Tuesday, 04 October 2016 13:21

Comments by Loro Parque on the Report “Ongoing concerns regarding the SeaWorld orca held at Loro Parque, Tenerife, Spain” by Dr. Ingrid Visser & Rosina B. Lisker


In 2010, the juvenile female killer whale (Orcinus orca) named “Morgan” was rescued by marine animal health professionals at Dolfinarium, Harderwijk from shallow waters on the Dutch coast at the request of the Dutch Government. Over the course of a year with constant expert care, Morgan was rehabilitated and her health restored, and after thorough and repeated review and due diligence by the Dutch Courts, The Dutch Government determined that Morgan was non-releasable and issued a CITES permit authorizing her transfer in 2011to Loro Parque, a professionally accredited zoological park on the island of Tenerife, Spain to join five other killer whales.   Upon arrival at Loro Parque, and under a comprehensive behavioural and veterinary care program, Morgan integrated rapidly and smoothly into the existing social group. 


Daily work with her trainers gave rise to a suspicion of possible hearing loss that was subsequently diagnosed as a substantial hearing deficit by extensive observation and testing.  This hearing deficit is most likely a contributing factor in her original stranded condition but has not in any way inhibited her interactions and integration with her new social group at Loro Parque.


 Regrettably, Visser’s  & Lisker’s “Ongoing concerns regarding the SeaWorld orca held at Loro Parque, Tenerife, Spain” does not accurately reflect the reality that Morgan is thriving in her definitive home.  A principal of the Free Morgan Foundation, the Orca Coalition and the World Cetacean Alliance, Dr. Visser has authored a document that is both erroneous and misleading. Dr. Visser has forgone scientific convention, objectivity and accuracy, instead creating an emotionally charged and exaggerated document that uses inflammatory language to describe negative welfare conditions that do not exist.


Any proper scientific document includes a presentation of materials and methods, which explains how the researcher has done his or her work, and a detailed summary of the data upon which the researcher bases any conclusions.  The Visser & Lisker report is virtually free of material, method or data but contains a large excess of conclusions.   In short, Free Morgan Foundation has again produced an animal activist opinion piece, which they attempt to veil and market as scientific literature.


The document was produced by a biologist (who has never published scientific research about any veterinary aspect) and a legal advisor based in pictures taken during the short time slots when the animals were in the public presentations. Their conclusions try to challenge the professional opinion of a qualified veterinary surgeon, with the degrees of MA, VetMB from the University of Cambridge, and Fellowship of the Royal College of Veterinary Surgeons, that holds the European Diploma in Zoological Medicine and a European and RCVS recognised Specialist in Zoo and Wildlife Medicine, who is also a Fellow of the Society for Biology and a Chartered biologist.

Hence,  two authors without professional formation on veterinarian medicine (one of them not even in biological sciences), are suggesting that a doctor in veterinarian medicine that has worked in the field of marine mammal medicine for 40 years (including continuous responsibility for killer whales) is not able to evaluate correctly the health and welfare of a group of killer whales or , even worst, is maliciously hiding and manipulating information.


Below follows a point by point rebuttal of Dr Visser’s  and Ms Lisker’s claims and opinions.

Visser, I. N. & Lisker, R. B. (2016). Ongoing concerns regarding the SeaWorld orca held at Loro Parque, Tenerife, Spain. Unpublished report. 67 pages. Available from www.freemorgan.org 



Page 2:


Such permanent self-mutilation and injuries from drilling the teeth are a reflection of extremely compromised welfare standards for orca held at Loro Parque


Comment 01:

First statement is false, teeth drilling is a veterinary practice to avoid infections in the teeth that would cause inflammation and pain. Thus the teeth drilling (which is always performed with anesthesia) is a prove of the dental care provided in Loro Parque to avoid welfare problems.


Page 2:


Furthermore, the staff regularly confine the orca in a tank so small it prevents natural body postures and normal behaviour. Such confinement, which is not associated with medical or husbandry needs, disregards commonsense and welfare guidelines and is against industry ‘best practice’ standards.


Comment 02:

“regularly confine the orca” is a very  vague term that does not gives information on how much time an orca stays in the medical pool on average. The authors say that their observations were taken in the time the animals were on public display, and that one of the three holding pools was empty at that time. As a consequence their observations were biased by those circumstances, it can not be inferred that orcas are regularly in the medical pool just from nine observations of less than 40 minutes each.


Page 2:


Violations of at least four of the ‘Five Freedoms’ and 23 published cetacean-specific welfare indicators were noted. Evidence for these was collected in only an extremely truncated timeframe; during the public circus-like shows from merely three days of observations.


Comment 03:

The “violations” suggested by the authors are not based on observations made with a scientific methodology, and the verification of the cetacean specific welfare indicators were not done following the specific methodology required, thus this statement can not be considered.




Page 2:


It is imperative for these animals to be provided with better living conditions that address these welfare issues.


Comment 04:

The authors fail to explain how the “better living conditions” would address the welfare issues or how living in a sea pen can recover the actual dental damage that is the fundamental complain of the report.


Page 5:


The most graphic and undeniable welfare indicator for captive orca is the damage they sustain to their teeth (e.g., such as that illustrated in the cover image, Figure 1). Unfortunately, the captivity industry tries to frame the dental damage sustained in their facilities as ‘normal’. Such obtuse allegations are easily and logically dispelled.


Comment 05:

Tooth wear appears to be a natural consequence of killer whale behaviour.  The author has chosen not to mention scientific studies demonstrating that tooth wear and tooth fractures are not unusual in wild killer whales[1].   Nowhere in the scientific literature is stated that dental damage is a valid welfare indicator.  As the report explains, teeth typically have extremely limited function in food processing in cetaceans, so how can a broken teeth compromise the welfare of an animal? If the broken teeth do not produce any pain, inflammation or infection, it will not have a significant effect in the welfare of the animal.


Page 5:


In another attempt to frame the dental damage as ‘normal’, the captivity industry claims variations on the theme that it results from; the way the animals manipulate their food; the animals feeding methods; or that in captivity the food (fish and squid) they are fed are causing this dental damage.


Comment 06:

This statement is false. Anywhere in the citation provided is stated that dental damage in captivity is produced by food. What the citation states is that there are pictures of wild fish-eating killer whales that show dramatic dental erosion.


Page 5:


Transients do not typically show excessive tooth wear (e.g., see photo of one male (at least 10 years old) and one female (at least 20 years old) in Ford & Ellis 1999, and see Figure 3 and Table 3 in Ford et al. 2011, as well as their supplementary material).


Comment 07:

Two pictures do not constitute a probe, to make such a statement a scientific reference must be provided. There are also pictures of young killer whales with severe tooth wear, hence the best approach would be to have an extensive study on the prevalence of tooth wear in different ecotypes of killer whales.


Page 6:


Although a North-Atlantic population of orca (termed Type 1 by Foote et al. 2009) has been described as having diagnostic population-wide tooth-wear, those orca despite sharing some genetic haplotypes with fish-eating Norwegian orca, are postulated to be very generalist feeders who also take marine mammals (Foote et al. 2009). Morgan, a wild-born orca, held at Loro Parque, is also from a fish-eating population of orca (from Norway) and that population has not historically been recognised as having extreme tooth wear (Christensen 1982, Christensen 1984).


Comment 08:

From this statements it can no be concluded that fish-eating Norwegian orcas do not have easily erodible teeth, as the authors stated  that only the transients are known to have reinforced teeth. There are many indications that killer whale teeth are easily erodible, not only by abrasive preys (like sharks) but also by more soft materials like herring skin or vegetable fibre rope.


Page 7:


The apical damage seen on captive orca often becomes so extensive that it results in life-threatening damage, which the facilities attempt to mitigate by drilling.


Comment 09:

The authors speculate about infections caused by damaged teeth without any supporting evidence.  Morgan does not suffer from any such infections. The authors fail to provide data on how many orcas have died due to teeth damage, so this argument is not supported.


Page 7:


Thus, based on enamel hardness and ‘protection’ by the lips (particularly in the maxillae), it is unreasonable and imperceptive to even attempt to propose that the damage seen on captive orca teeth is due to feeding.

Comment 10:

Loro Parque never stated that the damage was caused by the food.


Page 8:


In one instance it was suggested by stakeholders that a mutually agreed upon veterinarian, as well as a Judicial Officer, be used.


Comment 11:

The request was made without previous consultation to the organization responsible for the hosting as per request to the Dutch Authorities (Loro Parque), insinuating that the local authorities and the professionals and consultants in charge of the health and welfare of the animals were manipulating information or simply lacked of professional knowledge.



Page 8:


To validate the concerns raised by the stakeholders, including the Free Morgan Foundation (FMF) (www.freemorgan.org), observations by the authors of this report (Visser & Lisker) were made at Loro Parque 20-22 April 2016.


Comment 12:

Free Morgan Foundation cannot be considered a stakeholder anymore as the release of Morgan was considered non realistic by the Dutch Government.  As this decision was confirmed by all the judicial instances up to the final sentence by the Raad van State, the decision of the Ministry of agriculture is firm and irrevocable and, as a consequence, FMF cannot  maintain any lawful interest in Morgan.



Page 8:


Although the ‘Health Assessment’ makes reference to additional ‘Health and management records’, of which Greenwood states; “I reviewed the records for each animal for the last two years”, he makes no reference to any detailed dental records nor any description of how dentition is assessed.  Although the ‘Health Assessment’ makes reference to additional ‘Health and management records’, of which Greenwood states; “I reviewed the records for each animal for the last two years”, he makes no reference to any detailed dental records nor any description of how dentition is assessed. 


Page 9:


In general the Greenwood ‘Health Assessment’ lacks substantive details regarding much about the health of the animals and instead, just a general description is given.



Comment 13:

The authors Fail to include the most important part of the Healt Assessment, its conclusion  "In general, the physical condition and health of the group is excellent. From what I was able to see from their behaviour and through their records, their psychological health is also good.”I was satisfied that this group of whales was being given the best of care."



Page 11:


Although Dr Greenwood may mention teeth that are drilled he fails to explain or note that these drill holes are then left open and must be flushed daily to prevent impacted food from becoming a hazard (e.g., infections due to rotting fish).



Comment 14:

This procedure is not mentioned in the veterinarian report as this is a regular dental hygiene activity performed by the trainers to avoid infections, hence to prevent any problem that could affect the welfare of the animals. Nobody would expect that a doctor evaluating the general health status of a patient include information about the dental hygiene, explaining how many times a day the patient brushes his teeth, or if he uses dental thread.


Page 11:


Within such a compressed timeframe we have documented acute levels of dental stress for Adán and the other five orca, which signify and illustrate (not only to a layperson but to anyone with any ethical scruples or moral integrity), that there are major and


Comment 15:

The authors intentionally omit to explain how the dental damage is affecting so dramatically the welfare of the animals. The fact that the animals have dental damage does not automatically imply that there is infection, inflammation or even pain, thus a detriment on the animal welfare cannot be directly inferred from the dental damage.


Page 11:


There is a duty and an obligation to fix the problems as clearly this species does not thrive in captivity. To deny there are issues in the light of this evidence would be irresponsible as well as inhumane.


Comment 16:

To infer from the dental damage that the species does not thrive in captivity is ridiculous. Specially taking into account that the latest scientific publications demonstrate that the lifespan of captive orcas in the best facilities is comparable to their wild counterparts.


Page 14:


This was because Morgan was typically moved into the medical tank, by Loro Parque staff soon after the arrival of Visser & Lisker, to prevent clear photographs being taken.


Comment 17:

This is a speculation of the authors. They do not mention that the last day Morgan was at the main pool for the presentation (as they requested) and passed totally unnoticed for them. When the Loro Parque staff arrived at the facility to meet the authors they insisted that Morgan was in the medical pool, when in fact she was in A pool. The validity of the observations must be questioned given the fact that the authors probed to have problems in identifying Morgan.


Page 14:


Furthermore, if the authors attempted to stand in the area by the east tank (i.e., still in the general public viewing area) in order to attempt to photograph the distant animals in the medical tank, they were firmly instructed by security staff to move into the stadium area or to leave the facility. This was, again, in an apparent attempt to prevent photography to document Morgan’s physical condition.


Comment 18:

Despite the authors try to insinuate that Loro Parque prevented them to take pictures what they are describing is just the usual procedure with all the public, nobody can remain in that area during the presentation of the animals. That was not difficulting the observation, as from the stands they could have a perfect view of the medical pool. It is absurd to say that there was an attempt to prevent the photography of Morgan, as the authors were granted to stay for 15 min after one of the presentations with Morgan in the A pool so they could take pictures of her body condition.


Page 14:


A request by Visser & Lisker, for Morgan to be ‘stationed’ at the side of the tank to facilitate photography or even a visual assessment was refused by Dr Almunia.


Comment 19:

Because the trainers were in their lunch break and there was not enough staff to manipulate and control animals.



Page 16:


It is very clear from this series of images that Morgan suffers from relentless compromised welfare as the number of damaged teeth illustrates.


As discussed above, in captivity, orca dentition is a fundamental indicator of the animals compromised welfare. Damage to their teeth is an undisputable physical attribute which is extremely easy to identify, evaluate and document over time.


Comment 20:

Again the authors try to infer a compromise on Morgan’s welfare from teeth damage, which is not correct, as they do not probe any signs of inflammation or pain that could be the only issues compromising the welfare of the animal. Orca dentition has not been considered as an indicator or orca welfare or cetacean welfare in any scientific publication.



Page 18:


Due to the overwhelming evidence presented herein we can only assume that; (1) the Greenwood (2015) report glossed over the dental issues and/or (2) the Greenwood (2015) report failed to identify some of the dental issues and/or (3) there is some deep-seated stress trigger for the orca at Loro Parque that is causing them to self-mutilate their teeth at an extremely accelerated rate. Of course these points are not mutually exclusive and there may also be other factors (e.g., internal politics) contributing to the lack of accuracy when reporting or documenting welfare concerns.


Comment 21:

Or even more simple explanation, dental damage is not affecting animal welfare and this is only an exaggeration of the authors. Taking into account that an expert veterinarian with 40 years of experience has detected dental damage and qualifies the general condition of the animals of “excellent” the dental damage does not seem to have relevant welfare implications.


Page 18:


The United Nations has recognised, through their Food and Agriculture Organization (FAO) legal office, the growing wealth of scientific information indicating that “Disregard for animal welfare often leads to poor animal health” which in turn leads to “increased susceptibility of animal populations to disease and injury ....” (Vapnek & Chapman 2010). That the orca at Loro Parque have sustained irreversible injuries to their teeth speaks volumes.


Comment 22:

Again the authors are trying to infer disease and injury from the teeth damage which is a clear manipulation, there are no signs of disease in the animals, and the veterinary reports qualifies the health of excellent. So the rest are malicious speculations.



Page 19:


Using these four groups we then ranked each tooth based on their damage (Appendix 3). Where a tooth was damaged with multiple types of injuries the most severe was applied when ranking. For example, a tooth may have moderate apical wear but also be broken (cracked). Therefore it would be ranked as having ‘Severe’ damage.


Comment 23:

None of these descriptive categories give any information about the inflammation or pain that these damages provoke to the animal. Even a weak dental pain would provoke behavioural changes that will be detected by the trainers, that would check any possible sign of inflammation with a thermo graphic camera. In case an abnormal temperature rise is detected the veterinarians are warned to evaluate if the animals needs treatment, either analgesic or antibiotic if their blood analysis shows signs of infection. Hence the veterinarian protocols in Loro Parque prevent that any of this dental damage can affect the welfare of the animals.



Page 19:


Alarmingly, Morgan (the only wild-born orca held at Loro Parque) had 66.66% of her left mandible teeth ranked as Severely and Moderately damaged.


Comment 24:

The authors are misleadingly trying to link dental damage with welfare, but there is no scientific indication on the relation between the percentage of teeth damage and welfare.



Page 20:


This extreme damage is occurring despite claims by Loro Parque that there is; “... veterinary equipment at zoos that keep orcas have a dental plan to avoid problems related to this [tooth] wear.”16 Although this quote has stilted English it attempts to convey the idea that facilities should be able to prevent the very damage that is prevalent at Loro Parque. 


Comment 25:

What this phrase means exactly is that the zoos with orcas have a procedure to avoid the health and welfare problems that can occur if the dental damage is unsupervised. A veterinarian procedure cannot avoid dental damage, but can avoid the welfare and health problems caused by dental damage.



Page 20:


Recent published scientific research indicates that captive bears who conduct stereotypical bar biting, similar to the captive orca stereotypies of chewing on hard surfaces, are also prone to developing dental pathology. That damage can cause pain and suffering, resulting in negative welfare consequences (Fleming & Burn 2014).


Comment 26:

The authors use scientific references without reflecting all its relevant aspects of the study in the discussion of the dental damage. Thus, they surprisingly fail to refer all the situations conducting to a dental pathology in sun bears (longevity in captivity, inappropriate diet, trauma, and stereotypical bar biting) to emphasize the only thing that they want to emphasize, the bar biting. The paper describes precisely the way to detect pain from dental trauma in sun bears, a species with a much lower management level in captive environments than the killer whales. That means that dental damage, per se, is not a welfare issue but only the dental damage that has associated pain. Exactly in the way it is described for sun bears, the behaviour or the killer whales is the best indication of pain or discomfort. When is detected, the diagnosis include detailed thermo graphics of the mandible that would reveal even subtle inflammatory processes that can be easily treated with analgesics or   with antibiotics if an infection is revealed by the blood analysis.



Page 30:


The information gathered by the FMF and presented here, illustrate that the issues described in the Visser (2012) report continue and that these issues are therefore of increasing concern given their duration, i.e., in the magnitude of years. The welfare indicators that the FMF has used in the past (and herein) to signify compromised welfare include inter alia; aggression, bite and rake marks, stereotypies (abnormal, repetitive behaviours), confinement, self-mutilation, physical attributes (such as weight, eyes, dentition) and health (such as immune related issues, pathogens, etc.).


Comment 27:

Aggression, marks, bites and other wounds caused by interactions with other killer whales are commonly known as “rake marks.” In 1999, Dr. Visser herself published a report entitled “Prolific body scars and collapsing dorsal fins on killer whales (Orcinus orca) in New Zealand waters.”     Abundant literature and photo identification catalogues prove that such scars or “rake marks” are common in wild cetaceans. 


The authors fails to mention this well-documented fact.  Nothing in her report indicates how many rake marks may have been present when Morgan was rescued or makes any scientific comparison to the “prolific body scars” found on killer whales in the wild.  Neither does she mention that multiple rake marks obviously occur in a single encounter, instead presenting the numbers as if each were the result of an “attack.”.   The authors appears to be prone to making comments that are dramatic and malicious but cannot be substantiated.


Page 33:


Table 2. Summary of breaches of minimal animal welfare standards, by Loro Parque. These are specifically with respect to orca. Violations are not mutually exclusive. See text for details.


Comment 28:

The table so summarize the breaches of minimal welfare standards was completed without that the C-Well literally cannot be used unless it is objectively and using the correct methodology. To obtain precise results it requires the assessor to follow the detailed methodology and spend a lot of time observing the animals and completing the actual measures, which of course it has not been the case of the report by Visser and Lisker. Besides, many of the considerations were wrong:


Excessive logging (not swimming)

The report does not have any behavioral observation, thus assuming that the logging of all the animals is excessive


In medical tank no shade:

It does not mean that this provokes thermal or physical discomfort, the medical pool is not used as a holding pool, animal just stay for short periods of time.


Inappropriate environment as no topography and no complexity:

Speculation, that would make us suppose that when orcas travel in ocean (with no topography or complexity) they should feel discomfort, which do not seems reasonable.


In medical tank no ability to exhibit complex movements: 

Irrelevant, the medical pool is not used as a holding pool, animal just stay for short periods of time.


In medical tank no swim speed, in other tanks significantly reduced:

Again, the medical pool is not used as a holding pool, animal just stay for short periods of time. Besides, which means significantly reduced? Orcas perform fast swim in the holding pools. How much reduced has to be the swim speed to become a welfare issue?


In medical tank no aerials: 

Again medical pool is not used as a holding pool, animal just stay for short periods of time.


eye mucous discharge likely symptom eye stress (sun/chemicals/water quality). Not according Dr. Lacave, “” Speculation


Minimal application of enrichment:

Speculation, the authors can not know what happens out of the presentation times as they just observed the animals for short periods of time during public presentations. During animal presentations the animals are not provided with enrichment as they are displaying documents by command, thus this observation is clearly biased.


Total wound from aggression:

The authors do not describe open wounds in their report.


Candidiasis(fungal infection) :

Not present during the observations


Eye mucous discharge likely symptom eye stress (sun/chemicals):

Not described as a pathology, according professional veterinarians


Dental procedures (Drilling, daily irrigation):

Speculates that the tooth care and dental hygiene of the animals is painful which is totally wrong. The drilling is a procedure realized with local anaesthesia, and the irrigation is a procedure that does not cause any pain or discomfort to the animals, that participate it voluntarily using positive reinforcement.


Inappropriate social grouping (Dysfunctional group, no matriarch, hybrids, wild-born …)

Speculation, the authors did not made systematic behavioural observation of the animals, any suggestion that the social grouping does not allow to express social behaviour is just speculation.


Abnormal social behaviour prevalent (e.g., excessive aggression, inbreeding) Behaviourally speaking inbreeding is not an abnormal behaviour, it is an unwanted situation from the genetic point of view, but copulation is not abnormal behaviour. on the other hand the authors did not made systematic behavioural observation of the animals, any suggestion about the abnormal prevalence of aggression is an speculation, specially because there are no scientific references in what is the prevalence of aggression in the wild orcas.


Multiple incident os attacks on trainers, including a fatality:

The authors fail in the correct use of this methodology that tries to measure the welfare of an animal in a particular moment, thus the information used must be recent. An accident happened years before cannot be used as a data to assess the actual welfare status of an animal. The authors do not describe  recent indecent, attacks or agonistic behaviours directed to the trainers.



Page 34:


Unfortunately, they are also inappropriately used for segregation and / or as holding tanks.

Comment 29:

Authors fail to support this argument with the procedures to obtain an appropriate use of the holding tank. Thus there is no way to establish if the use is inappropriate.



Page 34:


Therefore, with the exception of short desensitisation sessions, medical tanks should only be used for medical events as they are absolutely unsuitable for persistent use as holding tanks.

Comment 30:

The authors do not define what is short (in time units) its really hard to establish if the actual use of the medical pool is appropriate with such an imprecise term. The authors do not support their statements with any documentation.



Page 35:


Using a medical tank for holding orca is incompatible with, and in direct conflict of the animals’ welfare, i.e., it prevents an orca from the freedom to express both fundamental natural body postures and normal behaviour. Such a violation is an unequivocal contravention of the most basic animal welfare standards; .


Comment 31:

Loro Parque does not use the medical pool as a holding pool suggesting the contrary based in a few observations made during animal presentations (accounting less than 10% of the day) is simply absurd. It is absurd to waste several pages of the report comparing lengths of the animal, speculating with the size of the pool or the water depth in different situations when the authors do not have a clue about the time that a particular animal is holding in the medical pool.


Page 36:


Whilst locked in the medical tank Visser & Lisker have observed Morgan floating in an apparent catatonic state, not responding to her surroundings, as well as chewing repeatedly on the concrete walls of the tank.


Page 37:


They somehow fail to see that Morgan is doing anything but remaining quiet. Furthermore, anyone with even the most basic understanding of animal behaviour can recognise that the thrashing, strident calling and smashing into the gates is far from ‘normal’, ‘natural’ or even a ‘trained’ behaviour. Keeping Morgan locked in the medical tank when she shows substantial anguish and stress is another violation of one of the Five Freedoms, in this case the right to “Freedom from fear and distress”.



Comment 32:

The authors emphasize two contradictory observations, one about Morgan being catatonic in the medical pool and in the next page anguish and stress by smashing into the gates. This is again a demonstration that the observations made by the authors did not have any scientific methodology, but they are just exaggerating situations instead of analyze carefully the prevalence of the different behaviours of the animal and then comparing them with others.



Page 38:


Clegg et al (2015), when looking at the welfare of bottlenose dolphins in captivity used ‘shade’ as one of the indicators to assess ‘good housing’.



Comment 33:

Shade does mean that all the facility should be shaded, but that shade opportunities are provided.



Page 38:


It can only be speculated as to why the orca at Loro Parque should frequently have their eyes closed but the lack of shade must certainly be considered, as must the chemical additives which are used to treat the water at Loro Parque. .



Comment 34:

There are other reasons that can be considered, for example the large amount of time that the captive killer whales spend surfacing compared with their wild counterparts, which exposes the eyes more time to a dry environment (air) that can be compensated for a mechanism (Lacave).



Page 45:


The potential for a violation of the CITES transport permit (see Spiegl & Visser 2015, for details) and a ‘mistaken’ pregnancy to occur are naturally high when a sexually mature male is kept with a sexually mature female (Morgan has been reported to be ovulating32).


Comment 35:

False, there is no limitation in the CITES permit of Morgan about breeding. Spiel & Visser (2015) made a particular interpretation of the CITES permit that has not been publicly acknowledged by any CITES authority, no CITES authority has addressed Loro Parque to express any concern about the management of Morgan nor to limit breeding or public display.



Page 45:


The recent observations (April 2016) by Visser & Lisker have illustrated, again, that there are welfare discrepancies between the official Loro Parque statements and the actual situation.


Comment 36:

The authors affirmations are not in discrepancy with Loro Parque statements, but with the health certificates made by several independent international veterinarians with extensive experience taking care of cetaceans.



Page 45:


For instance, she has been observed ‘lunging’ high out of the water when coming to ‘station’ (Figure 21a). It is unclear why she does this, however such behaviour may indicate that Morgan is extremely hungry.


Comment 37:

Speculation, authors fail to discuss the weight trend of Morgan which is publicly available in the website.



Page 46:


‘Begging’ is a behaviour that has not been reported in the scientific literature for wild orca. .


Comment 38:




Page 48:


subjected to excessive sexual pressure from at least one of the male orca (see details above). .


Comment 39:

Is an speculation, how can it be determined what is excessive sexual pressure. What is considered normal sexual pressure in the wild?




Page 50:


The Visser (2012) report noted, inter alia, the frequency of attacks (Morgan was at least 100 times more likely to be attacked at Loro Parque than orca in another study) and the extent of the bite marks (Morgan was inflicted with more than 320 puncture and bite marks, all documented by photographs). She exhibited self-inflicted mutilations from abnormal and repetitive behaviours such as banging her head on the concrete walls – all of which are strong indicators that there is compromised welfare for this individual. .


Comment 40:

There was no definition of aggression in the report by Dr. Visser, so it is not possible to compare her results with any scientific literature. Despite the unprecedented lacking of description by Dr. Visser on the central element of her report, there were several details suggesting that the concept of aggression is totally different in both studies.


Aggression, marks, bites and other wounds caused by interactions with other killer whales are commonly known as “rake marks.” In 1999, Dr. Visser herself published a report entitled “Prolific body scars and collapsing dorsal fins on killer whales (Orcinus orca) in New Zealand waters.”     Abundant literature and photo identification catalogues prove that such scars or “rake marks” are common in wild cetaceans. 


The authors fails to mention this well-documented fact.  Nothing in her report indicates how many rake marks may have been present when Morgan was rescued or makes any scientific comparison to the “prolific body scars” found on killer whales in the wild.  Neither does she mention that multiple rake marks obviously occur in a single encounter, instead presenting the numbers as if each were the result of an “attack.”.   The authors appears to be prone to making comments that are dramatic and malicious but cannot be substantiated.




Page 50:


Therefore, the evidence presented herein was severely limited by the behaviour of the training staff who, typically and almost immediately, moved Morgan into the medical tank each time the authors arrived into the stadium area prior to a show. By containing Morgan in the medical tank the staff severely restricted photographic opportunities. Moreover, the staff insisted that the authors could not take photographs in the public areas adjacent to the seating area of the stadium (i.e., alongside the east tank and closer to the medical tank). Attempts such as these are highly suggestive of a desire to hide any number of issues that would be revealed by clear photographs. Despite such endeavours to prevent data collection, a small number of images were collected of Morgan (e.g., of her teeth Figure 4a-b). .


Comment 41:

The authors fail to mention that they were granted to access the stadium after one show with Morgan in A pool for their only observation and with the veterinary staff answering their questions.


Page 52:


Keto also exhibits ‘pock marks’ of unknown origin which are clearly visible on the paler pigmentation of his saddle patch (Figure 28a-b). On the 22 April 2016 he also had two patches of skin anomalies on his right caudal peduncle (between the flank patch and the fluke inserts) that aetiology of these injuries is unknown and they may be from a skin disease or from rubbing against a hard surface (Figure 29a-b).


Comment 42:




Page 52:


It is unclear if such wrinkling on Keto’s skin is indicative of electrolyte imbalances or the initial stages of dehydration, however given that the wrinkling is only clearly visible on an isolated area of his body there is likely to be some other underlying issue(s) at hand. Regardless, the cause cannot be confirmed without further diagnostics, including standard serum chemistry and complete blood count panels assessed through an accredited laboratory and only if bloods were taken and analysed on these particular days. ).


Comment 43:





Page 59:


Assessments by local authorities are not identifying the very same issues that can be seen by anyone who stands in the public viewing areas. Health assessments by a veterinarian (who has a long-standing history with Loro Parque) and by those currently working at the facility, show extreme divergence from the documented evidence collected from the public viewing areas.


Comment 44:

The authors are accusing the local authorities of lack of knowledge or breaking the law, any of these accusations must be substantiated with documentation.



Page 59:


Without a completely independent assessment, it is impossible to ascertain the full extent of the compromised welfare of these animals. Such an assessment should be carried out over a number of days and not be restricted by access (i.e., not restricted to show times nor to only the location of the public viewing area) and should only be conducted by an expert very experienced with wild and captive orca behaviour as well as welfare. Furthermore, a thorough and open-book inspection of the daily behavioural records, the daily feeding schedules and the detailed medical records and any other relevant notes regarding each individual will help to clarify those welfare issues identified but also to discover additional welfare issues that are not necessarily apparent from observations of the animals themselves.


Comment 45:

The only inspectors that can audit LP are the local authorities, suggesting that the local authorities are not independent must be substantiated with documentation.



[1] See e.g., Ford, J. K., Ellis, G. M., Matkin, C. O., Wetklo, M. H., Barrett-Lennard, L. G., & Withler, R. E. (2011). Shark predation and tooth wear in a population of northeastern Pacific killer whales. Aquatic Biology, 11(3), 213-224; Rica, C. (1996). A report of killer whales (Orcinus orca) feeding on a carcharhinid shark in Costa Rica. Marine Mammal Science, 12(4), 606-611.