DMSION OF AQUACULTURE THE HoLLAND BmLDING, SUITE 217 {850) 617·7600 6oo SouTH CALHoUN STREET {850) 617-76o1 FAX TALLAHASSEE, FLORIDA 32399-1300
FLORIDA DEPARTMENT OF AGRICULTURE AND CONSUMER SERVICES COMMISSIONBR ADAM H. PuTNAM
October 31, 2014 Ann Garrett Acting Regional Administrator NOAA, National Marine Fisheries Service Protected Resources Division Pacific Islands Regional Office 1845 Wasp Boulevard Honolulu, lll96818 Re: Docket No. NOAA-NMFS-2014-0072 Dear Ms. Garrett:
Please accept our comments relative to the 90-day finding on a petition to list seven species of Indo-Pacific species ofPomacentrid reef fish as endangered or threatened. The Florida Department of Agriculture and Consumer Services (department) is the lead agency for the State of Florida for aquaculture. We are charged by state law with enhancing the growth of aquaculture while protecting Florida•s environment.
Our comments are specific to the orange clownfish, Amphiprion percula, and our recommendation is that if a listing is contemplated, that the listing be for animals found within its native range. There is limited trade in wild-collected animals and the species is globally cultured in increasing numbers such that it is unlikely the species is or will become endangered within the foreseeable future.
Efforts to spawn marine ornamental fish in the United States began in 1972 at Bayboro Harbor, St. Petersburg Florida, by rival companies led by Frank Hoff and Martin Moe, respectively. They focused on the genus Amphiprion because of''the beauty of the clownfish (Hoff 1996:3) ... By 1975, they spawned and cultured three species, produced species hybrids and by 1977 spawned the orange clownfish (Hoff 1996). Arguably because of this very early work and subsequent publication, the orange clownfish is readily produced commercially and privately by advanced aquarists throughout the United States and other countries. Relative to private production, there are hundreds to thousands of hobbyist breeders and the international trade in the species is mostly of aquacultured and no wild-caught individuals (personal communication A. Rhyne Roger Williams University).
The petitioners did not provide population estimates for the animal within its native range nor did they comment upon or include estimates of the number of animals held in captivity. None of
~ ,-_8_0_0--H-E-LP-F-LA------~.------w-w-w-.-Fr-es-h-Fr_o_m_FI-or-id-a-.co--m Garrett Letter Page Two October 31,2014 this information appears in grey or peer-reviewed literature and was provided to the department by farmers culturing the orange clownfish
Currently, the department has certified 10 aquaculture facilities that are growing and marketing the orange clownfish. These farms include Ocean Reefs &Aquarium (http://www.orafarm.comL) and Proaquatix (https://www.proaquatix.comL). Annual Florida production of the orange clownfish is approximately 55,000 animals that are marketed domestically or internationally to the aquarium hobby.
Aquaculture farms certified by the department are subject to on-farm inspection for compliance with Chapter 597, Florida Aquaculture Policy Act, Florida Statutes and Chapter 5L-3, Aquaculture Best Management Practices, Florida Administrative Code. Each farm must include their facility unique identification number on all business related paper trail (receipts, bills of lading, bills of sale) and we encourage including this identification number on packaging. The department conducts unannounced farm inspections for compliance with state laws which includes enforcing the Florida Fish and Wildlife Conservation Commissions regulations relative to the possession, transportation and sale of nonnative species. The 10 certified facilities are currently in compliance with federal and state laws.
In addition to the Florida farms there are three large farms that culture the orange clownfish in the United States. These farms are Alpha Aquaculture (http://alphaaquaculture.com/) in Wisconsin, Sea & Reef Aquaculture (http://www.seaandreef.com/) in Maine, and Sustainable Aquatics (http://sustainableaquatics.com/) in Tennessee. Their combined annual production is approximately 393,000 fish.
During 2013, Mystic Aquarium and Connecticut Sea Grant College Program surveyed the states of Maine, New Hampshire, Vermont, New York, Massachusetts, Rhode Island, Connecticut, Pennsylvania, New Jersey, Delaware, Maryland and West Virginia to determine the size and scope of marine ornamental aquaculture industry in the Northeastern United States. They found 550 marine aquarium businesses, education or research institutions. Of the 13 respondents who reported conducting their own commercial marine ornamental aquaculture, six reported aquaculturing clownfish, and two of those specifically mentioned the orange clownfish (Morcom et al2014; personal communication P. Anderson Mystic Aquarium). There are probably additional farms located throughout the United States that produce and market locally and regionally, but that production is inadequately reported. The recent Census of Aquaculture reported 16 farms that sold 1.06 million marine ornamental fish with a value of$10.3 million during the 2012 production year (USDA 2014). The prior Census of Aquaculture for production year 2005, combined marine ornamental fish with freshwater ornamental fish because farm numbers and sales values were not significant enough to report as a separate category (USDA 2006). In summary, total annual U.S. commercial production of the orange clownfish is very conservatively estimated to be 448,000 fish and production has significantly increased over the last five years. Garrett Letter Page Three October 31, 2014
In addition to the U.S. farms, there are farms producing the orange clownfish in Bali, Germany, Israel, Malaysia, Singapore and United Kingdom. Unfortunately, production data is not available.
We suggest that the National Marine Fisheries Service consider describing and listing the species for its native range as authorized by the Endangered Species Act to provide the protections inherent to the Act and to satisfy the petitioner's desires. The practical effect will be to stop what little, if any, commercial trade that occurs associated with range-originated animals.
As an example of agency decision making that distinguished at-risk populations from those unlikely to become endangered, the National Marine Fisheries Service identified and listed five distinct population segments of the Atlantic sturgeon in United States waters but did not list animals that occur in Canada (Federal Register 77(24):5880-5912; Federal Register 77(24): 5914-5982). The species historically occurred along the Canadian and U.S. Atlantic Coasts from Labrador to Florida. Breeding populations exist in at least 14 Atlantic Coast rivers in the United States and several more in Canada (St. Pierre 2006). After the listing, commercial production of Canadian-sourced Atlantic sturgeon products and a variety of life stages continued and may continue and expand in the United States other countries (personal communication D. Bernhart National Marine Fisheries Service) without negatively affecting populations in the waters of the United States. We are seeking similar decisionmak:ing by the National Marine Fisheries Service to distinguish between animals that are not at-risk and those that may be at-risk.
Thank you for the opportunity to provide comment. If there are any questions or an interest in receiving copies of the references we have cited, please do not hesitate contacting me.
I Thank you, 1\:'JZ ~t!P~~c-f;;;,;_ ,--
Kal Knickerbocker, Director Division of Aquaculture
cc: Art Rawlins, President, Florida Tropical Fish Farms Association Allen Register, Chair, Aquaculture Review Council Marty Tanner, President, Florida Aquaculture Association References
Hoff, F. 1996. Conditioning, Spawning and Rearing ofFish with Emphasis on Marine Clownfishes. Aquaculture Consultants Inc., 33418 Old Saint Joe Road, Dade City, Florida.
Morcom, S., R.S. Pomeroy and P.A. Anderson. 2014. Marine ornamental aquaculture in the Northeast U.S.: The state of the industry 2013.2014 Summer Science Meeting, Southern New England Chapter, American Fisheries Society (bttp://snec.fisheries.org/wp content/uploads/2014/06/Summer agenda 2014.pdfaccessed October 28, 2014).
St. Pierre, R. 2006. Acipenser oxyrinchus ssp. oxyrinchus. In: IUCN 2013. IUCN Red List of Threatened Species. Version 2013.2.
USDA (United States Department of Agriculture). 2014. Census of Aquaculture (2013). United States Department of Agriculture, Washington, DC. Volume 3, Special Studies, Part 2, AC-12-SS-2 (http://www.agcensus. usda.gov/Publications/20 12/0nline Resources/Aquaculture/aquace n.pdf accessed October 28, 2014).
USDA (United States Department of Agriculture). 2006. Census of Aquaculture (2005). United States Department of Agriculture, Washington, DC. Volume 3, Special Studies, Part 2, AC-02-SP-2 (http://www.agcensus.usda.gov/Publications/2002/ Aquaculture/ AQUACEN.pdf accessed October 30, 2014).