Dr. Dag Encke is a Managing Director of the Nuremberg Zoo.
Dear ladies and gentlemen of “TripAdvisor Animal Welfare”
On 5 December we received the following e-mail from your company:
“Good afternoon Nuremberg Zoo,
Recently we announced that TripAdvisor Experiences and Viator from January 2020 on will stop selling tickets for all attractions that contribute to that future generations of cetaceans (whales, dolphins and porpoises) will continue to live in captivity.
As a result, any commercial entity that breeds or imports whales as a public attraction for exhibition is prohibited from January 2020 on to sell tickets on TripAdvisor and Viator. Some facilities qualify possibly for an exception status and thus may continue to distribute tickets through our platform.
We have identified the Nuremberg Zoo as a facility where cetaceans are presented to the public. Therefore, we are making every effort to determine whether your institution qualifies for the exceptional status or not.
The exceptional status shall be granted to anybody which meets one or more of the following criteria:
- Any cetacean protecting facility that provides a sustainable marine environment for all captive animals*
- Any commercial or non-profit organization that is currently developing alternative sanctuaries for captive cetaceans in the sea and that is publicly committed to adequately relocate all the animals in captivity that it owns to these environments.
- Any WAZA** accredited facility that has made an official and public commitment to implement all of the following practices:
- the termination and prohibition of the breeding of cetaceans in their possession
- the termination of the importation or transfer of captive cetaceans from other establishments for exhibition
- Stop the capture and importation of wild cetaceans for exhibition purposes
If the Nuremberg Zoo meets any of the above-mentioned criteria, you can request the exception status by answering this e-mail or send a reply by 20 December 2019 at the latest to email@example.com.
Your reply must include evidence of a request for exemption. If public commitments are cited as evidence by the institution, this must be in the form of either a press release or a report published by a reputable media company.
Please note that Nuremberg Zoo will continue to be listed as an attraction on TripAdvisor, regardless of whether it is eligible for the exceptional status or not. Travelers can continue to submit valuations, ratings and photos, and the facility will continue to be presented in the TripAdvisor rankings. Learn more about our animal welfare guidelines here.
If you have any questions about our policies or are unsure whether your institution is eligible for exemption status or not, please contact:
TripAdvisor Animal Welfare
*A marine protected area is a natural stretch of coastal water, such as a bay, where cetaceans live as naturally as possible, while providing protection and supervision by qualified livestock and veterinary personnel. Marine protected areas must comply with a strict Non-breeders policy, must not train their animals for shows or performances for the public and must prohibit all forms of physical interaction between guests and animals, including human-animal encounters in water.
**Accreditation must be granted by a member association of the World Association of Zoos and Aquariums (WAZA).”
Unfortunately, I can only answer your letter to my zoological garden impersonally, because you sent it to me without naming a concrete contact person. You had published the contents of this letter as a Global News Release in October 2019. Since your letter seems to be part of a public image campaign for your travel platform, I am answering you with the greatest possible transparency for your customers in the form of the Open Letter.
You have informed us that you will no longer be selling tickets for the Nuremberg Zoo because the Nuremberg Zoo keeps dolphins.
In your animal welfare guidelines, you refer to “scientific Evidence” that the keeping of dolphins is contrary to animal welfare. Animal welfare violations must be proven on the basis of concrete housing conditions and of specifically affected animals. The tool required for this purpose, “Animal Welfare Assessment”, is a scientific discipline. The assessment of the “Animal Welfare Status”, i.e. the individual well-being of dolphins, requires methodologically sound scientific methods that can be applied in each individual case. Your rejection of our animal husbandry lacks any reference to a concrete “Welfare Assessment”. You do not even mention which method of assessment you used for your evaluation.
I consider a blanket discrediting of the keeping of dolphins in my zoological institution to be dubious populism from a scientific point of view.
So, let me make this perfectly clear:
We are not applying to you for “exceptional status”. We reject your demands for professional reasons for the welfare of our animals.
At an international conference organized by the Nuremberg Zoo for the protection of dolphins in coastal and inland waters (ESOCC Meeting – Ex situ Options for Cetacean Conservation) last year, an integrated approach to the rescue of seven acutely endangered dolphin species was formulated, in line with the “One Plan Approach” and that identifies the keeping and research of endangered species under human care as a fixed and indispensable component of current protection strategies.
We can debate at many levels about best practices in the ex situ management of marine mammals, but it is irresponsible to call for a boycott of institutions, without whose expertise and without whose structural infrastructure it becomes more and more difficult and unlikely to protect endangered species successfully.
Your letter comes at an inopportune moment and shows great ignorance regarding options for action and soon probably constraints for action regarding the international conservation of dolphins living in coastal and inland waters.
In view of the great responsibility that we humans – and in a particularly piquant way also and especially the tourism industry – have for the ecological integrity of coastal and inland waters, I am shocked by the sloppiness of your letter, which is supposed to have been addressed to the well-being of dolphins, but in fact no research on concrete options for action has been carried out.
Negative report 1:
We are a nonprofit professional service of the city of Nuremberg, not a commercial institution.
TripAdvisor, on the other hand, is likely to be profit-oriented and more likely to be a commercial platform than a charitable one. Your approach suggests that your commitment to dolphins is primarily and very likely a marketing campaign for the image of your company.
Negative report 2:
A “permanent living environment” at the sea for “captive animals” is a nonsensical criterion for determining the quality of a facility. To my knowledge, there is no successful keeping under the conditions you describe. If the two belugas transported to Iceland will survive in the “sanctuary” that has been rebuilt for them will be shown when they are put out of their covered enclosure into the netted bay in spring 2020.
Negative report 3:
“Alternative sanctuaries” are currently being sought for seven highly endangered dolphin species. These ex situ options for endangered dolphin species are sensibly not being considered for the not yet threatened dolphins which already enjoy a very good and sheltered life under our care. If we want to invest in the future of dolphins, then we should support meaningful projects that benefit the survival of endangered species instead of demanding experiments with already well housed animals.
Negative report 4:
In your animal welfare policy, you refer exclusively to the welfare of individuals kept in captivity, but propose a translocation of animals to open sea cages. You are thus subject to the criteria of the IUCN guidelines on the release and/or translocation of wild animals. I am aware that these guidelines are not of a legislative nature. However, they are internationally recognized conservation standards that should be adhered to, because the improper release of wild animals poses a great risk both to affected natural habitats and to the animals themselves. I consider your simple ideas of animal welfare and nature to be misguided.
Negative report 5:
Stopping the breeding of cetaceans is a frivolous demand in terms of animal protection, which we do not want to comply with at all for the benefit of the animals and their social structure. Our institution serves the protection of species and the sustainable population management of the breeding groups kept by us and coordinated throughout Europe. Your demand is directed against the social needs of the animals. We reject this. Of course, we will continue exchange animals within the framework of the transboundary European Breeding Program.
Negative report 6:
Unfortunately, we cannot stop capturing animals from the wild because we have not done so for decades. Taking from the wild and trading in plants and animals are also regulated by CITES and fortunately are not aligned with the interests of the tourism industry. The EAZA Bottlenose Dolphin ex situ Program coordinates the population of bottlenose dolphins in scientifically managed zoos in Europe. Since 2003, no bottlenose dolphins from the wild have been introduced into the population. The population is growing sustainably and is entering the third generation in human hands.
From my point of view, you are playing a bad game with the popularity of moralizing animal protection in your poorly researched and potentially animal harming letter of demands, with which you rather damage technically the protection of the species and in no way benefit the welfare of the animals we keep.
I would be pleased if you would approach us in the future in a serious and cooperative manner if you have open questions about the welfare of our animals. Perhaps you would have refrained from writing if you had known our institution beforehand.
With kind regards
Dr. Dag Encke
Managing Director of the Nuremberg Zoo.