The following tips are among those published by the government to help you increase the impact of comments you submit concerning government regulations, but they are useful points to know any time you want your comments to have impact. (Tips for submitting effective comments).
- Although agencies receive and appreciate all comments, constructive comments (either positive or negative) are the most likely to have an influence.
- If you disagree with a proposed action, suggest an alternative (including not regulating at all) and include an explanation and/or analysis of how the alternative might meet the same objective or be more effective.
- The comment process is not a vote. The government is attempting to formulate the best policy, so when crafting a comment it is important that you adequately explain the reasoning behind your position.
- Identify credentials and experience that may distinguish your comments from others. If you are commenting in an area in which you have relevant personal or professional experience (i.e., scientist, attorney, fisherman, businessman, etc.) say so.
- Agency reviewers look for sound science and reasoning in the comments they receive. When possible, support your comment with substantive data, facts, and/or expert opinions. You may also provide personal experience in your comment, as may be appropriate. By supporting your arguments well you are more likely to influence the agency decision making.
- Consider including examples of how the proposed rule would impact you negatively or positively.
For instance, if you would like to comment on the application submitted to NOAA by the Georgia Aquarium to allow for the importation of belugas from the wild, think about just one or two aspects that you feel strongly about, and emphasize what makes your opinion unique – this is not the time to be modest. It all counts, from a particular memory to personal beliefs, everyone’s voice is important. As an example, in the application Georgia Aquarium submitted copies of handwritten thank-you notes from children (which we all remember having to do following field trips as children – so while sweet, the letters may not reflect what the child experienced at all, and a teacher, parent, or really anyone who went on those field trips and wrote the letters can comment upon).
- Circus appeal of their “educational” brochure.
Notice in this letter the use of a few simple points and the inclusion of qualifications, as suggested in the tips provided:
Statement Against Proposed Beluga Imports by the Georgia Aquarium
I would like to address three points – education, conservation, and the proposed living conditions – in which I feel that the Georgia Aquarium inaccurately portrays itself in its request to import wild belugas
The Georgia Aquarium misrepresents itself as an educational institution in an attempt to convince the public that deeming a display educational justifies the inhumane conditions which cetaceans are forced to endure in captivity.
While it can be exciting to view whales and dolphins up close in captivity, there is nothing authentically educational in the experience. The content of talks given by aquarium personnel and the accompanying graphics are muted and secondary when compared to the mesmerizing presence of the animals.
What is actually being learned is that there is nothing wrong with taking animals from the wild and keeping them in unnatural conditions. This kind of learning is due to “meta-communication”, defined as “Communication that indicates how verbal information should be interpreted; stimuli surrounding the verbal communication that also have meaning, which may or may not be congruent with that of, or support the verbal talk. It may support or contradict verbal communication.” Seeing these animals – which come with built-in smiles – leads people to think that the whales are happy and healthy.
In the Aquarium’s “Education & Guest Programs Guide 2011-2012” (provided in the application and found on page 307), founder and chairman Bernie Marcus writes “When I first envisioned the Georgia Aquarium, I knew it had to be educational, entertaining and it must help future generations gain an appreciation for our oceans and the organisms that live there. The Georgia Aquarium has become a remarkable resource serving to promote conservation and awareness to nearly 10 million people. By using the Aquarium as a true learning environment, guests are exposed to the many wonders of the rivers and oceans that surround us.”
Yet in an New York Times article dated 8/27/2012 the Aquarium’s Vice President for Education and Training, Brian Davis, describes the Georgia Aquarium’s contradictory stance on providing true education when he says “…to this day this institution ensures its guests will not hear the term global warming. Visitors are “very conservative,” he said. “When they hear certain terms, our guests shut down. We’ve seen it happen.”
Thus Georgia Aquarium blatantly states that their commitment to education goes as far as telling the public what they think the public wants to hear, despite Marcus’ prose.
Conservation and Living conditions:
The concept of taking wild animals into captivity in order to conserve a species is antiquated, and is based on 19th century thinking in which wild animals were often slaughtered for museums as the populations were otherwise decimated to near extinction. A case in point is that of the Elephant Seal (Mirounga Angustirostris), a species nearly wiped out in less than two decades:
“In 1892 a Smithsonian expedition to Guadalupe Island discovered 8 elephant seals. But these early expeditions didn’t seem to be interested as much in species preservation as they were in collecting these rare specimens for science. As a result they killed 7 of the seals to bring back to U.S. museums. Reports of this discovery by Charles H. Townsend of the New York Aquarium further reveal that as they were loading the seals in the boats the surf came up and they were forced to leave 4 of the 7 on the sand. Nice.
This was rock-bottom for the elephant seal. It’s estimated that only between 20 and 100 individuals existed at that time. For the next twenty years each scientific expedition to Guadalupe Island killed as many specimens as they could as demand for them in museums of natural history was great. And despite this the population slowly recovered.”
Removing animals for display has the identical effect on the remaining wild population as does killing the targeted individuals, and captivity reduces the quality of life for the individuals removed thus can limit any perceived benefit to the captive gene pool (due to reproductive failure resulting from stress).
Although the Georgia Aquarium argues that the tank sizes meet or exceed APHIS requirements, and that the water quality is closely monitored, they do not appear to attempt the duplication of the natural conditions for belugas.
On page 269 of the application, the data given as representing the natural environment of the belugas proposed for importation is reported as:
“Average annual surface water temperatures are 5 to 7 °C (41 to 44.6 °F) in the north and 2 to 3 °C (35.6 to 37.4 °F) in the south (UNEP 2006). From May to November, average monthly water temperatures remain above freezing (UNEP 2006). Surface water temperatures drop to -1.0 to -1.8 °C (30.2 to 28.8 °F) in the late winter months (February and March), resulting in large formations of sea ice. In the Sea of Okhotsk, there is significant variability in water temperature between surface and sub-surface areas. The Sea is characterized by a layer whose core is -2 °C (28 °F) because of severe cooling on the northern shelf in winter. This cold intermediate layer can persist throughout the warm season and it is a feature unique to the Sea of Okhotsk (Radchenko et al. 2010)”
Yet the Aquarium belugas’ are kept in relatively balmy and uniform 54 degree (F) water which is composed of a “seawater mix with a combination of major salts as found in the ocean”. However, fundamental to all life in the ocean is the fact that salinity and mineral content varies with many factors, and can define the ecological niche of marine wildlife.
Further, and possibly the most important factor with respect to the housing, is that belugas are unique among cetaceans in that they shed their epidermis in an annual molt, as opposed to the continual sloughing that is the case among other species. This is known to occur in concert with annual migrations to warmer and fresher water. The Aquarium in no way accommodates this factor in the maintenance of the belugas they already house, nor is there anything in this permit application to suggest that they not the other institutions hoping to receive the belugas have even considered this basic biological need.
I urge you to not allow wild caught belugas to be subjected to captivity, as there are no valid reasons in education or conservation for doing so.
Candace Calloway Whiting
Bachelor of Arts in Psychobiology
Post Baccalaureate of Science in Oceanography
Submitting Comments (the online form is quick and easy to use. Limited to 2000 characters or less in the text).
You may submit comments on this [Beluga Importation] document, identified by NOAA-NMFS-2012-0158, by any of the following methods:
- Online: Submit all electronic public comments via the Federal e-Rulemaking Portal: www.regulations.gov
- Mail: Submit written comments to:
Chief, Permits and Conservation Division
Office of Protected Resources
1315 East-West Highway, Room 13705
Silver Spring, MD 20910
- Fax: 301-713-0376; Attn: Jennifer Skidmore
Instructions: Comments must be submitted by one of the above methods to ensure that the comments are received, documented, and considered by NOAA Fisheries. Comments sent by any other method, to any other address or individual, or received after the end of the comment period, may not be considered. All comments received are a part of the public record and will generally be posted for public viewing on www.regulations.gov without change. All personal identifying information (e.g., name, address, etc.) submitted voluntarily by the sender will be publicly accessible. Do not submit confidential business information, or otherwise sensitive or protected information. NOAA Fisheries will accept anonymous comments (enter “N/A” in the required fields if you wish to remain anonymous). Attachments to electronic comments will be accepted in Microsoft Word, Microsoft Excel, WordPerfect, or Adobe PDF file formats only.