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.
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population, which logistically would be the only realistic option for capture, numbers fewer than 100 individuals (NDP unpublished data), making them one of Namibia's rarest mammal species.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 againstkeeping 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.
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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.
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