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October 27th, 2012P. Michael PayneChief of Permits, Conservation DivisionOffice of Protected Resources National Marine Fisheries Service1315 East West HighwaySilver Spring, MD 20910 
RE: NOAA-NMFS-2012-0158 and File No. 17324 - the Georgia Aquarium’s request toimport 18 Beluga Whales from Russia
Dear Mr. Payne,My name is Samantha Berg. I am the owner of Alaska Center for Acupuncture in Palmer, AK,although I am writing to you and NOAA primarily as a former SeaWorld trainer. I worked as ananimal trainer at SeaWorld of Orlando from February of 1990 to August of 1993. During thattime I worked with 4 beluga whales - Spooky, Shadow, AJ and Bandit.A few weeks ago I travelled from Alaska specifically for the hearing in Silver Spring, MDbecause I felt that it was important for you to hear from a former trainer about what actually goeson behind-the-scenes at places like SeaWorld. I was one of the 15 people who spoke requestingNOAA to deny the permit, and I want to tell you more about why I believe that denying thispermit is the right choice.Many people spoke very eloquently at the hearing about why this permit should be denied. Iheard Dr. Lori Marino speak about the LACK of education at Aquariums and Marine Parks, and Ialso heard Dr. Naomi Rose of the Humane Society International address the technicalspecifications of the permit and why the capture and import of these animals clearly violates theMMPA. At the hearing, a statement signed by over 60 NGO’s from Courtney Vail of Whale andDolphin Conservation was presented to NOAA. All told, a total of 15 people includingeducators, researchers, animal advocates, homemakers,
 
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TV producer,
 
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pilot, lawyers, andsocial workers, and myself, a former SeaWorld Trainer, spoke against the import request.Other key points that were covered by this group of 15 people during the hearing were thefollowing:
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Brutally removing the belugas from the wild and transporting them thousands of milesinto the US for public display is unnecessary, inhumane and threatens wild belugapopulations. It has nothing to do with conservation.
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If approved, the import will contribute to the unsustainable and cruel international tradein belugas.
 
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Conservation means protecting species in the wild, not capturing them for captivity.Beluga populations in Russia have been decimated by over-hunting, and the samepopulations are also targeted for capture, preventing their recovery.
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The whales were caught first and held in pens before any application to import them wasmade. By capturing the belugas first, and then asking for permission later, the GeorgiaAquarium has unfairly prejudiced the permitting application and process.
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The Georgia Aquarium’s permit application does not meet regulatory requirements andmust be denied.In addition, I was surprised that there was very little evidence presented by the pro-permit sidethat addressed the specifics of the permit directly. Mostly the people speaking in support of thepermit appeared to be approaching the hearing as though it was a referendum on captivity itself,which it was not. Considering that these 18 beluga whales are also going to the SeaWorld Parks,the Shedd Aquarium and the Mystic Aquarium, I was also surprised that no one from any of these organizations/companies chose to speak at the hearing either.One of the presentations that I found incredibly compelling was from Bill Rossiter, President of the Cetacean Society International and former commercial pilot. Mr. Rossiter’s testimony aboutthe amount of time that the beluga transfer will actually take, including the logistics involved inthe transfer, was eye-opening. His estimate that transporting the belugas from Russia to the USwill take upwards of 40 hours if everything goes right (there is apparently no contingency plan incase there are problems), is a much longer estimate than the 26-30 hours which was provided onthe permit submitted by the Georgia Aquarium. In addition, the transfers in Liege, Belgium willnot only involve moving belugas from one airplane to another, but the belugas will also have tobe removed from their transport boxes via cranes and moved into other boxes due the fact thatthe boxes are not cross compatible between airplane types.Considering the multiple destinations of the animals, it’s likely that some animals could be intransit for more than 50 hours. This is clearly inhumane and definitely a violation of theregulatory requirements that
the transport will “not present any unnecessary risks to the healthand welfare” of the animals.From my experience working with belugas, it’s clear they are exceptionally sensitive to smallchanges in their environment. Subjecting them to the loud noises of the Russian planes, themultiple transfers, and ultimately a complete reorganizing of their social structure for aSECOND TIME (the first time having happened when they were captured), is highly cruel andunethical. The fact is inescapable that the transport process presents a pathological degree of stress, again, violating the regulatory requirements.A few other key points I would like to leave you with:
 
As a SeaWorld trainer I was not only responsible for training the animals and performing inshows, but I was also responsible for husbandry of these animals - which included monitoringtheir respirations and observing them for changes in their overall health and wellbeing. I wasalso responsible for educating the public about the beluga whales. We were all instructed toinform the public that extensive research was being done in the name of conservation - that isthat the animals in our care were supposedly contributing something to our knowledge base thatwould help us do a better job of protecting and conserving wild populations.Let me address these issues individually:While I was at SeaWorld, in 3 1/2 years I saw only one research project, and that was onhydrodynamics. The scientist’s goal was to determine the forces that affected the whales anddolphins as water passed by or was moved by their bodies, dorsal fins, flukes and pectoralflippers. I fail to see how this study contributed to conservation. Other than this, the onlyother data that I observed being collected was not in any way connected to wild populations butwas simply focused on how to keep the animals alive in captivity for shows - which, tragically, isa very difficult thing to do.Although the captivity industry extolls the benefits of their superior veterinary and dental care,the evidence is that cetaceans in captivity , except for a few extraordinary individuals, rarelymake it to half of their projected lifespan. In fact, the animals I mentioned at the beginning of this letter, Spooky, Shadow, AJ and Bandit are all dead now, as are Spooky’s only calf (stillborn)and Bandit’s only calf (lived 4 years).Additionally, what I actually witnessed in terms of veterinary and dental care was basically“frontier medicine” and from those currently in the industry, I understand this hasn’t changednearly 20 years later. Due to the limited nutritional content of their diet of frozen fish - in manycases not even the type of fish that the animals would be eating in the wild - animals wereconstantly getting sick. Many of the animals were given fish stuffed with antibiotics, antacidsand anti-fungals, in addition to synthetic vitamins. The fact that the veterinarians felt compelledto keep these animals on these medications long-term tells me that they are unable to address thesource of the actual illnesses - which is stress due to the effects of captivity including artificialenvironments, poor nutrition and limited social interaction.As far as education goes, I can tell you that I know more today about whales and dolphins than Iever knew as a SeaWorld trainer. A person could learn more about beluga whales in five minuteson Wikipedia than they would learn in a day long visit to SeaWorld. So, I have to question howit was possible for me to educate the public based on the limited and erroneous information provided to me by SeaWorld. Basically, I taught surface anatomy, talked about husbandry behaviors and answered simple questions about how much the animals were eating or how bigthe pools were. Real information about longevity, wild behavior, and natural habitat was never communicated to the public. SeaWorld trainers were expected to tell the public that the“behaviors” (tricks!) they were seeing were an accurate representation or at least extensions of 
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