NGO Statement Against Proposed Beluga Imports by the Georgia Aquarium We, the undersigned, representing tens of millions

of supporters worldwide, stand firmly opposed to the proposed import of 18 wild-captured beluga whales into the United States by the Georgia Aquarium and other US public display facilities. We find the actions of the Georgia Aquarium and its partner facilities in sourcing these animals directly from the wild to be regressive and contrary to progressive trends in the maintenance of marine mammals in zoos and aquaria. US public display facilities have not imported or taken cetaceans directly from the wild for public display since 1993, mainly because of public opposition to this practice; to do so now is a violation of the public trust. Russian beluga populations are still recovering from extensive hunting pressures and the localized, targeted, and repeated captures for public display from these same populations is unacceptable. Under US permitting regulations, any proposed activity that results in unnecessary risk to the health and welfare of marine mammals is a violation of the Marine Mammal Protection Act. We maintain that this import is both unnecessary and poses substantial risk to the health and welfare of both the 18 belugas to be imported and the groups from which they were taken in 2006, 2010, and 2011. Substantial risk to health and welfare These beluga captures are inhumane and lack transparency Captures are violent, and may cause distress, physical harm, and even death not only to those animals captured, but for the ones left behind. Beluga whales have died during capture and transport in Russian operations. The number of animals injured, accidentally killed, or whose health has been compromised as a result of capture operations remains unknown. No proof of capture methods and associated mortality or injury has been provided beyond a handful of photographs and a written statement by the Georgia Aquarium attesting to the safe methods utilized during capture activities. The proposed transport will be exceptionally stressful Russian transport planes will carry the whales to Belgium where each whale will undergo a transfer to a new shipment container and a new airplane before flying to the United States. To our knowledge, this type of transport has not been undertaken by the public display industry before, where cetaceans will actually be lifted out of one carrier and placed into another directly on the tarmac at an airport. If the personnel involved in this transport have participated in such a transfer/transport before, the Georgia Aquarium must describe in detail when and where it occurred and its outcome. Transport is extremely stressful for any cetacean, but this transport will subject the whales to considerable additional stress. Furthermore, they will be transferred again by plane and truck once they land in Chicago and Atlanta and are sent on to their destination facilities, including the John G. Shedd Aquarium and the three SeaWorld facilities in Orlando, Texas and California. It is unacceptable that the Georgia Aquarium has provided no contingency or emergency plans for these complicated transfers.

Under the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES), the Management Authority of the State of export must be satisfied that any living specimen will be so prepared and shipped as to minimize the risk of injury, damage to health or cruel treatment. Currently the Live Animals Guidelines of the International Air Transport Association (IATA) are deemed to meet the CITES Guidelines. IATAs Live Animals Regulations specify minimum requirements for air transport and state that large marine mammal species such as porpoises, dolphins and whales require special attention and must be accompanied by experienced handlers who understand the needs of these creatures. These guidelines describe the extreme dependence of these species on their environment and their lack of adaptability to sudden change, requesting that care must be taken that they are not subjected to sudden fluctuations. The IATA regulations also note that it is important that these animals are not subjected to noise as far as is possible and that they must be held in cool and quiet areas pending loading. The existence and detail of such requirements result from our understanding of the sensitivity of these animals to transport. Such transport of captive marine mammals should take place only in cases where urgently needed improvements are required in an animals living conditions and in the best interests of its health and welfare. We do not believe this transport meets any of these necessity requirements. Additionally, research has shown that dolphins take as long to acclimate when transported between captive facilities as they do when first transferred from the wild. During the acclimation period, stress-induced illness and even premature death can occur for susceptible animals. Data analysis identifies a 60-day acclimation period as a distinct interval of high mortality risk, thereby supporting our concerns about the long distances associated with this transport from the wild and between facilities. Conservation Concerns This proposal undermines protection of belugas in the wild The Georgia Aquarium is seeking to import beluga whales captured in 2006, 2010, and 2011 from the Sea of Okhotsk, Russia. Belugas in this area were subject to intensive hunting until the early 1960s and the population is still recovering. Quotas were issued in 2012 for up to 150 belugas to be taken by hunting and live captures in the same region where these 18 belugas were captured. The rationale for the import request is that the captive beluga collection is an important contribution to marine conservation and public education and is necessary to maintain the captive breeding population in US facilities However, such captures are actually undermining protection efforts for this population of belugas. According to the IUCN Cetacean Specialist Group, the removal of live cetaceans from the wild, for captive display and/or research, is equivalent to incidental or deliberate killing, as the animals are no longer available to help maintain their natural populations. Russia sets capture and hunting quotas at well over a thousand belugas annually in all of its waters, despite the profound

lack of information on the status of most populations. In 1999, the Deputy Chairman of the Government of the Russian Federation acknowledged that the beluga quota was based on unreliable population estimates and prohibited capture and export of belugas that year. The live capture of beluga whales for the public display industry is currently carried out solely in Russian waters. The status of the species is cause for concern; the Scientific Committee of the International Whaling Commission (IWC) concluded in 1999 that only four out of 29 beluga populations are stable. No new information has been produced to change this conclusion. Belugas are threatened across their Arctic range by climate change and its related impacts, oil and gas development, over-hunting, over-fishing, vessel traffic, and pollution. Over-hunting all but wiped out an entire sub-population of Sea of Okhotsk belugas in the 1930s and little is known about the meta-population other than that it is still believed to be recovering. Although preliminary population estimates have been conducted for the Sakhalin-Amur population, the assessments do not adequately consider repeated targeted removals from distinct matrilines and summer feeding aggregations, which may result in the disruption of social groups and the loss of important gene complexes, cultural traits, and ecological knowledge. In addition, half of the 18 belugas are reported to have been less than three years old when captured (with several listed as 1.5 years), suggesting they were not independent of their mothers, despite the permit applications assurances that mothers with calves were not targeted. This import will promote potentially unsustainable international trade in beluga whales Reports are not available on the number and source of live beluga whales captured in Russian waters. However, between 1990 and 2010, the World Conservation Monitoring Centre records the export of at least 263 live belugas from the Russian Federation. The undersigned organizations are very concerned about the increasing international trade in beluga whales, involving several new countries importing them for public display, including Turkey, Iran, Egypt and China. We are concerned that any international trade in these animals, including the proposed import of belugas by the Georgia Aquarium, will increase demand by the public display industry, with a resultant impact on wild populations targeted by live capture operations. We remain concerned about the holding conditions of beluga whales currently held captive, or destined for future display, around the world. These social animals are supremely adapted to group life in near freezing conditions. Despite the compelling scientific and moral arguments against their captivity, a strong market for belugas still exists, increasingly met by dealers in Russia who have even offered them for sale on the Internet. The United States should not participate in this trade but should instead be working to stem it; the Georgia Aquarium is acting as part of the problem in this instance rather than part of the solution. Unnecessary risk to wild belugas There are at least 40 belugas in Marineland of Canada that are currently suffering in inadequate conditions and could be imported instead of taking more from the wild. According to US regulations, the Georgia Aquariums import request poses an unnecessary risk to the health and welfare of wild belugas, through unjustified captures and a transport plan that will cause

exceptional stress for logistical and/or political, rather than biological or veterinary, reasons, when 40 already-captive animals may soon need rescue and relocation. At least 45 cetaceans are known to have died at Marineland of Canada since 1964, including 13 orcas, seven belugas and 26 bottlenose dolphins. As there is no requirement in Canada to record the deaths of marine mammals in its public display facilities, mortality may be much higher. There are no approved standards for public display facilities in Canada and concerns have been raised over the years about the general welfare of animals held at Marineland of Canada. Most recently, media exposs have revealed the inadequate conditions at Marineland. It would be negligent for US facilities to source additional belugas from the wild in Russia when a surplus of belugas much closer geographically is in need of assistance. Conclusion The demand for wild-caught belugas is increasing. The United States was one of the first countries in the world to display captive cetaceans and now has one of the largest public display industries in the world. US aquaria must assume responsibility for shaping the nature of the public display of cetaceans around the world. The Georgia Aquariums decision to seek wildcaptured belugas from Russia is at best regressive and at worst irresponsible in contributing to the continuing international trade in belugas, which undermines the conservation and welfare of this species worldwide. The Georgia Aquarium and its partners are being misleading by justifying their permit request in the name of conservation. These aquaria commissioned the captures of these belugas half of them under the age of three and almost certainly still dependent on their mothers and then asked for permission later, a blatant disregard for the welfare of these animals that undercuts the spirit and intent of marine mammal protection laws and prejudices the evaluation of the permit application. The Georgia Aquarium and its partners claim that the belugas they seek to import would have been captured and shipped to other locations regardless of their permit request. In fact, these animals were specifically procured for these US facilities, making them complicit in the ongoing capture and international trade in belugas. We find it unacceptable that US facilities are turning to the capture of wild belugas in other countries, but would not conduct such activities in US waters because of public aversion. Once again, we urge the agency to reject, in the strongest terms possible, the Georgia Aquariums import permit request. Signed
Animals Asia Foundation Animal Defenders International Animal Public e.V. Animal Welfare Institute Bluevoice.org Born Free Foundation Born Free USA Campaign Whale Canadian Marine Environment Protection Society Captive Dolphin Awareness Foundation

Care for the Wild International Centro de Conservacion Cetacea of Chile Cetacean Society International Coalition For No Whales In Captivity David Shepherd Wildlife Foundation Deutscher Tierschutzbund (German Animal Welfare Federation) Dolphin Connection Dolphin Dance Project Earth Island Institute Earthrace Conservation ECCEA (Eastern Caribbean Coalition for Environmental Awareness) Environmental Investigation Agency FAADA (Foundation for the Adoption, Sponsorship and Defence of Animals) FreetheAtlanta11 Georgia Animal Rights and Protection Gesellschaft zur Rettung der Delphine e.V. (Society for Dolphin Conservation) Green Vegans Grupo de los Cien Hong Kong Dolphin Conservation Society Humane Society of Canada Humane Society International International Marine Mammal Project of Earth Island Institute Lifeforce Foundation Marine Animal Rescue Marine Connection Marine Mammal Connection Society NABU International Foundation for Nature NY4Whales OceanCare Ocean Conservation Research Ocean Defender Ocean Friends Oceanic Preservation Society Orca Conservancy Orca Network Origami Whales Project Pacific Orca Society/OrcaLab Pacific Whale Foundation PETA Pro Wildlife reEarth Save Misty the Dolphin TerraMar Research The Humane Society of the United States The Love Foundation The Orca Project Voice of the Orcas WDCS, Whale and Dolphin Conservation Society Worldwide Events to End Animal Cruelty World Society for the Protection of Animals, USA Zoocheck Canada