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Dear Ms. Dodds,

I am writing you in reference to your letter from March 13rd were you expressed concerns about Morgan and her unborn calf. First of all, let me say that we appreciate your concern about orca Morgan. I can ensure you that all the staff of Loro Parque shares your concern, not only about this particular individual, but for every single animal (nowadays more than 10.000) of over 500 species hosted in its facilities.

I am very aware that Morgan was rescued in 2010 in the Waddensea. I am also aware that she would be now dead if the staff from the Dolfinarium Harderwijk wouldn’t have performed an extraordinary work recovering her from the brink of death. In 2011 we got the request from the Dutch Authorities to host Morgan and integrate her in our killer whale group, as the only other option was euthanasia. Loro Parque accepted to take care of Morgan in the same way we have done with many other animals (chimpanzees, gorillas, penguins, parrots, seals, etc.) in need of help.

Loro Parque follows strictly all the national and international regulations on zoo practice, including the compliance with the CITES regulations. Every year Loro Parque applies for hundreds of CITES permits and manages several hundreds of animals either on Appendix I or Appendix II of the convention. Thus the professionals of Loro Parque have an extensive knowledge and experience on the interpretation of the CITES permits and regulations. Loro Parque received Morgan with a CITES permit which clearly states she can be used for “the advancement of science/breeding or propagation/research or education or other non-detrimental purposes”. Free Morgan Foundation maintains the strange interpretation that this bans the breeding of Morgan, which is absolutely nonsense. This opinion of Free Morgan Foundation has never been supported by any CITES authority. At the beginning of 2016 Free Morgan Foundation addressed to the Spanish and Dutch authorities requesting the annulment of the CITES permit issued to transfer Morgan based on this peculiar interpretation and both rejected the request and considered it unfounded. Moreover, the Spanish authorities replied in a letter to the Free Morgan Foundation were it is clearly stated that “the only binding document for this [Spanish] management authority is the CITES certificate accompanying the specimen”, adding that “In this regard, it should be noted that the Community Certificate issued by the Dutch CITES MA doesn’t set any express legal limitation to breeding and authorized to keep the orca for research, breeding or educational purposes.”. As you can imagine, if the Spanish CITES authority has clearly expressed that there is no limitation to breed Morgan, Loro Parque must not accept other interpretations but this from the competent authorities.

It is not true that EAZA and WAZA do not recognize the possibility of breeding orcas, in fact both organizations made clear statements against the unilateral decision of SeaWorld of not breeding them. Please, contact the EAZA offices if you have any doubt, they will be able to inform you that within the Marine Mammal Taxon Advisory Group of EAZA there is a Monitoring Breeding Program
for Killer whales (Orcinus orca), hence it is clear that the European Association of Zoos and Aquaria does not have any problem or limitation on the breeding of the species.

So, it is clear that Loro Parque does not violate any conditions of the transfer of Morgan, nor any European regulation, nor the ASCOBANS regional agreement of the Convention on Migratory Species.

Regarding to your statement on Morgan I must say that it contains many mistakes and misunderstandings. For example, it is not true that the alternative of a seaside sanctuary was never legitimately considered, in fact during 2011 and 2012 there was a complex technical debate about the possibilities to release Morgan or house her in a sea pen. The Dutch Court took into account several release plans (up to three different with major changes in the course of three months, which says something about its robustness) presented by the Free Morgan Foundation, and decided that none gave a significant chance to survive in the wild for Morgan.

It is false that Loro Parque has published no research using Morgan. Since the arrival of Morgan by the end of November 2011 Loro Parque Fundación has funded and implemented 15 scientific projects with Orcinus orca, and has also collaborated with different research groups that requested the scientific use of the group of orcas. The research activities were focused in bioacoustics, genetics, physiology, ethology, biotracking and biometrics, and as a result of this scientific work with killer whales just in the last six years six scientific papers have been published in peer-review journals (and other three are submitted), eleven communications have been presented to international congresses, and one doctoral, two masters and six diploma theses have been produced.
All the research projects were selected taking into account the potential benefits to the conservation of the species. Hence, the published research will benefit the knowledge on how the cocktails of toxic substances would affect the immune system of wild killer whales. The paper on killer whale audiometry will provide essential information to study how the noise pollution in the sea could affect the killer whales.

Among these research projects, Morgan has participated in five of them that resulted in peer reviewed scientific publications:

DESFORGES, J. P., LEVIN, M., JASPERSE, L., DE GUISE, S., EULAERS, I., LETCHER, R. J., ACQUARONE, M., NORDOY, E., FOLKOW, L.P., HAMMER JENSEN, T., GRONDAHL, K., BERTELSEN, M.F., ST. LEGER, J., ALMUNIA, J., SONNE, C., DIETZ, R. (2017). Effects of polar bear and killer whale derived contaminant cocktails on marine mammal immunity. Environmental Science & Technology, 51(19), 11431-11439.

LUCKE, K.; FINNERAN, J.; ALMUNIA, J.; HOUSER, D. (2016) Variability in Click-Evoked Potentials in Killer Whales (Orcinus orca) and Determination of a Hearing Impairment in a Rehabilitated Whale. Aquatic Mammals 42(2):184-192

ALMUNIA, J. Analysis of call sequences in Orcinus orca. Submitted

ALMUNIA J., MOLINA-BORJA, M., KRASHENINNIKOVA, A., SÁNCHEZ, P. Social Interactions Analysis in Captive Orcas (Orcinus orca). Submitted

ST. LEGER, J., ORTÍN, S., LLORENTE, M., ALMUNIA, J., ÚBEDA, Y., Personality in captive Killer whales (Orcinus orca): a rating approach based on Five Factor Model. Submitted

And also in others that resulted in seven communications in International Scientific Symposiums

LALUEZA, E.; MORALES, H.; ALMUNIA, J. (2017) Analysis of cohesion calls in Orcinus orca. 45th Symposium of the European Association for Aquatic Mammals. Genoa

MORALES, H.; LALUEZA, E.; ALMUNIA, J. (2017) Analysis of call sequences in Orcinus orca.45th Symposium of the European Association for Aquatic Mammals. Genoa

UBEDA, Y.; LLORENTE, M.; ALMUNIA, J. (2016) Personality in Zoo-Housed Killer whales: a rating approach based on Five Factor Model. 44th Symposium of the European Association for Aquatic Mammals. Benidorm

KIRCHNER, A.C.; OJEDA, M.; ALMUNIA, J. (2016) Comparing day and night vocalizations in Orcinus orca. 44th Symposium of the European Association for Aquatic Mammals.Benidorm

ROSA F.; SANLUIS LEAL, J.C.; LUKE, J.P.; ALMUNIA, J.. Looking for number of degrees of freedom at Orcinus orca calls for the design of a classifier. XXV International Bioacoustics Congress.Murnau, Germany 2015

ALMUNIA, J.; SANLUIS, J.C.; LUKE, J.P.; ROSA, F. Automatic localization by acoustic methods of “Orcinus orca” individuals at LoroParque facilities. 42nd Annual Symposium of the European Association for Aquatic Mammals.Puerto de la Cruz, Canarias, Spain 2014.

SANLUIS, J.C.; LUKE, J.P.; ROSA, F.; ALMUNIA, J. Smart IP net to acquire and detect bio-sounds. 42nd Annual Symposium of the European Association for Aquatic Mammals.Puerto de la Cruz, Canarias, Spain 2014.

Regarding the first viable calf in orcas, please review carefully the literature you are citing. The age of first viable calf (that means the first calf that survives) was established around 12 years for the killer whales off Washington State (Olesiuk et al., 2005). But you must understand that this is the first viable, which means that killer whales can get pregnant before, lost the first calf and after year and a half have their first viable. There are recordings of several wild killer whales in Washington State Coast giving birth viable calves when they are just 9 years old (R38 was born in 2000 and gave birth to R52 in 2009; R24 was born in 1987 and gave birth to R32 in 1996; I92 was born in 2000 and gave birth to I125 in 2009). That means wild orcas can get pregnant when they are seven years old, further, seven years has proven to be a common age of sexual maturity for Icelandic killer whales in zoological parks. The fact is that animals reproduce instinctively, and are not able to control their sexual impulses or their reproduction. As a consequence, only sexually immature animals can be considered too young to breed. Morgan’s age has not been clearly established, she was estimated to be around 2 and 4 when she was rescued in 2010, so she could be between 10 and 12 years old now. Judging by her length, and using a table of age/length for North Atlantic Killer whales her age could even be 13 years.

It is totally false that the report made by Sánchez and Molina supports the findings made by Dr. Visser, as the authors clearly measured agonistic behaviours in less than 1% of the time they observed the orcas, clarifying that aggression was even less frequent. On the contrary Dr. Visser depicted the group of killer whales of Loro Parque as the most aggressive in the world, having a rate of aggression 100 times higher than any other. The conclusions of Sánchez and Molina suggested that could be signs of stereotypy, but that was not clear in the 100 hours of observation. It is clear that the results of Dr. Visser are not supported by this independent research made by expert ethologists. Similarly, the observations of Dr. Naomi Rose, are not part of a scientifically driven study with a professional methodology, but just the opinion of a person who leads an anti-dolphinaria organization.

Finally, after depicting a terrible situation (which disagrees with all the professional independent experts in animal welfare that have evaluated the situation of the Killer whales in Loro Parque during the last years) you propose the magical solution of a sanctuary that will solve all the problems just because the animals will have “more natural” conditions. That’s a simplistic way to approach animal welfare, especially because there are no experiences on sea-pens, thus you cannot take for granted that they will mean any positive change. Nowadays there are no marine sanctuaries, in fact despite the few existing projects that have spent several hundreds of thousand dollars there are no places selected, there are no permits to build the sanctuaries, there are no environmental impact analyses and, most important, there are no permits to transfer animals to the sanctuaries. As you should know, placing non-indigenous cetaceans in a sea-pen would pose at risk of genetic contamination the wild populations in the region, and also would mean an epizootic risk, because of the potential pathogens that could be released and affect the wild populations. It is highly unlikely that the European environmental authorities will issue permits that would pose at risk the wild populations of cetaceans.
After carefully evaluating most aspects of sanctuaries by comparison to professional and certified facilities, it is clear that these would not improve the welfare of captive bred cetaceans and even of wild caught cetaceans having lived several decades in captivity. The relocation to a sanctuary would not, in the long term, eliminate the conflict between activists and professional institutions caring for the animals, since no matter how big the sanctuary, it will always be hopelessly tiny compared to the natural marine mammal habitat.
Marine mammals adapted to a life in captivity have formed tight bonds with trainers and are constantly rewarded for their activities. This would need to me maintained in sanctuaries to ensure high levels of activity and continuous well-being of the animals.
Maintaining optimum conditions for cetaceans in captivity requires a wealth of experience and is very cost intensive. The animals require intensive care by veterinarians, trainers, technical personnel as well as the careful control of a wide variety of parameters.
In sea pens or sanctuaries the ingestion of foreign objects, pollution by oil spills, and chemical and biological hazards stemming from the sea or from land runoff cannot be controlled or would require costly additional measures. Captive cetaceans today reach high ages, and orcas may become older than 50 years. This constitutes a very long financial and ethical commitment for operators of any type of facility and would have to be guaranteed in the light of the proposed financing structures underlying any such activity. It seems highly unlikely that this level of funding can be easily reached, at least judging by the difficulties that the sanctuary projects have in order to get just the money necessary to find a suitable place.

I am sure the ruling of the Dutch court will soon probe for eight time that you are wrong.


Javier Almunia