Recently the USA National Oceanic and Atmospheric Administration (NOAA) announced a new regulation that would effectively ban imports of the Banggai Cardinalfish or BCF (Pterapogon kauderni) in the USA. The proposed regulation can be viewed here:
https://www.regulations.gov/document/NOAA-NMFS-2023-0099-0004
OFI is opposed to the proposed regulation as it is unlikely to have any impact on the conservation of BCF in the wild, and would negatively impact efforts by industry to develop aquacultured BCF for the international market. It would appear that NOAA has largely ignored a mountain of information demonstrating that the current trade in this species, and the current management plan for BCF, are producing positive conservation outcomes and meets several of the UN Development Goals. It also ignores the fact that the vast majority of BCF imported into the USA are in fact aquacultured and not sourced from the wild, and so do not put any pressure on the wild population.
The CITES Animals Committee has debated the listing of the BCF on several occasions. The CITES Animals Committee and the CITES Secretariat have been deeply engaged with the Indonesian government on the development and implementation of their BCF management plan; a plan which appears to be having the desired outcomes. CITES has agreed with this ultimately concluding that the management plan was robust and that the species did not require a CITES listing or further controls.
We would humbly suggest that if CITES does not deem a ban on trade to be needed for BCF, then an honest assessment of the scientific evidence available should lead NOA to the same conclusion and we would request that the proposed regulation be replaced in favor of one that protects the species by encouraging trade in sustainably raised and collected specimens.
The deadline for public comment on the proposed regulation is 5pm US Eastern Standard Time 16 October – OFI would strongly advise industry supporters to make a submission by via the Federal eRulemaking Portal at the following link:
https://www.regulations.gov/commenton/NOAA-NMFS-2023-0099-0004
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