First, let me post the portion of the letter I sent to MAC in response for their call for comments on the agenda. I did not feel it was appropriate for me to post it here prior to the meeting.
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USL- This is an issue I've been working on in my industry
forum at
www.reefs.org. As I stated in my public comments, I believe
that the only animals that should ever be included on an unsuitable
species must fit into one of these three categories:
- Obligate feeder- It must be known that the fish
feeds on items impossible or too expensive to provide in captivity.
This list is actually smaller than most people think. The list we
came up with over at
www.reefs.org consists of less than 30 fish
species, with about 90% of those being butterflies.
-Animals that get too large for the majority of
hobbyist tanks- This one should be fairly easy. Someone needs to
determine what an "average" size aquarium is and then determine what
the maximum animal size for that aquarium is. Don't allow fish to be
imported into the hobby trade over that size. Will there always be a
few hobbyists with an extraordinary size tank that will argue he
should be able to keep a nurse shark? Of course. But we aren't
catering to the few- we're catering to the majority. Public aquariums
are a different story and they could easily be issued import permits
for these animals.
-Deadly Animals- This one is easy. It pretty much
consists of the blue ring octopus. It is important that this list
consist of deadly animals- not poisonous ones. Lionfish are
poisonous, but not deadly. There will always be someone in the world
allergic to something. There's probably someone out there allergic to
damsel fish slime coat. But again, we need to cater to the majority,
not the minority.
NO animals that are considered to be difficult for unknown reasons
should be included. With the advancement of technology, animals that
we can't keep now can become some of the hardiest fish in the future!
My favorite example of this is Acropora. 10 years ago it was
considered to be only for the most advanced hobbyists- and half of
them couldn't keep it. Now it is one of the most prolific corals-
growing and reproducing at astonishing rates in average hobbyists
tanks. If we had banned it 10 years ago because the mortalities were
high, we wouldn't have been able to figure out the technology
necessary to keep it alive. And no one needs to fool themselves by
thinking that these advancements were made by research scientists and
public aquariums. It was the determination and hard work of countless
hobbyists who fell in love with these animals and wanted to insure
their health. Making "difficult to keep" animals only available to
research scientists will never get those animals off the USL.
With all of that said, we come to the issue of suitability vs.
sustainability. This is one that keeps me up nights! I change my mind
about every 15 minutes as to where I stand on this issue, and have
finally come up with a happy medium to pertain to my personal
business. Suitability refers to the ethical issues of keeping an
animal in captivity...is that animal suitable for the hobby. For
instance, let's take the mimic blenny Exallias brevis as an example.
This fish is a documented obligate coral polyp feeder. We all know
that it will probably survive for about 6 weeks before it starves to
death in a hobbyists tank. Let's say that a study determines that
1000 E. brevis can be sustainably harvested each year from Reef A.
That means that as long as we are importing less than that the
industry will have no effect on the health of the ecosystem
containing this fish. At that point, it strictly becomes a moral
issue. Do we want to harvest 1000 fish that we know are doomed to
starve in 6 weeks?? Suitability vs. Sustainability. Is that fish
suitable? No. Is it sustainable? Yes. I think that if we start basing
industry operations on what's "moral", we could be in for some
serious trouble. Who defines moral? I would guess that PETA defines
moral as "leaving every animal in it's natural environment". I worry
when we start legislating morality and ethics. Where does it stop?
Mary Middlebrook personally does not think it's moral to receive fish
one day and ship them out the next. So should the entire industry
have to conform to my moral stance? Another valid point is that once
a fish leaves the reef, it's never going back. Therefore, once it's
gone no matter if it dies in 10 minutes or 10 years the impact on the
reef is the same. Maybe the question of suitability is better
addressed in an educational way than a legislative way. If the
collectors, exporters, importers, retailers, and hobbyists are
educated to know that E. brevis is unsuitable, that would greatly
reduce the numbers harvested and solve the problem in a manner other
than legislating ethics. Another question is who determines what
suitable really is?? How long does a fish have to live? Just long
enough to get to the hobbyist? That's all the MAC standards require-
that a fish live for the approximate 2 weeks it takes to get from
collector to hobbyist (less time in many cases). Or should it live
for a significant portion of its lifespan? Research hasn't even
established the life spans of most animals.
With all of those questions thrown out there, I'll give you where I
am on this topic. I am perfectly happy with a USL being implemented
that consists solely of animals falling into the 3 previously
mentioned categories. I think such a list would actually be good for
the industry, showing that we are willing to police ourselves, and it
would have no real impact financially. I think a list consisting of
anything other than the 3 criteria would spell disaster for the
industry. I never have imported any of the species on the USL we've
created over at
www.reefs.org, and never will. There are also a lot
of other fish I won't import for personal reasons. However, I'm not
one to tell the entire industry that they have to do things my way,
because frankly there are too many "gray" areas in this issue.
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Ok, there's the letter, and here's what happened at the meeting.
When we first starting discussing the USL, the majority of the industry was saying "NO list". MAC said there should be some kind of a short, well-researched list. Although I have been disagreeing a lot with MAC lately, I stepped forward and said that I do agree that we need a list. Then I discussed the 3 criteria and explained how we need to take a proactive approach to showing the government that we can police ourselves. The idea of banning "deadly" was accepted immediately, we discussed large and quite a few (not all) wholesalers voiced agreement with this. The obligate feeders list was a little more complicated. I argued that no one was going to go out of business because of less than 30 species. However, one wholesaler said that he is currently importing larval raised butterflies that are known obligate coral polyp feeders- and that they are readily eating prepared foods. So that throws a new twist in the mix. A couple of other wholesalers that I know and respect backed up this position, saying that technology concerning obligate feeders is changing as we speak, and to ban the import would make it more difficult to get the larval raised ones into the country. I think it's important that we support this new technology and not throw up obstacles. I know some of you are going to say "Well, we'll just issue permits to allow only the import of larval raised". Guys, it isn't as easy as that. For example, right now Wellsophyllia is NOT a recognized genus of coral- it has been scientifically proven that it is Trachyphyllia. However, CITES still requires it to be listed as Wellsophyllia and Fish & Wildlife will go through any shipments listing Trachyphyllia to try to find an "illegal" Wellsophyllia- I had that happen to me in January. That's a cut and dry obvious issue- Wellsophyllia is NOT Trachyphyllia. Importing aquacultured fish vs. wild caught is a much more difficult area. How do you KNOW it's aquacultured?? How do you PROVE it?? How do you make it "cheat proof" to insure someone isn't importing a wild caught as aquacultured?? Too much gray area. As I've said many times before, we have to steer clear from gray areas or we're opening ourselves up for all kinds of problems. So I agreed that we should not include the obligate feeders and stick with too large and deadly. Everyone seems to be on the same page with this, and the USL Committee will be started sometime before the end of this year to throughly research the individual species and input from all interested parties (industry and conservation). I will be serving on that committee. By the way Fishaholic, Randy Goodlett was at the meeting and didn't say a word concerning the criteria of the list. He only made a couple of comments- one was in regard to how this would affect the freshwater industry. So if you thought he agreed with the obligate feeders being included, I guess you were incorrect.
So where do we (this forum) go from here? Well, I would say that we need to continue work on the large list. I have asked for volunteers to lead this up and no one has stepped forward yet.... But we have several months to work on it, so time isn't of the essence right now. After that, I think we need to figure out some way to educate people about the obligate feeders. It is not MAC's job to educate the public- they are a certifying body. Education is the responsibility of the industry, hobbyists, and other concerned parties. Let's think of some ways we could educate the general public about obligate feeders. One thing that was mentioned at the meeting is that Germany and England have designations for marine ornamentals instead of ban lists- beginners, intermediate, and advanced. Maybe we could figure out some way to do the same thing. I think many people simply are not aware that many of the obligates we have on our list are obligates. I know I wasn't. Think about it, and let's see what we can come up with.
