Dolphins' importation

The Biological Conservation Research Foundation (Bicref) would like to reply to the letter by Ray Bezzina, on behalf of the Ministry of Rural Affairs and the Environment (September 17).

In connection with the new marine mammal regulations issued on August 12, only days before the arrival in Malta (on August 31) of six dolphins caught from Cuban waters, Bicref would like to highlight at least one important change between the regulations contained in LN 77, issued in 1992, and the new regulations laid down by LN 203 of 2003.

Specifically the addition of paragraph 7(1)d which states: 'The competent authority may issue a permit to authorise: the performance of any activity which would otherwise not be permitted under these regulations to dolphinaria or oceanaria, which at the time of the coming into force of these regulations are already in possession of live specimens, provided that such permit is limited to the replacement or replenishment of the specimens".

This statement may have encouraged the replacement or replenishment of specimens in the local dolphinarium with the added drawback that rather than replacing the three Black Sea bottlenose dolphins that died at the dolphinarium with another three from some other captive group, six Cuban bottlenose dolphins have been imported after being caught from the wild.

Of course, Bicref may also indicate several biological reasons why such importation is not proper and that is why we have advised caution. Local authorities should seek advice or consultation on the setting up of such regulations in the future.

Moreover, a very important issue that Bicref stresses is the impact of the removal of individuals from the wild especially without accurate knowledge of the status of the dolphin population at the site of capture. Under Cites, to which Malta is party, Cuba should have issued what is called a non-detriment finding to demonstrate that the export would not cause detriment to the survival of the species.

A Cites resolution on the designation and role of scientific authorities notes that the "issuance of permits by a management authority without appropriate scientific authority findings constitutes a lack of compliance with the provisions of the convention and seriously undermines species conservation".

The resolution recommends that "the findings and advice of the scientific authority of the country of export be based on the scientific review of available information on the population status". Since Cuba does not seem to have such dedicated dolphin research, how would it provide the scientific data required to determine and confirm a non-detriment to the species? Did the Maltese competent authority issuing the import permit ask for such scientific data to make sure that its importation would not deplete a wild and vulnerable population of bottlenose dolphins in Cuban waters?

Lastly, we regret to note that environmental issues are being overloaded with fears of job losses. It is important to stress that when Malta considers abiding or becoming party to conventions and environment agreements it surely should take into consideration the assessment of the possible impacts of these on job losses or job changes. An important international understanding is that while humans are capable to adapt to new job requirements, the extinction of a species is forever.