T
WDC, Brookfield House, 38 St Paul Street, Chippenham, Wiltshire SN15 1LJ
+44 (0)1249 449 500 F +44 (0)1249 449 501 E [email protected] W whales.org
WDC is a company limited by guarantee. Registered in England No. 2737421. Registered Charity No. 1014705.
Hugh Morgan
Managing Director
Cosmos Holidays
Wren Court
17 London Road
Bromley
Kent, BR1 1DE
Cc: Shena Howie, Senior H&S Consultant
10th December 2013
Dear Mr Morgan
I am writing on behalf of WDC, Whale and Dolphin Conservation, concerning Cosmos Holiday’s continued
promotion of holiday excursions involving captive whale and dolphin attractions.
Our research suggests that, among other facilities displaying whales and dolphins to the public, Cosmos promotes and
offers park ticket packages to SeaWorld, Aquatica and Discovery Cove in Orlando, Florida; Marineland Mallorca and
Loro Parque in Spain and swimming with dolphins attractions in Tortola, Mexico and Curaçao.
We welcome the publication of ABTA’s animal welfare guidance in June 2013 and its members’ commitment to
support good practice and help phase out bad practice in animal attraction and experience suppliers. While we
appreciate that this guidance has only been published in the last six months and that it may take a little time for it to be
fully implemented by ABTA members, we would like to take this opportunity to raise some specific concerns about
the captive dolphin attractions promoted by your business and urge you to end such support. To that end, in the
coming months, we are planning to launch a public campaign calling on tour operators not to promote facilities
holding captive whales and dolphins.
Acquisition of wild animals
In its list of “discouraged practices”, ABTA’s guidance includes “acquisition of wild animals”, noting that, “generally,
animals should not be acquired from the wild unless there is a demonstrable and justifiable conservation need, or it can
be demonstrated that the acquisition will not adversely affect in any way the conservation status or welfare of the
species”.
Bottlenose dolphins (Tursiops truncatus) held in attractions across the Caribbean region, including Tortola and
Curaçao and facilities in Mexico, were captured from the wild in Cuban waters. A paper authored by several cetacean
scientists and published in the Latin American Journal of Aquatic Mammals on the live capture of bottlenose dolphins
in Cuban waters concludes that “no sufficient evidence is found for independent scientists to evaluate the sustainability
of the current harvest of Cuban T. truncatus. Therefore, we strongly recommend that international trade ceases until
supporting evidence of no detriment can be authenticated. Continued field research on stock structure, abundance, life
history and anthropogenic threats is also greatly encouraged”. In response, the International Whaling Commission’s
Scientific Committee expressed concerns at “the complete lack of abundance data against which to measure the
sustainability of live capture removals”, recognising “the potential threat to small coastal populations
of bottlenose dolphins from unregulated and undocumented live capture fisheries.”
WDC does not believe that Cuba is in a position to make a non-detriment finding under CITES for
the export of bottlenose dolphins captured in its waters. We are concerned that captures and trade in
these animals continue to occur with little assessment and an unknown impact on the wild
populations from which they are taken. Captures also violate the United Nations Environment
Programme’s Protocol concerning Specially Protected Areas and Wildlife in the Wider Caribbean
A world where every whale and dolphin is safe and free
T
WDC, Brookfield House, 38 St Paul Street, Chippenham, Wiltshire SN15 1LJ
+44 (0)1249 449 500 F +44 (0)1249 449 501 E [email protected] W whales.org
WDC is a company limited by guarantee. Registered in England No. 2737421. Registered Charity No. 1014705.
Region, to which Cuba is a ratifying Party and which prohibits the taking, possession or killing of dolphins.
We strongly urge Cosmos to end its support of attractions which have recently sourced whales and dolphins captured
in the wild.
Animal performances
ABTA recommends that “where animals are involved in performances these should only involve natural behaviours”
(Dolphins in Captive Environments, page 13) and “animals should not be trained to undertake tasks that have no
relation to their natural behavioural repertoire (page 30)”.
In an analysis of footage and commentary from 18 dolphin shows in 10 Member States of the EU, dolphin behaviour
observed during the shows included dolphins shooting basketballs through nets, dolphins towing children around the
show pool in an inflatable boat, dolphins given paintbrushes to paint on canvas, dolphins jumping through hoops and
dolphins pushing trainers into the air or through the water. These types of behaviour, which bear little to no
resemblance to the types of behaviour seen in wild dolphins, were not observed in isolated facilities but across the
majority of dolphinaria. No dolphin show exhibited only untrained dolphin behaviour. Furthermore, it was impossible
to calculate what proportion of their behaviour was natural or unnatural as it was clear that all of their behaviour was
either trained, choreographed, unnatural or all three. In every show observed, the animals interacted with foreign
objects, such as balls or hoops, and with human trainers or visitors.
Dolphins, including orcas or killer whales, are exhibited in similar attractions across the world to those analysed in the
European Union, including those promoted by Cosmos, who also display their animals to the public through
performances involving behaviour not naturally seen in the wild.
Furthermore, the majority of shows analysed in the EU research involved animal performance to loud music,
something considered bad practice by ABTA. SeaWorld’s shows are also set to loud music.
ABTA recommends that “animals should remain in the pool at all times” (page 28) and “beaching should only be
performed if it has been deemed necessary by a veterinarian” (page 29).
Beaching on the poolside is a regular feature in many cetacean shows, including SeaWorld’s One Ocean show
featuring captive orcas. Many of the shows at captive dolphin attractions in EU Member States analysed by WDC also
featured beaching as part of the show routine.
The captive environment
ABTA recommends that “environments should be stimulating and enriching, encouraging natural behaviour”
(Dolphins in Captive Environments, page 21).
Captive whale and dolphin attractions cannot provide an environment that simulates the natural environment of
cetaceans. Water is chemically treated, often with chlorine, which prevents the placing of live fish and natural plant
life or coral in pools. It is also filtered to prevent the build-up of the animals' excrement and other waste. Pools are
generally small and empty of stimuli, perhaps to facilitate cleaning, although lacking in species-specific enrichment.
Some dolphinaria provide only indoor facilities for their animals, lacking any natural light.
ABTA also recommends that “animals should be able to escape other individuals, public view and
interaction at all times (page 21)”.
During shows, show pools are generally gated off to retain dolphins involved in the show in front of
public view. Whales and dolphins are encouraged to remain both in show pools and perform in the
shows through rewards of dead fish given at the poolside.
A world where every whale and dolphin is safe and free
T
WDC, Brookfield House, 38 St Paul Street, Chippenham, Wiltshire SN15 1LJ
+44 (0)1249 449 500 F +44 (0)1249 449 501 E [email protected] W whales.org
WDC is a company limited by guarantee. Registered in England No. 2737421. Registered Charity No. 1014705.
At SeaWorld parks in Orlando, San Diego and San Antonio, visitors can purchase fish from a booth and feed it to a
number of bottlenose dolphins held in a shallow pool at arm’s reach. Although the booths selling fish open only
periodically, visitors to Sea World still have non-stop access to the dolphins in these pools, known as “petting pools”,
for as many hours as the park is open - up to 12 hours a day in summer months. Even if the dolphins move away from
the poolside, they cannot escape public view. WDC has a number of additional concerns about these pools, which are
outlined in Annex A and are relevant to ABTA’s discouragement of “public feeding of cetaceans” (page 16).
ABTA also recommends that “cetaceans should be housed in social structures similar to those in the wild” (page 25).
In captivity, social structures are vastly different to those in wild populations. Individuals who would never naturally
come across one another in the wild are forced into close proximity, which can lead to aggression between individuals,
stress and injury.
In the wild, small cetaceans such as dolphins form a complex society that is frequently based on kinship. Some species
retain family bonds for life. In some orca populations family ties are so persistent and well-defined that all family
members are usually within a four-kilometre radius of one another at all times. Captive facilities, with their logistical
constraints and space limitations cannot provide conditions that allow natural social structures to form. In captivity,
social groups are wholly artificial. Facilities mix individuals from Atlantic and Pacific populations, unrelated animals,
and, in the case of orcas, races (transient and resident), which have disparate diets, habits, and social structures.
Morgan, a female orca rescued from the wild in the Netherlands in 2010 is currently being held at Loro Parque in
Tenerife, where she is displaying worrying signs of stress and is subject to aggressive behaviour by the other orcas
held there. This is despite there being a viable release plan, developed by experts, for her return to her native waters. In
December 2009, trainer Alexis Martinez was killed when he was rammed by an orca during a training session at Loro
Parque. In 2007, another trainer at Loro Parque was dragged to the bottom of the tank by an orca and suffered damage
to her lung and broken bones.
ABTA considers “feeding by hand, above the water” and “artificial, inland, smooth-sided swimming pools” to be bad
practice. WDC is unaware of any captive dolphin attraction around the world that feeds cetaceans by any other method
than feeding by hand, above the water or any – not counting those which use sea pens on the coast – which isn’t made
up of artificial, smooth-sided swimming pools. Sea pens have their own potential problems. Recent hurricanes have
led to dolphins in them being battered by falling debris, washed out to sea and even killed. Water quality can also be a
problem. Sea pens close to shore may contain only very shallow water, which can get too hot in the sun. Those close
to towns or resorts may also contain high pollution levels, bringing the risk of illness and even death to the animals
held.
Breeding concerns
ABTA recommends that “calves should not be separated from their mothers until naturally weaned” (Dolphins in
Captive Environments, page 23).
Unfortunately, captive facilities routinely separate cetacean calves from their mothers and move them to other
facilities or enclosures long before they would accumulate the skills necessary to fend for themselves in the wild.
Sumar (who died in 2010 aged only 12 years), a male orca born at SeaWorld Orlando, was separated
from his mother at only six months of age and was moved to California when he was less than 10
months old. Splash (who died in April 2005 aged only 15 years) was moved from his mother at
Marineland Ontario to SeaWorld San Diego when only 2.5 years old.
A world where every whale and dolphin is safe and free
T
WDC, Brookfield House, 38 St Paul Street, Chippenham, Wiltshire SN15 1LJ
+44 (0)1249 449 500 F +44 (0)1249 449 501 E [email protected] W whales.org
WDC is a company limited by guarantee. Registered in England No. 2737421. Registered Charity No. 1014705.
Interaction programmes
ABTA states that “animal handling and contact by the public should be discouraged” (Dolphins in Captive
Environments, page 31)
Interaction programmes involving animal handling and contact by the public are main features at animal attraction
facilities such as SeaWorld, Discovery Cove and the attractions promoted by Cosmos in the Caribbean region which
offer swimming with dolphins or similar programmes where visitors enter the water with the animals. SeaWorld also
offers dolphin petting pools, our concerns about which are outlined in Annex A.
WDC sincerely welcomes the development and publication of guidelines for animal attractions by the tourism industry
and appreciates the commitment tour operators such as Cosmos have made to phasing out bad practice among such
attractions. However, WDC believes that in the case of whales and dolphins (including bottlenose dolphins, orcas,
belugas and other cetaceans) in captive environments, ABTA recommendations are being flouted by captive cetacean
attractions across the board.
Captive cetacean attractions actively promoted and supported by ABTA members such as Cosmos hold dolphins
recently acquired from the wild, in condemned capture operations which are likely to have adversely affected the
populations targeted; display whales and dolphins to visitors in circus-style shows, which bear no resemblance to the
natural behaviour of these animals, against a backdrop of loud music and include potentially dangerous activities such
as beaching on the poolside; hold whales and dolphins in stark, artificial tanks with no natural stimulation in which
environments it is impossible for these complex, highly intelligent, social animals to exhibit natural behaviour and
where they have no means of escape from one another or their trainers or the viewing public; calves are routinely
separated from their mothers at a young age and animal handling and contact are commonplace and highly publicised.
WDC therefore strongly recommends that Cosmos cease its promotion and support of attractions holding whales and
dolphins in captive environments.
In the coming months we are planning to launch a public campaign calling on tour operators not to promote attractions
holding captive whales and dolphins. We very much hope to be able to add Cosmos to a list of tour operators
supporting our position on whale and dolphin captivity, which will hopefully encourage other tour operators to follow
your example.
Thank you for your time. I look forward to hearing from you.
Yours sincerely,
Cathy Williamson
Captivity Programme Manager
WDC, Whale and Dolphin Conservation
Email: [email protected]
Phone: 01249 449 523
A world where every whale and dolphin is safe and free
T
WDC, Brookfield House, 38 St Paul Street, Chippenham, Wiltshire SN15 1LJ
+44 (0)1249 449 500 F +44 (0)1249 449 501 E [email protected] W whales.org
WDC is a company limited by guarantee. Registered in England No. 2737421. Registered Charity No. 1014705.
Annex A: visitor/dolphin interaction programmes: “petting pools” at SeaWorld parks, USA
WDC has a number of concerns about these attractions, including the following:
•
Potentially unlimited numbers of inexperienced members of the public are permitted to engage in poorly
regulated physical interaction with large, powerful animals in a crowded environment;
•
Dolphins are enticed with food, exacerbating aggressive competition between individuals and inciting attacks
by birds;
•
Dolphins are accessible to the public without respite for up to 12 hours each day, often without access to a
physical refuge;
•
The daily participation of hundreds of visitors makes it impossible to ensure that individual dolphins are
receiving an appropriate amount and type of food, and are not fed dangerous foreign objects or contaminated food;
•
Abrupt movements by, and aggressive competition between dolphins can result in physical injury to visitors,
including bites, head butts and trapped hands;
•
The selective attention of the public on the ‘pushiest’ dolphins results in obesity and may reinforce and
perpetuate dangerous attention-seeking behaviour;
•
Physical contact between visitors and dolphins provides an opportunity for bi-directional transmission of
diseases;
•
A misconception promoted and reinforced by public feeding of captive dolphins that it is appropriate to feed
and touch dolphins may lead to harassment of wild dolphins.
A world where every whale and dolphin is safe and free