Comment by J. Harvey on 0648-AW32

RIN 0648?AW32 Comment Regarding the Proposed Endangered Status for Black Abalone While it is clear that the population of the black abalone is declining at an alarming rate, it seems that protection as an endangered species can provide little protection from the forces causing this decline. No doubt, the current population of the species could be much higher had commercial fishing been curbed at an earlier time,but one would think that the cessation of such harvesting in California as early as 1993 would yield greater numbers than are observed today. Despite the California coastline comprising such a large portion of the abalone's habitat, the numbers have not grown since the close of black abalone fishing. The abalone's decline since this time has been largely, and correctly, attributed to the abalone withering disease. It has been noted that beyond the listing of the abalone as an endangered species, procedures to create a protected habitat have begun. However, given that the species current decline can be attributed to the disease, I fail to see how habitat protection or protection from harvesting could provide benefit to the black abalone. Rather than focusing on hollow promises of protection and redundant restrictions, should there not be a more rigorous investigation into possible ways to mitigate the harms of the wasting disease? Studies suggest that rising water temperatures or any number of other factors may contribute to the spread of the disease. Accepting these studies as true, I feel that the so called protection being afforded the species could not possibly yield any real world results in terms of conservation without some form of parallel program seeking a solution to the spread of the withering disease. Otherwise, what protection is being provided beyond a convenient habitat in which the species may become extinct? While protection as an endangered species is no doubt warranted in this case, and while the future establishment of a protected habitat for the black abalone is an important step toward ensuring the survival of the species, these steps alone will not meet the goals for which they are created. It is imperative that this is but the beginning of a multi-step process in reviving the black abalone population, and not constitute the culmination of efforts to protect the species. Otherwise, the current proposed rule sits as little more than a band-aid on an ever growing problem.