The National Oceanic and Atmospheric Administration (NOAA) has proposed 4(d) rule NOAA–NMFS–2023–0099 which would ban the import or export of the Banggai cardinalfish into and out of the United States regardless of its source.
What it means:
Banggai cardinalfish would no longer be available, even though those being imported into the U.S. are almost exclusively aquacultured. This is despite the fact that the aquarium trade recognized the plight of the Banggai cardinalfish over a decade ago and worked to establish aquaculture facilities to provide these beautiful and hearty fish that peacefully coexist with tankmates.
What you can do:
- Send a letter to NOAA expressing your belief that the proposed 4(d) rule should not be adopted.
o Use some of the points we have provided below, as well as your own opinions, to write your letter expressing your opposition to the proposed rule.
o To submit your comments, go to https://www.regulations.gov/commenton/NOAA-NMFS-2023-0099-0004 and fill in the required information along with your comments.
- Share this with others in the trade and the hobby that believe we should contribute to the conservation of this fish by encouraging sustainable harvest and aquaculture.
Suggested comments to use:
- I oppose the proposed rule NOAA–NMFS–2023–0099, which would ban trade in the Banggai cardinalfish.
- The Banggai cardinalfish in the U.S. come from aquaculture, so they do not put any pressure on the wild population.
- NOAA appears to have presented the data on the Banggai cardinalfish very selectively, ignoring a mountain of information demonstrating that the current trade in this species, and the current management plan for the native fish, are producing positive conservation outcomes.
- The Banggai cardinalfish naturally occurs in isolated areas within its native range. The management plan that is currently in place protects these genetic strains that may have been reproductively isolated for 100,000 years or more.
- The CITES Animals Committee and the CITES Secretariat were deeply engaged with the Indonesian government on the development and implementation of their Banggai cardinalfish management plan; a plan which appears to be having the desired outcomes.
- The CITES Animals Committee also debated the listing of the Banggai cardinalfish on several occasions, ultimately concluding that the management plan was robust and that the species did not require a CITES listing.
- The marine aquarium community recognized the challenges facing the Banggai cardinalfish over a decade ago and established captive breeding programs. Do not destroy all that work and progress.
- An honest assessment of the science and trade data concerning the Banggai cardinalfish should have led NOAA to conclude that the species should not be listed on the ESA at all. There is no justification for the proposed 4(d) rule banning trade in the species and such a rule will undoubtedly harm its conservation.
- Please abandon this proposed 4(d) rule in favor of one that protects the species by encouraging trade in sustainably raised and collected specimens.
Source: This article is a repost from the Pet Advocacy Network
