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MMIR Deficiencies

The National Marine Fisheries Service continues to issue permits for the capture, import, export and transfers of marine mammals, including killer whales, despite failures in compliance with Marine Mammal Protection Act (MMPA) requirements. Help us change that!

Read The Orca Project’s complete report on this issue here:

NOAA-NMFS Failures in Marine Mammal Inventory Management for Killer Whales

How to Help:

Copy and paste the following letter into your email program and send to the individuals and organizations listed below (feel free to edit and personalize as you see fit). Remember to sign your name and location at the end:

RE:      Marine Mammal Inventory Management Deficiencies

Dear Decision Maker,

Since the 1972 implementation of the Marine Mammal Protection Act (MMPA), the National Marine Fisheries Service (NMFS) has had jurisdiction over the capture, export, import, and public display of all cetaceans and pinnipeds (killer whales, dolphins, seals, sea lions, and the like, with some exceptions) and the issuance of permits to satisfy the MMPA. Additionally, the NMFS is required to maintain an inventory of marine mammals held in public display facilities.

An audit of NMFS Marine Mammal Inventory Reports (MMIRs) has revealed the shockingly sparse data contained within the database in regard to killer whales (Orcinus orca). For nearly 40 years, NMFS has tracked the status of more than 7,400 individual marine mammals, yet only 1.4% of those consist of the relatively small population of 103 orcas for which NMFS maintains records. The historical and current record keeping for killer whales has been found to be grossly inadequate.

One would assume that data compiled by the sole government oversight agency charged with this task would be thorough and complete—especially where it concerns large, intelligent, sentient beings such as orcas. However, these inadequacies are just the tip of the iceberg: Data deficiencies appear to be widespread throughout the NMFS inventory information about the thousands of dolphins, seals, sea lions, and other marine mammals.

A database of orca inventory information has been reconstructed by The Orca Project to simulate the NMFS MMIR database, incorporating “unknown,” blank, missing, or incorrect data into the orca inventories through historical record research. The scarcity of data readily available from the NMFS is quickly apparent from this reconstruction, and the extent of information that has not been recorded is alarming.

After data is incorporated from external sources and historical records into the existing records on file with NMFS, the following statistics are produced:

Of the 103 orcas on file with NMFS:

  • 33 are still alive (21 in U.S. parks, 12 in foreign countries).
  • 69 are deceased. 15 of these 69 are still shown as living by NMFS. 4 of these 69 are listed as dead, but no cause of death is given. One orca (Keiko) was released.
  • 35 orcas were born in captivity, 67 were wild captures, and 1 (Sandy) was beached/stranded.
  • 20 are listed as from “unknown” origins, and many are currently listed in “unknown” facilities by NMFS.
  • Approx 24 orcas tracked by NMFS have never been in the United States (before or after capture).
  • Orcas passed through approximately 58 marine parks, aquariums, and holding areas—only approximately 25 of which can be found through MMIR data.
  • 37 of the 103 orcas spent time at Saedyrasafnid Aquarium in Iceland after their capture before being shipped to other destinations, but there is not a single report of this facility in the MMIRs (although information about a few may exist in import permit data).
  • There have been 224 transfers/imports of orcas. NMFS records show only 43 transfers and 24 imports for a total of 67 (import permits may indicate some prior movements).
  • The purpose reported for all captive orcas has been public display, with the exception of two unnamed orcas taken for “scientific research” in 1997 in Taiji, Japan. Both of those orcas died within 4 months.

In addition to the statistics listed above, no MMIR data exists for the following 123 orcas:

  • An additional 32 orcas have been captured in, rescued from, born in, or transferred to the United States, for which no MMIR data exists. 3 were released, 1 escaped, and 28 are deceased.
  • An additional 20 captive-born orcas, which are the progeny of orcas on file and tracked by NMFS, have no MMIR data and are not recorded with NMFS as required by USC § 1374 Sec 104 (c) (10). 14 are deceased, and 6 are living.
  • An additional 26 orcas have spent time at facilities on file with NMFS. No MMIR data exists for these 26 orcas. 25 are deceased, and 1 is living.
  • Additionally, there have been 28 unsuccessful orca births (miscarried, stillborn, or otherwise unsuccessful) at NMFS-monitored facilities. NMFS has not been required to maintain records on unsuccessful births.
  • For informational purposes, 17 orcas reside or resided at foreign facilities that are currently in operation for which NMFS may have oversight on future transactions. None of these facilities or orcas are on file with NMFS. No MMIR data exists for these 17 orcas (14 deceased, 1 living, and 2 unsuccessful births).

It is the intent of this study and report to recommend to the governing bodies of the MMPA that no further permits be issued to any active marine mammal park, aquarium, facility, or permit holder for the capture, import, export, or transfer of marine mammals until all outstanding incomplete data is updated.

Additionally, numerous facilities in the United States and abroad (including the largest holder of marine mammals in the United States, SeaWorld) have not complied by failing to provide the inventory data required to maintain previously issued permits and should immediately be excluded from any future permits until the requirements set forth above have been satisfied.

It is not reasonable to approve, grant, or maintain permits for facilities that are not in compliance with the MMPA and do not meet professionally recognized standards of the public display community or meet the minimum acceptable standards of the Animal Welfare Act (AWA) for the animals in their possession. The U.S. Department of Agriculture’s Animal Plant and Health Inspection Service (USDA APHIS) maintains oversight and permitting for facilities pursuant to AWA regulations, and AWA compliance is additionally used as a basis by which the NMFS issues permits for the capture, import, export, and transfer of marine mammals.

The data contained in the report clearly demonstrates that the requirements of the AWA and MMPA cannot be satisfactorily confirmed without knowledge and verification of historical records, the care and status of presently and previously held animals, and compliance with current and past regulations.

In 1994 the MMPA was overhauled, incorporating numerous changes that stripped away much of the independent oversight from U.S. government regulatory agencies. This effectively created a self-governing industry in which the transparency of marine mammal care at public display facilities is now essentially controlled by the multibillion-dollar entertainment facilities that house these animals. It is hoped that through this report, the U.S. Department of Commerce, the House Committee on Natural Resources, and the Subcommittee on Fisheries, Wildlife, Oceans, and Insular Affairs will recognize the need to once again overhaul the MMPA, the AWA, and the Endangered Species Act (ESA) to return them to the status for which they were created and intended: for the care, safety, and protection of our precious marine life.

As a distinguished representative and steward of our oceans and wildlife, I am sure that you, like many, are concerned about the welfare of our valued marine life. Please take whatever actions are necessary to address and correct the shortcomings in marine mammal inventory management, ensure the implementation of the aforementioned restrictions on permit issuance, and actively cooperate and participate in bringing about the changes that are required in our laws and regulations to ensure the well-being of all of our marine mammals and wildlife.

The complete report detailing the deficiencies in marine mammal inventory management can be found here:

You can also open/view/download the complete report (25 pages) in PDF format here:

I appreciate your time for reviewing this data and look forward to your commitment to working on behalf of these magnificent beings.

Thank you.


(your name)

(city, state, province)


Send to:

US Department of Commerce, Secretary Gary Locke:

Acting Under Secretary of Commerce and Administrator for NOAA, Kathryn Sullivan:

NOAA National Marine Fisheries Service:

Assistant Administrator of the NMFS, Jim Balsiger:

Secretary of Agriculture, Tom Vilsack:

Deputy Secretary of Agriculture, Krysta Harden:

Under Secretary for Marketing & Regulatory Programs, Edward Avalos:

USDA- APHIS Animal Care:

The Marine Mammal Commission:

Comma separated for bulk mailing to the individuals listed above with additional contacts:,,,,,,,,,,,,,,,,,,,,,,,,,,,,,

You can also contact the United States House of Representatives Committee on Natural Resources here:

Majority site:

Minority site:

Or visit them on FaceBook:

What else YOU can do:

  • Tell your friends and families not to visit or support Marine Mammal Parks like Miami Seaquarium, SeaWorld and Six Flags.
  • Call your Congressman and elected officials and tell them not to support Marine Mammal captivity. To locate your government officials, click <HERE>.
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