Comment from Defend Them All and the Center for Biological Diversity
Defend Them All and the Center for Biological DiversitySupportAdvocacy
Summary: Defend Them All and the Center for Biological Diversity support the proposed threatened listings for two Tope Shark population segments but argue that the proposal is insufficient for the remaining four segments. They urge the NMFS to list the Northeast Pacific DPS as threatened or endangered and to adopt stronger protective regulations, including a similarity-of-appearance rule for lookalike species.
Please see attached file: Defend Them All and the Center for Biological Diversity support NMFS’s proposed threatened listings for the Southern Africa and Southwest Atlantic DPSs of the Tope Shark, but urge NMFS to strengthen the final rule. The attached comment explains why NMFS should reconsider its not-warranted findings for the Northeast Pacific, Southeast Pacific, Northeast Atlantic, and Southwest Pacific DPSs; address DPS-level risks, cumulative threats, data gaps, and regulatory inadequacies; and adopt protective regulations under ESA sections 4(d) and 4(e).
In particular, the comment asks NMFS to list the Northeast Pacific DPS as threatened or endangered, conduct a legally adequate significant-portion-of-its-range analysis for southern California, Baja California, and adjacent waters, reconsider the Southeast Pacific DPS in light of substantial uncertainty, evaluate recent trade and product-identification evidence, issue protective 4(d) regulations for threatened DPSs, and adopt a similarity-of-appearance rule for relevant lookalike species and product categories.