29 September 2016
To: The Permanent Secretary,
Namibian Ministry of Fisheries and Marine Resources
Request to deny permission to
capture live dolphins, penguins and seals in Namibia
Dear Dr Maurihungirire
We are writing to you on behalf of the Namibian Dolphin Project (NDP) and our sister organisation, Sea Search, to voice our concerns over the recent proposal from the Welwitschia Aquatic and Wildlife Scientific Research Pty Ltd (WAWSR) concerning the live capture of marine animals in Namibia for the aquarium industry. We strongly urge you to reject this proposal and not allow the capture of any marine animals for reasons detailed below.
We are writing to you on behalf of the Namibian Dolphin Project (NDP) and our sister organisation, Sea Search, to voice our concerns over the recent proposal from the Welwitschia Aquatic and Wildlife Scientific Research Pty Ltd (WAWSR) concerning the live capture of marine animals in Namibia for the aquarium industry. We strongly urge you to reject this proposal and not allow the capture of any marine animals for reasons detailed below.
Scientific Merit
WAWSR claims that the main purpose of this proposal is
to “promote scientific research” and
help Namibia gather information on the impact marine mammals have on the
Namibian fish stocks. Given the wording of this proposal, and indeed the
company name, one would expect that this proposal would be based on sound
scientific evidence; however, nothing in this proposal would suggest that this
is the case. For example, WAWSR proposes to capture 50-100* Indo-Pacific
bottlenose dolphin, a species which does not occur anywhere near Namibia (their
range being to the east of Cape Town, South Africa (Findlay et al. 1992). WAWSR also proposes to
capture 50-100 common bottlenose dolphins, which are resident in Namibia.
However, the inshore population, which logistically would be the only realistic
option for capture, numbers fewer than 100 individuals (NDP unpublished data),
making them one of Namibia's rarest mammal species. If WAWSR capture the upper
limit of their proposed number (100), it would effectively wipe out this entire
population of animals. Even if they were to capture the lower limit (50), it would
likely have dire consequences for an already small and sensitive population,
possibly resulting in local extinction of this species from coastal Namibia. It
is clear that this proposal has little or no scientific foundation, and
therefore to suggest that this is for anything other than making profit, is irrational.
International Legislation
We believe that the proposal directly contravenes the
Convention on International Trade in Endangered Species of Wild Fauna and Flora
(CITES). The African penguin, which WAWSR proposes to capture between 300-500
of, is listed under the International Union for Conservation of Nature’s (IUCN)
Red List of Threatened Species as “Endangered”, with estimates suggesting that
it has decreased by more than 60% over the last 28 years. WAWSR also propose to
capture “various sharks”, given that
the IUCN suggest that one quarter of all known species are threatened by
extinction, it is highly plausible that some of the species WAWSR propose to
capture, are included in this listing. The other animals listed by WAWSR, such
as Heaviside's dolphins and killer whale are listed by the IUCN as "data
deficient", and in such scenarios a precautionary principal should be
taken as there is little or no information on population abundance or trends
Captive Cetacean Industry
The argument against
keeping marine mammals in captivity for educational purposes has gained a lot
of support in recent years from the scientific literature. Killer whales, of which
WAWSR have proposed to capture 10 per year, have been shown to live shorter
lives in captivity compared to their wild counter parts (Jett and Ventre 2015)
and often face poor cramped conditions, while Fair et al. (2014) suggested the increase in stress levels induced
during live capture could have major negative consequences on individual
cetaceans. Additionally, there is little strength to the argument that captive
animals provide unique opportunities for research as the vast majority of scientific
literature on cetaceans in the last 10 years at least has come from studying
animals in the wild, something the NDP has been doing in Namibia since 2008.
Whales and dolphins have long term, individual based
relationships and learn behaviours though cultural transmission. The random removal of individuals can break
up these long lasting associations influencing the cohesion of the remaining
wild population. The removal of animals can be incredibly stressful for the
remaining group associates and could reduce the overall health and fitness of
the wild population.

Should you need any further information on the whales and dolphins of Namibia, our work specifically, or wish to discuss any of the concerns highlighted, please do not hesitate to contact me.
Yours sincerely,
Dr. Simon Elwen, Director - Namibian Dolphin Project, Director Sea Search Africa
NRF Research Fellow, Mammal Research Institute,
University of Pretoria
on behalf of the Namibian Dolphin Project & Sea
Search teams
Dr Tess Gridley, Dr Els Vermeulen, Ms Bridget James, Ms
Morgan Martin and Mr Barry Mc Govern
References
Fair, P.A., Schaefer, A.A., Romano, T.A., Bossart,
G.D., Lamb, S.V. and Reif, J. (2014) Stress response of wild bottlenose dolphins (Tursiops
truncatus) during capture–release health assessment
studies Original Research Article. General and Comparative
Endocrinology. 206 203-212
Findlay, K. P., Best, P. B.,
Ross, G. J. B., & Cockcroft, V. G. (1992). The distribution of small
odontocete cetaceans off the coasts of South Africa and Namibia. South African Journal of Marine Science.
12(1), 237-270.
Jett, J. and Ventre, J. (2015) Captive killer whale (Orcinus orca) survival. Marine Mammal Science. 31 4 1362-1377.
*It is not clear from the poor wording of the proposal whether killer
whales are the only species to be targeted in subsequent years “10
killer whales per year; 50-100 Indo-Pacific bottlenose dolphins; 50-100 heads
of Common bottlenose dolphins; 500-1000 Cape fur seals; 300-500 penguins; and
various sharks.”. As such,
we have drafted this letter using the more conservative idea that they do not
intend to target all other species in subsequent years. However, it is highly
likely that WAWSR do intend to capture all species in subsequent years.
12 comments:
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