An Open Letter to Members of the Senate Committee on Fisheries and Oceans

An Open Letter to Members of the Senate Committee on Fisheries and Oceans

Dear Senator:

On behalf of Canada’s Accredited Zoos and Aquariums, I am writing to urge members of the Senate Committee on Fisheries and Oceans to vote to end Bill S-203. The proposed legislation intends to end the captivity of cetaceans, but would in fact have a profoundly negative impact on our ability to protect whales and dolphins by criminalizing scientific research and rescue and rehabilitation programs.

CAZA was founded in 1976 and today represents the leading zoological parks and aquariums in Canada. Over 12 million people visit our 31 institutions each year. As the leading animal welfare organization in Canada responsible for developing and enforcing animal welfare standards, our organization ensures the continuing evolution of Canadian zoos and aquariums as ethical agencies of learning, species conservation, and science. Our standards are based on animal welfare science which is a bridge between pure science and ethics. CAZA regularly partners with governments, the academic community, and animal welfare partners to develop regulatory measures, scientific studies, and species survival programs.

Accredited zoos and aquariums offer critical elements in research and rescue efforts that other stakeholders simply can’t – space and skills. The accredited zoological community in Canada have only begun to scratch the surface of what we can do to save critically endangered species through research, breeding programs, and reintroduction programs with the teams of scientists’ biologists, and animal welfare experts who work around the clock in our facilities.

However, if passed, Bill S-203 stands to end much of this important work.

At the mercy of ideology, Bill S-203 will greatly inhibit the ability of accredited facilities to conserve, protect, and save Canada’s whales and dolphins –including critically endangered populations of beluga whales, killer whales, and right whales struggling to survive against the multiple assaults of underwater noise, overfishing and ship strikes.  The Bill would criminalize important work done to help us understand cetacean physiology, such as the work being done at the Vancouver Aquarium to understand hearing and acoustic communication in whales, their lung pulmonary functions, and diet and energy requirements. It would also stifle in-situ work which depends on the research done at the Aquarium such as rescue efforts to save the critically endangered vaquita porpoise, and measuring acoustic communication on beluga whales.

With a professional team made of up of veterinarians, scientists, and marine biologists who are on staff 24/7, the Vancouver Aquarium is the most trusted life line in Canada for injured and stranded marine mammals. Bill S-203 would criminalize them for rescuing and rehabilitating stranded or orphaned whales or dolphins too weak to make it on their own in open waters. If passed, Bill S-203 will force the accredited rescue program to euthanize the very animals they work to save.

As part of our continuous improvement model, CAZA actively engages with animal welfare experts, scientists, and veterinarians to modify, improve, and enforce our standards to reflect the latest research. In keeping with this principle, CAZA adopted the Canadian Council on Animal Care (CCAC) guidelines for the care and maintenance of marine mammals as part of its standards.

CCAC’s guidelines represent the most comprehensive, evidence-based framework for the keeping of marine mammals in the world, and they come with a requirement for institutions to promote species conservation through education and research.  It took the government over 10 years to procure, research, and create the CCAC guidelines. We urge Committee members to review these guidelines and create legislation to protect cetaceans which reflects the principle of the recommendations –promoting species survival in marine mammals though scientific research and educational opportunities that connect people with nature.

If one is searching for the ethical and moral foundations for aquariums and zoos, they will find them in the transformative potential of the personal connection between humans and animals. However, if Bill S-203 is adopted, for whales and dolphins at least, that work will stop and those connections will be severed.  By criminalizing research, education and conservation activities involving cetaceans, this Bill would not only end important research, but it would end the personal connections and journeys that could one day help to preserve the Beluga or the Right Whale, just as surely as they have the Black Footed Ferret.

Bill S-203 would dismiss 10 years of independent research commissioned by the Government of Canada itself to create monumental guidelines – guidelines which far surpass what we have seen globally, even from our neighbours in the United States.

So you may ask yourself why with federal and provincial oversite, is accreditation important?

You may be shocked to know that other than the CCAC guidelines on the keeping of Marine mammals; our country is absent a consistent, pan-Canadian approach to the keeping of exotic animals in human care. Absent formal coordination and information-sharing mechanisms – we are left with a hodgepodge of policies, legislation, and regulations that vary in each jurisdiction in Canada – not only in their scope but also how they are enforced.

We disagree with the proponents of this Bill on the road they’ve chosen to travel on, but we agree with them on this: cetaceans are creatures that, in our facilities as in nature, deserve and require our respect and our continued care. That is why we have members whose chosen path involves studying, protecting and healing these animals, striving to understand and decode their behaviours, and educating others so that a new cohort of scientists and conservationists will be there to continue their journey.

We urge you to keep that road open and clear for them.


Dr. Susan Shafer

Executive Director

Canada’s Accredited Zoos and Aquariums

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