Comment from Dave Raney

SIERRA CLUB COMMENTS IN SUPPORT OF PETITION TO REVISE CRITICAL HABITAT DESIGNATION FOR ACROPORA CORAL SPECIES Attention: Jennifer Moore These comments are submitted on behalf of the Sierra Club by the Coral Reef Working Group of the Marine Action Team, with the concurrence of the Sierra Club Florida and the Sierra Club Loxahatchee Group. We have reviewed the Petition to Revise Critical Habitat Designation for Acropora Coral Species submitted by Palm Beach County Reef Rescue, and support the Petitioner’s request that the northern boundary of the Florida area of critical habitat for elkhorn and staghorn corals be extended to the Lake Worth inlet, approximately 15.5 miles north of the current boundary at Boynton Beach Inlet. As noted in the petition, after receiving public comments the National Marine Fisheries Service eliminated the area in question in the designation of critical habitat for the two Acropora species, with the finding (Comment 17 of Federal Register, 50 CFR parts 223 and 226) that “We have no knowledge of either species of Acropora historically or presently occurring north of this boundary.” The Petitioner has submitted evidence which we find convincing that (a) during the critical habitat review period the Petitioner had submitted documentation of the presence, both present and historical, of Acropora cervicornis populations north of the Boynton Beach Inlet, and (b) on December 20, 2008, subsequently verified the accuracy of the information previously submitted. Thus, it appears that NMFS did not take into consideration all the available scientific data obtained during the critical habitat review period, and established the northern boundary for Area 1 (Florida) critical habitat based on incomplete information. This petition provides the opportunity, and duty, for NMFS to revise the northern boundary based on more complete information. The Sierra Club is aware that coral reefs worldwide face stresses from global warming and ocean acidification, in addition to local stresses from coastal development and other human activities. We have placed high priority on promoting local, national, and international efforts to reduce greenhouse gas emissions, and these efforts directly address a major threat to the survival of coral reefs. We know, however, that it is also necessary to act at local levels so as to provide coral reef ecosystems with conditions favorable for their future survival. This petition is one such local action, and it is of more than local significance. The survival of staghorn and elkhorn corals is very important not only to our members in Palm Beach County and the State of Florida, but also to our members elsewhere, and to future generations. We strongly urge you to act favorably on this petition. Thank you for the opportunity to submit our comments. Drew Martin Frank Jackalone Dave Raney Conservation Chair Sierra Club Loxahatchee Group Senior Field Organizing Manager on behalf of the Sierra Club Florida Steering Committee Chair Sierra Club Coral Reef Working Group; Marine Action Team