Hawai‘i’s Dept. of Land and Natural Resources (DLNR) is accepting comments on two Draft Environmental Assessments (EAs) crafted by the aquarium trade in response to the September 2017 Hawai‘i Supreme Court ruling that determined aquarium collecting activities are subject to Hawai‘i’s environmental laws.

Each of these EAs – one for Oahu and one for Hawai‘i Island – inconceivably propose findings of no significant impacts, with DLNR approval. This, despite years of reports and papers, published by DLNR and staff, documenting the devastation caused by the aquarium trade and labeling it a major cause of coral reef degradation in Hawai‘i.

Your comments – describing the lost abundance, missing species, diminished beauty, you’ve experienced or are concerned about, and demanding a full assessment of the trade’s environmental, cultural and ethical impacts – are urgently needed. TAKE ACTION NOW.

Citing environmental, cultural and ethical concerns, 90% of Hawai‘i residents want more restrictions on the trade and a full 83% want it banned altogether. Visitors to Hawai‘i and marine life lovers around the world express concerns over the current state of Hawaii’s reefs. Yet these assessments conclude there are no significant impacts and propose no limits on permits, species, or levels of take.

The aquarium trade wants nothing more than to keep intact Hawai‘i’s position as the world’s third largest supplier of wild marine life for U.S. household aquariums, with several times more fish taken from our reefs than from Australia’s Great Barrier Reef, the largest coral reef on the planet.


Lastly, the flawed process that led to these empty assessments is noteworthy. The EAs were prepared by Stantec, a company with long history of ignoring environmental risks and disrespecting native voices. Most notably, its development and design of the controversial Keystone Pipeline generated over 2 million comments in opposition to the project. Since completion, the pipeline’s flawed design and execution has resulted in 12 oil spills, the most recent of which was in November 2017 when hundreds of thousands of gallons leaked in South Dakota.

Stantec was hired to complete the aquarium trade environmental assessments by the Pet Industry Joint Advisory Council (PIJAC), the lobbying arm of the pet industry, located in Washington D.C. PIJAC’s board and executive committee members include owners and representatives from the world’s largest sellers of marine life for the aquarium hobby.

Major flaws in the drafting of the Hawai‘i aquarium trade environmental assessments include:

An accurate assessment of aquarium trade impacts cannot be completed in just a few short months.

  1. DLNR recently estimated the cost and time required to complete fish stock assessments and catch limits for just 40 aquarium species at $10 million per year over 10 to 15 years.
  2. The aquarium trade has access to nearly all of Hawai‘i’s estimated 475 square miles of nearshore coral reefs, where they are permitted to capture unlimited numbers of more than 250 marine species.

Cumulative impacts have been ignored.

  1. As a result of the Hawai‘i Supreme Court decision in Umberger v. DLNR, all aquarium permits have been deemed illegal and invalid (i.e. DLNR has been illegally issuing aquarium permits since 1974, the year Hawai‘i’s environmental law was enacted).
  2. Oahu’s aquarium fishery began collapsing in the 1980’s, but the assessments inexplicably use the year 2000 as an arbitrary baseline for measuring impacts, years after the fish populations collapsed.
  3. The population differences between the areas closed and open to the aquarium trade clearly show the trade’s impact: millions of yellow tangs, butterflyfishes, wrasses and other fishes targeted by the trade are missing from Hawai‘i reefs.
  4. The assessments propose a short, 12-month, time frame for assessing current cumulative impacts, without factoring the life histories of the species taken by the trade, or climate change which is expected to create potentially catastrophic bleaching conditions on an annual basis by mid-century.

Early consultation with conservation, native Hawaiian, and other citizen groups, landowners near coral reefs, and individuals affected by aquarium collecting is mandated by law.

  1. None of these groups or individuals, including the plaintiffs in the lawsuit that led to the court victory mandating this environmental review, were consulted.

Read more:  Conservationists Criticize Aquarium Industry’s Flawed Analysis of Unlimited Collection of Hawai‘i Reef Fish
Review the Draft Environmental Assessment for Oahu
Review the Draft Environmental Assessment for Hawaii Island