ATTN: Jolie Harrison Chief
Permits and Conservation Division
Office of Protected Resources
National Marine Fisheries Service
1315 East-West Highway, Room 13705
Silver Spring, MD 20910
Dear Ms. Harrison:
In response to the National Marine Fisheries Service (NMFS)/Office of Protected Resource’s (OPR) recent request for comments on the permit application to import five beluga whales for scientific research (File No. 22629, Mystic Aquarium), the Association of Zoos and Aquariums (AZA) fully supports the proposal submitted by Mystic Aquarium.
Founded in 1924, AZA is a 501(c)3 non-profit organization dedicated to the advancement of zoos and aquariums in the areas of conservation, education, science, and recreation. AZA's accredited aquariums, nature centers, science centers and zoos annually host more than 195 million visitors, collectively generate more than $22 billion in annual economic activity, and support more than 208,000 jobs across the country. In 2018, AZA-accredited facilities spent over $220 million on field conservation in 128 countries benefiting over 860 species and subspecies. In order to gain AZA membership status, an aquarium or zoo must meet our rigorous accreditation standards. AZA accreditation is the world’s gold standard for zoological institutions, which 238 facilities have met or exceeded. Mystic Aquarium is not just a member, but a leader among members in our community.
In our view, Mystic Aquarium’s permit application warrants approval for three principal reasons:
Scientific Research: Generally speaking, research at and by AZA member facilities is essential in understanding the anatomy and physiology of marine mammals, in treating sick and injured animals from the wild, and in learning to better manage and assist endangered species. Additionally, many AZA facilities collaborate with marine mammal researchers from colleges, universities, and other scientific institutions that conduct studies important to wild species’ conservation and health. This body of work has contributed significantly and will continue to contribute to the knowledge of marine mammal physiology (e.g., blood chemistry, immune function, metabolic processes, respiration, thermoregulation, etc.), sensory biology (e.g., visual acuity, color vision, passive and active touch, auditory frequency detection thresholds, auditory temporal processing rates, hearing in noise, sound localization, echolocation, gustatory and olfactory sensory systems, etc.) and psychophysics, which addresses the relationship between physical stimuli and sensory responses. These studies have led to improvements in diagnosing and treating diseases; techniques for anesthesia and surgery; tests for toxic substances and their effects on wild marine mammals; and advancements in diet, vitamin supplementation, and neonatal feeding. Much of this research simply cannot be accomplished in ocean conditions.
There are additional areas of investigation that are immediately needed to understand how arctic species thrive in the wild, or just as importantly, may fail to thrive, as anthropogenic factors alter their natural habitat. We know that climate change will present a number of new challenges for these species. On a basic level, increased water temperatures and the record minimum of arctic sea ice means that concentrations of watershed pollutants will increase, prey species will migrate, newly opened waterways will allow invasive species and ship traffic to enter, sound pollution will increase…among other changes. In order to take steps proactively to conserve belugas, we must understand their physiology and sensory biology. Detailed studies that investigate the belugas’ nutritional needs given different calorically-valued prey items, metabolic rates and thermoregulation capabilities in different water temperatures at various stages of beluga lives, including pregnancy and lactation, and bio-acoustic and diving adaptations in response to ship noise and oil exploration, can only be conducted with the animals in our care.
This is the crux of Mystic’s proposal. We need to better understand these animals. It is difficult and expensive to study them in nature. Ex situ study can play an essential role in filling gaps, and assuring that in situ research is better focused, more effective, and safer for the animals being studied. Sea Research Foundation is a center for global research in beluga whales with a core team of five full-time scientists studying belugas within a larger, world renowned marine science research program. The research is conducted through a state-of-the-art facility at the University of Connecticut-Avery Point, by scientists holding faculty appointments, with proven publication records, and dedicated to non-invasive beluga research that advances knowledge in areas like immune response, health indicators, hearing and sound issues, diving physiology, and non-invasive study techniques. This research will be conservation relevant, addressing priorities identified in existing recovery and sustainability plans like those for beluga populations in Cook Inlet, Alaska and the Saint Lawrence Estuary.
This import will facilitate unique accessibility to study belugas in ways not possible or practicable in wild settings; it will ground-truth new technologies and testing equipment for wild population study; and it will advance knowledge on key issues impacting survival of belugas.
At the recent public hearing held by NMFS/OPR on this research permit proposal, a large proportion of those testifying fully recognized and respected the professional capabilities of Mystic Aquarium to conduct bona fide scientific research, including those organizations that are not typically supportive of zoos and aquariums in general.
AZA noted one organization argued that, although the Marine Mammal Protection Act (MMPA) allows public display associated with an enhancement permit, because the law is silent about public display associated with a scientific research permit, the MMPA does not allow public display under such a permit. We disagree with this interpretation. Although the MMPA includes language about public display associated with an enhancement permit, it is restrictive language. The lack of specific public display language associated with scientific research permits only suggests that public display is not similarly restricted. This position is supported by NOAA’s explicit regulations regarding public display associated with both scientific research and enhancement permits. Regarding scientific research permits, the regulations state as follows:
50 CFR §216.41 (c)(1)(vi):
Marine mammals held under a permit for scientific research shall not be placed on public display, included in an interactive program or activity, or trained for performance unless such activities:
The Mystic Aquarium permit application is entirely consistent with these provisions.
Care and Welfare:
Approval of this importation will improve the care and welfare of these five beluga whales. They will be moved from a well-managed but unaccredited facility, to an AZA accredited and exceptionally designed habitat where they will receive customized care and enrichment. Moving these animals will also reduce crowding at Marineland, benefitting the animals remaining there as well.
Engaging the public and inspiring empathy and action: Sadly, tragically, and now helplessly, we are witnessing extinction of the vaquita porpoise. To prevent this from happening to belugas and other cetaceans, we need two things: 1) greater understanding of their biology and ecology; and 2) a public that is informed, engaged, empathetic and inspired to action. Mystic Aquarium has proven capacities to couple powerful scientific research with inspiring public outreach and education that reaches key audiences.
By approving this permit request, you will be immediately improving the welfare of these animals. You will set the stage to significantly improve our understanding and conservation of beluga whales. You will facilitate the engagement of a public that will be empathetic and inspired to act.
The millions of people that come through our collective doors each year to view our marine mammal ambassadors like beluga whales learn about the wonderful world of the sea and the fragility of its diverse ecosystems. We believe our message of respect, wonder and appreciation of the natural world contributes significantly to marine mammal conservation and management.
Thank you for the opportunity to comment and we look forward to working with you and your dedicated staff in the future on this and many other fish and wildlife conservation initiatives.