31 October 2012

To Whom It May Concern:

I am most grateful for the opportunity to comment on the request made by the Georgia Aquarium and its partners for permission from the National Marine Fisheries Service to import 18 wild caught beluga whales from Russia. The reasons given by the group of aquariums for wanting to import these whales are (a) that they are needed to assist efforts to conserve beluga whales in the wild, (b) to educate the public, and (c) to introduce new genetic material into the captive population. But these arguments are not convincing. It is not clear how the capture and exhibition of the 18 whales would help beluga conservation in the wild. Watching whales that, in nature, roam for miles through the ocean, swim round and round behind glass does not seem to me to be a good way to educate the public: this can be achieved by footage of whales in the wild and information about their behavior and the threats which face them. Belugas apparently do not thrive well in captivity. None have lived to the maximum age (60 years) that can be attained by those in the wild. And they do not breed well the number of individuals in captivity in America has declined over the past decade despite intensive efforts to create a sustainable captive population. Rather than attempting to achieve more successful breeding in captivity, it would seem better to admit that belugas and other whales are not suitable animals for aquarium life. Quite apart from what seem to be inadequate reasons given by the Georgia aquarium and its partners for wishing to import these whales into the US, there is a strong reason for rejecting such a request on ethical grounds. Whales are long lived, large brained mammals. More and more studies have demonstrated that they live in complex societies in which individuals form close social bonds. And everywhere respected scientists are providing evidence that animals with complex brains and nervous systems are capable of intelligent behavior and experience pain and emotions similar to our own including fear, depression, and anxiety. For an animal that has lived free in the ocean, spending all its life in the water, a long journey in a plane will be very stressful and very frightening. For these unfortunate 18, the journey will be especially stressful. I understand that American cargo planes are not allowed to land in Russia. The whales will first be loaded onto a Russian cargo plane

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which has a level of noise emission that does not comply with American regulations and will not be allowed to land in the US. Thus the Russian plane will have to land in Belgium where the whales will be transferred into new containers and loaded onto an American plane. It might be mentioned that for animals with such sensitive hearing, the noise emissions of the Russian plane may well be even more distressing than to the average human and we can use ear plugs in such situations. Wild whales and dolphins have not been deliberately captured for importation into the US for over 20 years. If permits are granted for these 18 it could be a precedent that leads to a new phase of commercial trading of wild beluga whales and other cetaceans. I would urge the National Marine Fisheries Service to consider the plight of some 40 beluga whales currently living in deplorable conditions in Marineland in Ontario, Canada. These individuals, some captured from the same population in Russia as the 18, are desperately in need of finding new homes. Moving these animals to reputable aquariums in America would thus be a humane operation far less costly than transporting such large animals from Russia. I would urge the Georgia Aquarium and its partners to take this alternative route. Finally, I do not support capturing free-ranging whales or dolphins for public display. In this day and age, there is no excuse for putting these magnificent marine mammals through the trauma of capture to supply zoological facilities with animals for display. Thank you for the opportunity to express my views on this issue. Sincerely,

Jane Goodall, PhD, DBE Founder the Jane Goodall Institute & UN Messenger of Peace www.janegoodall.org

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