Comment from David Obura

Submitted on behalf of the IUCN-SSC Coral Specialist Group The petition is based on the current IUCN Red List, with the following status for the 83 species: vulnerable (76 species), endangered (six species: Acropora rudis, Anacropora spinosa, Montipora dilatata, Montastraea annularis, M. faveolata, Millepora tuberosa), or critically endangered (one species: Porites pukoensis). It is not stated in the document which of these species have been proposed for endangered or vulnerable status under the US ESA, or how these categories map onto the IUCN Red List categories. The purpose of listing them under the US ESA is to strengthen management and regulation within the US. It is not completely clear from the text of the document if this is a full listing of ALL scleractinian corals listed in the IUCN Red List which are found in US territorial waters. Taxonomic identification – this is notoriously difficult for corals due to both genetic complexiy and high phenotypic plasticity, and particularly when taken out of their natural environment, in small fragments or just in tissue form, as may often be the case when applying this legislation. Many taxa that are vulnerable are limited-distribution species known by very few experts, making problems of their identification even more complex. For example, one listed species, Acropora rudis, is found mainly in the Indian Ocean, but is also noted from American Samoa, a highly disjunct distribution. Whether this is a true record or not will not be fully accepted until genetic work has been done in combination with revised taxonomy of A. rudis itself and of sibling species. Text in the petition noting the problem of species identification, and establishing genetic barcoding to support identification will be essential to strengthen implementation and applicability of any legislation.