prohibition of take.


“These are very serious scientific concerns that make the proposal to list 46 of hard coral species found in our territory highly contentious. The process has also been inconsistent with other cases such as the unwarranted listing decision for the bumphead parrotfish,” she wrote.


“We await substantial answers to these concerns,” she concluded. (See Tuesday, April 16, 2013 Samoa News edition on similar concerns raised last month by the governor)

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