NOAA to Propose Ban on import of Bangaii Cardinal

Bpones

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Looking online recently the price for these guys is all over the place. Live aquaria has some listed at $109. I’ve seen other sites as high as $149. But also still seeing lower prices as well. They have never been a fish I felt I Had to have but will be interested in seeing how this all plays out.
 

steveschuerger

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Just did a quick search. Reefs4Less has smaller ones for just under 21 dollars if people are looking for them. I got mine almost 2 years ago on sale for about the same at PetCo.
 

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This isn't about Banggai Cardinalfish. They are just the poster child radical special interest groups grabbed onto because they had legitimate issues in the past. These issues have been resolved through CITES oversight and the relatively few fish entering the trade from their natural habitat are now part of a well managed fishery. The Indonesian government and the locals spent years and made significant investment restructuring the fishery to make it sustainable.

It should be telling that the Center for Biological Diversity (CBD), an organization more interested in the paychecks of its lawyers than science, is behind this proposal as they are the organization who petitioned NOAA for the 4d rule. Its noteworthy CBD, along with Earth Justice, and the Humane Society of the United States, is also one of the organizations suing the state of Hawaii to ban the Hawaii fishery. This isn't about populations of fish in the wild, this is about ending the keeping of animals of any kind in captivity. Why else would they go after fisheries that are some of the most well managed and have mountains of research spanning decades?

CBD recently sent out an email saying banning the import and export of Banggai Cardinalfish is not enough and encouraging their members to submit comments encouraging NOAA to ban ALL sale of Banggai Cardinalfish in the United States. It should be very obvious the true state of the fishery and wild population is of no concern to them. CBD lawyers make millions of dollars by suing US Fish & Wildlife Service and NOAA and receiving settlements under the Endangered Species Act and the Equal Access to Justice Act, in addition to the millions of dollars of fundraising they are able to do by convincing naive people that putting a species on a list is the same as saving the species.

Sometimes the ESA is a useful tool in conserving a species and preventing extinction. Other times, as in this case, it is so restrictive that it can actually prevent the implementation of conservation programs and cause externalities that are to the detriment of the species in the wild. Even the scientific papers for which NOAA contends this proposal is based on recommend the continued management of the fishery, not the complete closure and banning of trade.
 

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I supposed that everybody knows that first posts on this board about any sensitive topic are not likely from a hobbyist? Those that complain about radical groups are probably from the radical on the other side?

Did all of you hobbyists all get your comments in? Somebody contacted me about mine with a question. They seem to be trying at least.
 

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I am indeed a hobbyist and have been keeping fish for most of my life and have been active in the organized hobby for many years. You can find articles of mine in Coral Magazine, Amazonas Magazine, Reef Hobbyist Magazine, Reef2Rainforest, ReefBuilders, and various other print and online publications. That is where I tend to focus my energy as those published sources have editors ensuring there is at least some vetting of qualifications. Unfortunately, on forums, anyone can post anything and that leads to a lot of unqualified people with no background or experience having an outsized impact on the conversation, thus why I tend to avoid spending time engaging on such platforms. However, this issue is significant and therefore I felt it worthwhile to take the time to comment. I am happy to discuss the issues, but simply seeking to discredit me because I've never posted on this particular forum before is disingenuous and has no substantive bearing on the issue at hand. I have been involved in the conversation regarding the Banggai Cardinalfish for several years now and have thoroughly reviewed the scientific literature regarding the status of this species. I also have an in depth understanding how some of these big environmental law organizations work and what their motives and priorities are. You can attempt to discredit me personally based on your lack of knowledge of my background, but do you have any substantive information to challenge the information I provided?
 

jda

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I am sorry that you might have to wear the hundreds of similar posts by outside special interests that have come on this board to have one-sided arguments with their first post. Your name or links to your articles could be a nice way to avoid this.

Did you read this thread or the others on here? Unless you are holding more back like you did in the first post, it appears that I did more than you did about this issue. I made calls, emails (easy, anybody can do this), waited for people to call me back and then left commentary by the deadline with my sources who were willing to speak to the NOAA too. This took a lot of effort and I started in the US and it took a few hops to find the right people who knew stuff. In the end, I am nearly 100% positive that wild Banggai are being caught and sold as AQ and that at least one US importer was knowingly complicit in this. This appears hidden from some entities and well know with perhaps some documentation and evidence by others - the entities appearing to be communicating and shoring up their thoughts. It is too bad that this takes so much time. If this even has a chance of being true, I am not risking the import of other fish to die on this hill.

If getting all of the international organizations on the same page is all that comes out of this, it was worth it, right? Who can argue with that.

Going all deep-state, deep-money lawsuit conspiracy that this will lead to a stop on all collection is just not helpful at all. Tying this to Hawaii (which I personally do not agree with that ban) is distracting and also not helpful. I think that we have pretty much totally discussed this the right way, eventually, everybody got all that they needed to educate themselves and leave their comment like an adult. Heck, I think that we even had somebody say that none of this is legal because they did not like that Congress could charter entities to do things like this - of course, Congress can do this and it is totally legal, so this was super helpful too.

Besides, isn't all of this about a month or two too late? Public comment period ended last week.

FWIW - I don't blame anybody for not wanting to converse on a message board anymore. I am mostly here to try and help new people get their tanks going, but I have lots of moments of just disappearing too.
 

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For some more context, once the poo started to hit the fan with Underwater Creations and Vibrant, we had probably a dozen (maybe more) folks whose first post was that they were some kind of expert in bacteriology or chemistry and that the product was certainly some newly formed bio weapon that ate algae and was not a chemical like all of the testing said that it was. They did not post about actual credentials or anything either... and of course they were wrong with Vibrant being registered with the EPA as a Busan 77, an algaecide.

With this issue, the ReefBuilders article did not even differentiate between a special interest and the NOAAs actual proposal... that was super fun and also disingenuous, incompetent or both. There were a few others out there too with made up quotes from the NOAA text that nobody could find in the proposal.
 

AP Fishkeeper

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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.
 

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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.

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
 

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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
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.
 

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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.
 

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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
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.


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 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.


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.


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.
 

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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
 

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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.
 

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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.

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
 

AP Fishkeeper

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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
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.
 

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Estimated figure 120,000 Banggais imported each year into the USA. 90% of which are by one importer (whom I believe to be Quality Marine), and are from aquaculture stock.

That leaves an estimated 12,000 (10%) banggais imported into the USA that are not specifically accounted as aquacultered. For fairness they are also not specifically labelled as Wild Collected either.



There have been a number of comments so far enquiring what aquacultered means in this context .

Having contacted Quality Marine for more information, I was informed that the source of the aquaculture specimens was a Sea Based Fish farm in Thailand.



The NOAA 5 year periodic review was carried out after petition from Centre for Biological Diversity, the Animal Welfare Institute, and the Defenders of Wildlife.

I invite readers to visit these sites and find any suggestion that they want to ban aquariums or that they are Anti-Aquarium. PETA is often used as a scarecrow in these debates. I can see no reference to PETA in this proposal by NOAA.



Some reference has been made to both Hawaii proposed ban and this NOAA proposed ban.

Neither of these proposals mention or indicate a ban on aquariums or the entire aquarium trade. The Hawaii proposal allowed aquaculture ornamental export and the collection for personal aquariums in Hawaii. The NOAA proposal would allow aquaculture and trade within the USA boundaries.


It is up to each individual to either support or oppose the legislation. The portal for comments have been widely published.

However what aggrieves me personally is the rhetoric and in my opinion, disingenuous reporting by a number of the media outlets associated with the hobby.



I would like to remind those media outlets, they do not have a remit to propose to speak or represent on hobbyists behalf or their readership and in the case of organisations donors or members. We are a diverse community that have many different viewpoints. There is a distinct separation between trade and hobby. Do not surmise that we all think a like or that hobbyists have a responsibility for trade concerns.

Tony Thompson, aquarium hobbyist.
 

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