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Environmental Groups Call Aquarium Industry Assessment “Flawed”

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Hawai‘i’s aquarium trade, represented by the continent-based Pet Industry Joint Advisory Council, has released a Draft Environmental Impact Statement defending the collection of reef wildlife for aquarium purposes in West Hawai‘i.

The environmental law firm Earthjustice and the Pono Advocacy group are calling the DEIS “inadequate”  and “flawed,” alleging the document it attempts to brig the aquarium trade into compliance with the Hawai‘i Environmental Policy Act:

  • after the Hawai‘i Supreme Court in 2017 held that collection without environmental review violates the Act, and
  • DLNR was later ordered to cease issuing further aquarium collection permits until the environmental effects of aquarium collection have been fully and publicly vetted through the HEPA process.

Aquarium fish. File photo.

An Environmental Assessment issued in 2018 was rejected by the state Department of Land and Natural Resources.

According to the DEIS, “There would be no construction of permanent or semi- permanent infrastructure, no discharges into coastal, surface or ground waters, no dredging, and no significant use of hazardous materials that could be released into the environment.”

But environmental groups disagree.  “DLNR can’t ignore the 800-pound gorilla that, except for bag limits for a limited number of species, nothing prohibits these collectors from taking every single fish from every singe reef in the state,” said Earthjustice attorney Kylie Wager Cruz. “It’s common sense that this level of unrestricted take can’t be sustainable.”


“The DEIS is based on the false premise that aquarium collecting doesn’t impact fish populations on the reefs where the trade operates,” said Inga Gibson, policy director of Pono Advocacy. “Nothing could be further from the truth. This false premise lays the foundation for this extremely flawed study, and prevents DLNR from ultimately accepting the DEIS.”

DLNR has reported that aquarium collectors take the majority of Achilles tangs and yellow tangs on the reefs where they operate, amounting to more than 80% in some years.

The groups claim the data is skewed in the DEIS because it compares catch numbers to estimates for fish populations on the entire island.

“For years, DLNR has allowed the trade to pillage Hawai‘i’s treasured coral reef wildlife, in violation of HEPA. Since the Hawai‘i Supreme Court’s ruling, DLNR has been ignoring the fact that the industry has continued to collect reef animals for aquarium purposes capturing more than a half million animals in the past two years,” said Mike Nakachi of Moana ‘Ohana. “If DLNR accepts this shell of an EIS, it would be yet another dereliction of the agency’s responsibility to protect our ocean resources, for the benefit of all of Hawai‘i’s citizens.”


“For decades, the aquarium trade took 1.8 times more fish than did all types of food fishers, combined. The trade now proposes to reinstate that same program for 14 collectors who were responsible for more than 78% of that take—and that was when they were capturing these fish an average of three days per week. Imagine how much more they could take in six or seven days per week,” said Rene Umberger of For the Fishes. “With one exception (limits on Achilles tang) nothing in the proposal limits the total number of fish the trade can take, and nothing prevents the trade from taking every last fish on any and every reef they operate on in West Hawai‘i.”

According to information compiled and distributed by Earthjustice, the DEIS “fails to identify the 14 applicants who are requesting exclusive access to areas and reef wildlife that would be denied to all others. It also lacks any information about their wildlife resource violation histories, the collection gear they use, or the mortality rates for the wildlife they ship out of state.”

“Hawai‘i needs its reef fish now more than ever before,” said Maxx Phillips, Hawai‘i director with the Center for Biological Diversity. “Hawai‘i is expected to lose 70 percent of our coral reefs in the next couple of decades, so we don’t have time for aquarium industry-sponsored justifications for raiding the reefs. Our reefs depend upon the restoration of that balance and the return to natural abundance.”

Since aquarium collection ceased in West Hawai‘i in 2018, pursuant to court orders, there has been a surge in fish abundance, according to the environmental advocacy groups. “During the first year, yellow tangs increased by nearly 50% in the areas where the trade had previously operated. Despite that increase, their populations in those hard-hit areas are still 60% lower than those found in long-term protected areas, indicating an ongoing and severe impact by the trade,” according to the environmental groups.


The 45-day public comment period for the DEIS closes on Jan. 7, 2019.

Read the DEIS online.

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