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Comments on Draft: Programmatic Environmental Impact Statement for Coral Restoration

Dear Alice Stratton,

I wish to correct serious inaccuracies in the draft statement on page 17, namely the section below:

The method described was invented by the late Prof. Wolf Hilbertz, and developed and patented by him and myself over the last 20 years. The citations given are mostly to unauthorized work that copied ours, but which made serious errors of design, materials, and operating conditions. They did not get the results that we, and those who we train to use the method properly, routinely get in the field in nearly 30 countries in the Caribbean as well as the Pacific, the Indian Ocean, and South East Asia. We typically get growth increases of electrified corals 2-6 times faster than uncharged controls, based on 7 independent studies, but these depend on the species and the operating conditions. Most of this work is in Indonesian, and we have not had time to prepare a summary in English. In contrast, our imitators have had much inferior results, and in fact some of those you cite published a "peer" "reviewed" paper in which it was claimed that they could only get corals to grow when the power was off!

But there is an even more important aspect of our work to restoration following physical damage than enhanced growth rates, namely the almost immediate healing of physical damage to tissue that our electrical method promotes.

One of our students in Indonesia, transplanted 32 freshly broken Acropora formosa tips from a single large clone onto Electrified structures and 32 onto control uncharged structures. The electric corals grew 4.01 times faster than the controls. But more important, while the controls released mucus for two weeks after transplantation, which is typical for physical damage, THE ELECTRIC CORALS RELEASED NO VISIBLE MUCUS AND COULD BE SEEN BY EYE TO BE OVERGROWING THE SUBSTRATE WITHIN HALF A DAY. The exceptionally rapid wound healing caused by the direct current electrical field is similar to that long known in vertebrates.

We routinely use this method in rescuing naturally broken coral fragments for transplantation. Most of the natural fragments we use were long ago damaged by anchors, divers,, waves, or fishing gear, and when we get them many have been severely injured by rolling around on rock or sand, often with much of the tissue dead or necrotic. But when we put them onto electric nurseries the damaged areas heal very rapidly, and the polyps quickly extend and start feeding. The photos below taken by Leong Sze Wong at one of our projects in Indonesia show broken corals that have had only one day of electrical recuperation and were simply placed on a temporary charged substrate without being attached, as this was simply a temporary measure to restore them until they could be transplanted onto a permanent electrified structure. Their vivid colors and healthy polyp expansion of both hard and soft coral fragments are a dramatic difference from how they were when we collected them a day or two before.

In conclusion, the Biorock reef rehabilitation method is the best practice for rescuing corals from physical damage, but it requires prompt intervention for the best results. Whenever NOAA is serious about using the best methods to rescue damaged corals, we will be happy to show them how use our method properly. There are so few corals left in the Keys that it is remiss not to use the best methods for rescuing those that have been smashed by careless divers, pleasure boaters, commercial shipping, or University of Miami research vessels.

Best wishes,

Tom

Thomas J. Goreau, PhD

President

Global Coral Reef Alliance