The IMARCS Foundation's official comment on the proposed rule to include giant clams on the endangered species list

Dear Mr. Rippe,

The proposed addition of giant clams to the endangered species list, while well-intentioned, will actually harm conservation efforts and research. Labeling them as endangered will create restrictive regulations that hinder essential scientific research, making it harder to study not only their ecological effects but also promising new avenues for positive environmental impacts, such as their potential to aid in carbon sequestration and removal of microplastics. Additionally, placing them on the list will likely do little to deter poaching; illegal trade often continues despite such designations, and enforcement can be challenging, especially in the geographical areas where giant clams are found.

The IMARCS Foundation officially opposes this proposed inclusion on the endangered species list and suggests that, instead, more focus should be placed on supporting and expanding giant clam nurseries and farms, which have proven to be the most effective way to increase wild populations. These nurseries not only provide sustainable sources of clams for reintroduction into reef environments but also help meet the demand for food and ornamental trade, reducing pressure on wild populations. Expanding these initiatives instead of including giant clams on the endangered species list will lead to better outcomes for giant clam populations and, by extension, lead to more positive environmental benefits.

Imposing a broad, likely ineffective designation on this list will actually stifle meaningful conservation actions and harm countless individuals and organizations that have dedicated years to helping giant clams through research and the development of effective nurseries and farms - all of which will be negatively impacted and largely cease to exist if the proposed inclusion on the endangered species list moves forward.

We urge you to revisit and reconsider the real-world ramifications of including giant clams on this list.

Sincerely,
Jordan Hlagel
COO & Lead Environmental Scientist
IMARCS Foundation
www.imarcs.org

In addition to our response, below are several other comments on this motion that are publicly available to view at https://www.regulations.gov/comment/NOAA-NMFS-2017-0029-0035:

"OFI fully supports the protection of genuinely threatened or endangered species. However, we believe that the listing of giant clams under the ESA may not achieve the intended conservation outcomes. Instead, it could undermine ongoing conservation efforts by disrupting sustainable farming practices that are crucial for the protection and restoration of these species in the wild.
We urge the authorities to consider the extensive evidence of the sustainability and positive impact of giant clam farming. We recommend exploring alternative measures that support both conservation and sustainable use, such as enhanced monitoring and regulation, rather than imposing prohibitive trade restrictions.
We appreciate your attention to this matter and are available to provide further information or participate in discussions to develop balanced and effective conservation strategies."
- Jonathan Poh
Secretary General
Ornamental Fish International (OFI)

"It is incredibly unfortunate that giant clams are being considered to become illegal in the USA. Not just for hobbyists and their children that learn to appreciate these creatures and the importance of protecting them, but for wild populations of giant clams.
If the economic potential for aquaculture is crashed then where will clams be collected? The wild of course. People that wish to consume the meat of giant clams will continue to do so but will remove them from their natural habitat. The hobby of keeping giants clams in captivity provides economic viability to captive raise these animals.
The ‘hobby’ has gone full circle from collecting from the wild - to multi generational captive breeding - to breeding enough to place back out in the wild.
Coral reefs and their inhabitants are in danger worldwide. This proposal, if approved would be another blow to not only giant clams but to the reefs they originated from. The ability to keep these animals ensures that they are studied, understood, captive bred and appreciated. Otherwise they will silently disappear."
- Jason Zacher

"As a member of an aquaculture organization working directly with these species of clams, this proposed listing seems to neglect the wildly successful aquaculture/mariculture operations around the pacific. There seems to be a missed opportunity to move forward with partnerships that would greatly increase conservation efforts with outplanting and economic support. Moving forward with a listing, specifically of Tridacna derasa would effectively end all mariculture farms in the region and have the blowback effect of encouraging poaching and illegal harvesting of this species and others. The solution has to include the farms and communities successfully raising these species and the combined collaborative effort for conservation with the addition of an economic incentive for local communities."
- Jordan Noe

"I believe harvesting clams from the wild unsustainably should not be practiced, but this broad, sweeping ban would have a profoundly negative impact on the mariculture and aquaculture of these species, especially those carefully bred and raised and sold within the aquarium hobby. The data you use and the facts you recognize indicate that nearly all, if not all, species of giant clams imported or bred and sold within the US are not harvested from the wild and this addition will simply have no positive impact whatsoever. Rather, it will cause incredible harm to dozens, hundreds of communities in impoverished communities in Southeastern Asia. And it will probably cause them to resort to means of making a living that do cause harm to species that are threatened and their local environments, as has happened in multiple other cases where additions to this act have been made without thoughtful consideration. I believe the act as a whole requires reform, but in the meantime—this addition WILL cause harm and WILL NOT help these species in any meaningful way. It’s simply not supported by any factual data and thoughtful consideration of reality. I implore you, do not do this."
- John Lake

Furthermore, below are also some publicly available formal letters that have been sent to regulations.gov on this proposed rule: 

To whom it may concern,

I am writing to express my deep concern regarding the potential ban on the trade of aquacultured clams in the United States. As the Mayor of Likiep Atoll, in the Republic of the Marshall Islands, I am acutely aware of the profound impact such a ban would have on our community. Clam farming has been the comerstone of our local economy for decades, providing a main source of income for many residents of Likiep Atoll.

Our people have invested years of hard work and dedication into cultivating clams, an industry that has not only sustained our livelihoods but has also allowed us to remain on our atoll, preserving our culture and way of life. Should the U.S. ban the import of aquacultured clams, the economic consequences for Likiep Atoll would be catastrophic. Many of our residents would be forced to leave their homes in search of other opportunities, contributing to the already significant issue of out-migration from the Marshall Islands.

Furthermore, our community has long understood the importance of sustainable practices. We have || worked closely with local authorities to ensure that our clam farming operations do not harm the environment. In fact, the farming process itself has contributed to the replenishment of wild clam populations, as we release surplus fertilized eggs back into the ocean, enhancing the natural ecosystem.

Brood stock clams are collected and kept together in the lagoons, and therefore create collections of spawning clams in the wild. This helps with ensuring the best possible fertilization percentage in the wild.

Without needing to keep the brood stock, natural spawning won't be as effective, and the wild population will not be repopulated.

If our ability to sell aquacultured clams is taken away, the incentive to protect and conserve wild clam populations will be lost. Instead, the people of Likiep Atoll may be forced to rely on these wild clams for sustenance, leading to overharvesting and the rapid decline of the very species the proposed regulation seeks to protect. This would not only be a loss for our community but for the global effort to preserve marine biodiversity.

By allowing the trade of aquaculture clams, we are supporting the livelihoods of our people but also contributing to the conservation of the species in the wild. We are committed to sustainable practices and stand ready to work with international partners to ensure that our clam farming operations continue to benefit both our community and the environment.

Thank you for your attention to this critical issue.

Nicholas de Brum
Mayor of Likiep Atoll

October 2. 2024

Mr. John Rippe

Office of Protected Resources, NMFS

1315 East-West Highway, Silver Spring, MD 20910

RE: Comments on the 90-Day Finding Regarding the Petition to List 10 Species of Giant Clams as Threatened or Endangered under the Endangered Species Act. NOAA-NMFS-2017-0029

Dear Mr. Rippe,

On behalf of Marshall Islands Conservation Society (MICS), a conservation organization dedicated to supporting sustainable livelihoods and marine biodiversity conservation in the Marshall Islands, I am writing in regards to the petition to list 10 species of giant clams under the U.S. Endangered Species Act (ESA) and to express our concerns about the potential socioeconomic and environmental impacts that such a listing could have on local communities and ongoing conservation efforts in the Marshall Islands.

For several years, MICS has partnered with communities across the Marshall Islands to establish sustainable giant clam aquaculture programs. These programs serve a dual purpose: they provide essential income for rural communities through the export of aqua-cultured giant clams to the marine aquarium trade, and they also contribute to local conservation and food security by enabling the restocking of lagoon ecosystems with healthy giant clam populations. The farmers involved in these projects are deeply invested in both the economic and ecological outcomes, as giant clams are a critical component of their livelihood and cultural heritage.

We are particularly concerned that the proposed ESA listing could jeopardize these successful programs. The listing may restrict access to key markets, reducing the economic incentives for communities to continue these environmentally responsible aquaculture practices. This would not only impact the livelihoods of many island families but could also weaken local conservation efforts, as community-driven restocking initiatives rely on the continued operation of hatcheries.

Moreover, the existing regulatory framework in the Marshall Islands, which mandates the exclusive use of aqua-cultured giant clams for export, ensures that wild populations are protected from exploitation. The closure of hatcheries, as feared under the ESA listing, would eliminate a critical resource for restocking efforts, potentially undermining ongoing efforts to replenish and restore wild giant clam populations in local lagoons.

We urge you to consider the unique circumstances of the Marshall Islands and the robust sustainable aquaculture programs that contribute to both economic development and biodiversity conservation. An ESA listing for these species would disproportionately impact vulnerable communities that depend on the sustainable use of their marine resources while potentially hindering important conservation work that aligns with the goals of the ESA.

Thank you for considering our views, and we hope that you will take into account the significant conservation and livelihood benefits these programs offer as you evaluate the proposed listing.

Sincerely,

Dolores Kattil-deBrum
Executive Director

Mr. John Rippe

Office of Protected Resources

National Marine Fisheries Service

1315 East-West Highway

Silver Spring MD 20910

Re: Proposed Listing Determinations for Ten Species of Giant Clams under the Endangered Species Act (NOAA-NMFS-2017-0029)

Dear Mr. Rippe:

Thank you for providing a briefing on the proposed listing determination for ten species of giant clams under the Endangered Species Act (ESA) at the 200" meeting of the Western Pacific Regional Fishery Management Council (Council) held September 23-25, 2024. The Council requests NMES to extend the public comment period to allow more time for NMES to conduct outreach with affected communities and for community members to provide informed comments in response to the proposed rule. The Council additionally requests NMFS to provide written translations of the proposed rule documents in Samoan.

The Council is concerned that the proposed listing determination is based on sparse data

species under the ESA will have disproportionate impacts on American Samoa, Guam and CNMI, where these species have cultural significance associated with long-standing traditions, and there are ongoing or developing aquaculture programs.

The listening sessions and public hearings held in American Samoa, Guam and CNMI in September 2024 provided an initial introduction of the proposed rule and potential impacts to the affected communities. However, additional outreach and engagement as well as an extension of the public comment period is needed for the communities and local governmental agencies to provide comments and information relevant to the proposed listing determination as well as the proposed 4(d) take prohibitions associated with the species under consideration to be listed as threatened. The Council urges NMFS to utilize the additional time during the extended comment period to work with the governments of American Samoa, Guam and CNMI to review the information underlying the proposed rule and associated socioeconomic and cultural impacts.

Thank you for considering the Council's requests. Please contact the Council's protected species coordinator Asuka Ishizaki (asuka.ishizaki@wpcouncil.org) if you would like to discuss.