A Primer on Writing the AZA to Deny SeaWorld Accreditation

If you’re a SeaWorld fan or supporter, you should head over to Awesome Ocean or another of your beloved fan sites.  This post is not for you.

I’ll lay out my position at the very start – I’m not at all opposed to you writing to the AZA in an effort to cause SeaWorld to lose its accreditation.  I believe that people should follow their hearts, and if your heart says that the animals there live in horrible conditions, then follow it.

But be cautious with your letter.  Writing the AZA is not like sending letters or petitions to AAA or Southwest in efforts to get them to end their partnerships with SeaWorld.  The AZA is one of a number of industry associations representing zoos and aquariums, and you need to take that into account when writing your letter of concern.

First, it’s important to remember that the term “animal rights extremist” was not coined by SeaWorld.  It’s been used throughout the zoo community for quite some time.  So don’t mention PETA or cite any of its websites.  The zoo community as a whole is not a fan of PETA and its tactics.  If you’re going to cite a veterinarian, chose someone with far more experience working with wild and exotic animals than PETA’s Heather Rally, who is less than a year out of veterinary school.  Two women I really admire who are good to quote are Naomi Rose and Ingrid Visser, though I’m not certain how the AZA will accept them because of their crusades to end captivity, and Dr. Rose may be a tougher sell due to her involvement with AB-2140 (more on that later).  Two other good candidates for quotes who have great relationships with AZA zoos and aquariums are Sylvia Earle and Jane Goodall.

Second, the accreditation is for the entire park, so you’ll want to express your concern over a number of animal enclosures, including those for pinnipeds, reptiles, birds – not just the orcas.  Although the AZA has unique guidelines for elephant exhibits and husbandry, it does not for orcas.  The three SeaWorld parks are the only AZA members with orcas, and therefore SeaWorld has established the standard for the Association as a whole.

Third and most important, word your letter carefully.  To the zoo community, there is a big difference between “animal rights” and “animal welfare.”  The goal of animal welfare is to improve the conditions of the exhibit space and the husbandry of the animals.  The goal of animal rights is to remove the animals from captivity altogether – which is in direct contradiction to the purpose of zoos and aquariums.  Letters that have an overtly animal rights tone may not be taken seriously by the AZA.

Fourth, avoid any mention of California’s AB-2140 Orca Safety and Welfare Bill.  Jim Maddy, the President and CEO of the AZA flew to Sacramento and stood before the California Assembly Water, Parks, and Wildlife Committee to express his opposition to the bill on behalf of all of the AZA’s California members.  Lecturing the AZA on why a bill they are opposed to is a good thing will likely get your letter placed at the bottom of the pile, especially if you attempt to write about the bill while failing to note the AZA’s objection to it, showing that you really haven’t paid that much attention to the bill and its proceedings.

Fifth, the accreditations are not for SeaWorld as a corporate entity, but for the individual San Diego and Orlando parks. Sending individual letters for each park will provide a better assist to the committee in making its decisions than an overriding letter about the parent company’s policies.  It may also be worth your while to spend your funds and visit one or both of the parks up for accreditation.  First person accounts go much farther than third person citations, especially if the source material involves the animal rights movement.

Finally, the letters should be site and time specific.  Only the San Diego and Orlando parks are being evaluated.  Any other parks owned by SeaWorld, such as San Antonio or Tampa, or parks or aquariums where SeaWorld animals are or have been on loan, such as the Georgia Aquarium, Marineland of Canada, or Loro Parque, are irrelevant.  The committee is also only concerned with the current situation at the two parks.  Do not include incidents or policies more than five year old and do not include any future planned projects, including the Blue World Project orca habitats.

One of the more popular form letters going around was posted on change.org.  The author intends it to have double the impact, with the intention that British Airways will drop its alliance with SeaWorld if the parks lose accreditation.  I commend her for her forward thinking.  This letter is a perfect example – as in a perfect example of how not to write a letter to the AZA.  Let’s take a look.

The author separates the letter into sections based on different aspects of the AZA Accreditation Standards.

  • “Animals must be managed as appropriate for long-term genetic viability of the species, which means careful planning of resource allocation, exsitu breeding, and ex-situ/in-situ conservation and research.”

The author begins by referring to orcas at Loro Parque, Spain.  These orcas are irrelevant to the accreditation process as they reside at neither the San Diego nor Orlando parks undergoing inspection.  She then offers a link to the Captive Cetaceans website, one I myself use often as a reference, but one that is obviously opposed to SeaWorld. The linked post on Captive Cetaceans does not cite any supporting documentation, research papers, or researchers working in the field with orcas to back up its data. Finally, the author only addresses orcas and not other animals in the parks.

  • “All animals must be housed in enclosures and in appropriate groupings which meet their physical, psychological, and social needs.”

This response entails a number of valid concerns that have been addressed by the public.  The problems, as in the above section, remain an emphasis on orcas instead of inclusion of other animals and the mention of Loro Parque.  Only care in San Diego and Orlando are relevant.  Anything that happened to SeaWorld orcas in San Antonio, Canada, or Spain are irrelevant to this accreditation process.

  • “Also, providing program animals with choices and control over their environment (e.g., whether they want to participate in a program on any given day), where and when appropriate, is essential to ensuring effective care and management.”

The author quotes former SeaWorld trainer Jeff Ventre from a blog post on the WDC website.  Mr. Ventre left SeaWorld in 1995.  While his experience has proven relevant in the world of public opinion, Mr. Ventre is recounting his experiences from 20 or more years ago in this statement, which makes it irrelevant to the AZA’s accreditation process.  A quote from a trainer who has left during the past few years, such as John Hargrove, Bridgette Pirtle, or Branden Loetz would be more time appropriate to the investigation.  The AZA is concerned with current procedures, not with what occurred 20 years ago.

  • “The animals must be protected from weather or other environmental conditions clearly known to be detrimental to their health.”

The author responds by stating that captivity itself is detrimental to the life of orcas.  This is the wrong thing to state to an association whose entire existence is based on captivity.  And, as before, the author concentrates solely on orcas, ignoring other animals in the parks.

  • “Institutions that acquire aquatic animals from the wild will make a good faith effort to determine that collecting procedures are done in a sustainable manner”

The response centers on the capture of the Southern Resident killer whales in the 1960’s and 1970’s.  Not only are British Columbian and Icelandic captures ignored, but anything before the turn of the 21st century is pretty much irrelevant to the inquiry.  The AZA is not interested in what took place in the past.  It’s interested in how the parks currently handle captures, which also include their large collections of fish and birds.  If the AZA went back and accredited each and every zoo based on the methods of acquisition that took place decades and, in some cases, centuries ago, it would end up denying the majority membership.

  • “Institutions dealing with commercial collectors must determine that the collectors are properly permitted to conduct legal collections of animals (including aquatic animals) from the wild.”

The response to this section is almost identical to the above and contains the same faults.

  • “The animal is used in a respectful, safe manner and in a manner that does not misrepresent or degrade the animal.”

Although the dorsal fin collapse argument is valid, the lifespan argument does not address this particular AZA standard. Orcas have only been in captivity for the last 51 years.  It is impossible, therefore, for a single captive orca to have reached the same age as wild counterparts.  Besides, the AZA is concerned with the current situation, not the overall 51-year situation.  The current situation includes orcas that are in their 30’s and 40’s, well on their way to matching their wild counterparts. On another note, the author fails to address how the animals are not used in a respectful and safe manner or are degraded.  This is where choreographed shows with blaring music and lights for entertainment purposes might be addressed – something that does not appear anywhere in this letter.

So what can we expect the outcome of this letter writing campaign to be?

  • If the majority of letters are like the one above, they will likely have a minimal impact and the two SeaWorld parks will be reaccredited.
  • However, the committee could take into account some of the points made about orcas in SeaWorld’s care and place the parks on table accreditations.  These provisional one-year actions allow the parks to retain their accreditations while fixes are made. They’re followed by a follow-up inspection and second hearing.
  • If the AZA opts to deny the membership altogether, the parks will have 60 days to appeal.  Once the appeal is denied, they will have to wait a full year from the date of the original denial to reapply for accreditation.  Although this won’t result in the death of animals as some have claimed, it will result in the loss of AZA program privileges, including staff and animal exchanges and participation in Species Survival Plans, which will affect mostly non-mammalian animals in the SeaWorld collection.  However, this loss will be offset by their memberships in WAZA and AMMPA and by their individual relationships with other zoos and aquariums.
  • If they lose both AZA and WAZA membership, they will retain their AMMPA membership, which will place them in the same league as the Miami Seaquarium.
  • Or they could opt to join the ZAA on top of the AMMPA membership.  ZAA is the other major zoo and aquarium trade association in the United States.  Its rules are more lenient than the AZA with regards to breeding and visitor interaction.  This would place SeaWorld on the same membership and accreditation level as Six Flags Discovery Kingdom.

The best advice I can give is don’t write your letter like the one above.  The author attempted to address the principles behind the standards.  But that’s not what the investigation team and the committee are looking at.

If you want to have an extremely effective letter, you need to address almost all of the Areas of Primary Focus starting on the bottom of Page 32 of the 2015 AZA Guide to Accreditation.  And the only way to effectively to do this is to visit the parks and ask the staff questions.  When animal activists like Ric O’Barry, Naomi Watts, Ingrid Visser, Russ Rector, and others, want to know exactly what shape things are in, they go and see it first hand.  It will be painful to fork over your money to a company your detest and it will be painful to experience animals in conditions you find hideous, so bring a few hundred extra dollars with you.  You’re going to need a side trip to a Disney park afterwards to bring the happy back into your life.  But you’ll also be bringing a very effective letter to life.