October 27th, 2012 P.

Michael Payne Chief of Permits, Conservation Division Office of Protected Resources National Marine Fisheries Service 1315 East West Highway Silver Spring, MD 20910 RE: NOAA-NMFS-2012-0158 and File No. 17324 - the Georgia Aquariums request to import 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 an animal trainer at SeaWorld of Orlando from February of 1990 to August of 1993. During that time I worked with 4 beluga whales - Spooky, Shadow, AJ and Bandit. A few weeks ago I travelled from Alaska specically for the hearing in Silver Spring, MD because I felt that it was important for you to hear from a former trainer about what actually goes on behind-the-scenes at places like SeaWorld. I was one of the 15 people who spoke requesting NOAA to deny the permit, and I want to tell you more about why I believe that denying this permit is the right choice. Many people spoke very eloquently at the hearing about why this permit should be denied. I heard Dr. Lori Marino speak about the LACK of education at Aquariums and Marine Parks, and I also heard Dr. Naomi Rose of the Humane Society International address the technical specications of the permit and why the capture and import of these animals clearly violates the MMPA. At the hearing, a statement signed by over 60 NGOs from Courtney Vail of Whale and Dolphin Conservation was presented to NOAA. All told, a total of 15 people including educators, researchers, animal advocates, homemakers,aTV producer,apilot, lawyers, and social 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 the following:

Brutally removing the belugas from the wild and transporting them thousands of miles into the US for public display is unnecessary, inhumane and threatens wild beluga populations. It has nothing to do with conservation. If approved, the import will contribute to the unsustainable and cruel international trade in belugas.

Conservation means protecting species in the wild, not capturing them for captivity. Beluga populations in Russia have been decimated by over-hunting, and the same populations are also targeted for capture, preventing their recovery. The whales were caught rst and held in pens before any application to import them was made. By capturing the belugas rst, and then asking for permission later, the Georgia Aquarium has unfairly prejudiced the permitting application and process. The Georgia Aquariums permit application does not meet regulatory requirements and must be denied.

In addition, I was surprised that there was very little evidence presented by the pro-permit side that addressed the specics of the permit directly. Mostly the people speaking in support of the permit 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. Rossiters testimony about the amount of time that the beluga transfer will actually take, including the logistics involved in the transfer, was eye-opening. His estimate that transporting the belugas from Russia to the US will take upwards of 40 hours if everything goes right (there is apparently no contingency plan in case there are problems), is a much longer estimate than the 26-30 hours which was provided on the permit submitted by the Georgia Aquarium. In addition, the transfers in Liege, Belgium will not only involve moving belugas from one airplane to another, but the belugas will also have to be removed from their transport boxes via cranes and moved into other boxes due the fact that the boxes are not cross compatible between airplane types. Considering the multiple destinations of the animals, its likely that some animals could be in transit for more than 50 hours. This is clearly inhumane and denitely a violation of the regulatory requirements that the transport will not present any unnecessary risks to the health and welfare of the animals. From my experience working with belugas, its clear they are exceptionally sensitive to small changes in their environment. Subjecting them to the loud noises of the Russian planes, the multiple transfers, and ultimately a complete reorganizing of their social structure for a SECOND TIME (the first time having happened when they were captured), is highly cruel and unethical. 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 in shows, but I was also responsible for husbandry of these animals - which included monitoring their respirations and observing them for changes in their overall health and wellbeing. I was also responsible for educating the public about the beluga whales. We were all instructed to inform the public that extensive research was being done in the name of conservation - that is that the animals in our care were supposedly contributing something to our knowledge base that would 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 on hydrodynamics. The scientists goal was to determine the forces that affected the whales and dolphins as water passed by or was moved by their bodies, dorsal fins, flukes and pectoral flippers. I fail to see how this study contributed to conservation. Other than this, the only other data that I observed being collected was not in any way connected to wild populations but was simply focused on how to keep the animals alive in captivity for shows - which, tragically, is a 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, rarely make 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 Spookys only calf (stillborn) and Bandits 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 hasnt changed nearly 20 years later. Due to the limited nutritional content of their diet of frozen fish - in many cases not even the type of fish that the animals would be eating in the wild - animals were constantly getting sick. Many of the animals were given fish stuffed with antibiotics, antacids and anti-fungals, in addition to synthetic vitamins. The fact that the veterinarians felt compelled to keep these animals on these medications long-term tells me that they are unable to address the source of the actual illnesses - which is stress due to the effects of captivity including artificial environments, 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 I ever knew as a SeaWorld trainer. A person could learn more about beluga whales in five minutes on Wikipedia than they would learn in a day long visit to SeaWorld. So, I have to question how it 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 big the 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

natural behavior in the wild. Nothing could be further from the truth. Pick any Youtube video on SeaWorld and watch how the trainers run through the same boring sequence of anthropomorphized and mimicry behaviors, including head shakes/nods yes and no, spins, wiggles and unnatural vocalizations. From talking to my colleagues who are still working at SeaWorld, I know that this hasnt changed either in 20 years. So, I find the assertion that places like SeaWorld and the Georgia Aquarium are educating the public rather deceptive and disingenuous. When I was a SeaWorld trainer I believed that I was incredibly fortunate to swim and SCUBA dive with beluga whales, and at the time I didnt think about the circumstances of the whales themselves. Knowing what I know about beluga whales NOW (the complexity of their social structures, their intelligence, their ability to experience fear and pain, the stress they experience when isolated from other animals, and the complete lack of ability of the captive industry to meet any of their basic needs) I can tell you that I would trade all of my experience with belugas in a heart-beat to prevent more of them from being subjected to the horrible experience that captivity is for whales and dolphins. Rather than continuing the support of this inhumane practice which only perpetuates suffering and misery, please decline this permit. Thank you for your consideration. Sincerely, Samantha Berg, M.Ac, L.Ac., Dipl.Ac Former SeaWorld Trainer Owner of Alaska Center for Acupuncture, Palmer, AK