30 November 2000

Dr. Robert Gibbens, Supervisor
Western Region
APHIS/USDA
9580 Micron Ave., Suite J
Sacramento, CA 95827

VIA FACSIMILE: 916/857-6212

Dear Dr. Gibbens:

This letter shall serve as a formal complaint and request, on behalf of In Defense of Animals, Earth Island Institute and Observe Respect and Compassion for Animals, for a USDA investigation of animal care at Six Flags Marine World in Vallejo, Calf.

ANIMAL DEATHS

Since 1997, when the Premier Parks theme park company took over management of Marine World the following animal deaths and animal-related incidents are known to have occurred:

* October 1997 - Yaka, a 32-year old orca, dies from a respiratory fungal infection.
* July 1998 - Sea lion dies at Marine World after a heating malfunction
* August 1998 - Tiger mauls a woman during a photo session.
* Sometime in late 1999 - An adult male dolphin, possibly Scooter, dies from unknown causes.
* June 2000 - 3-week old dolphin dies.
* August 2000 - Vigga, a 23-year old orca, dies from alleged heart problems.
* November 2000 - Kala, 2-year old elephant, dies from viral infection.

We understand that the USDA has already investigated the sea lion death, cited Marine World for Animal Welfare Act violations, and assessed a fine. However, we believe that the string of animal deaths may constitute a failure to provide adequate care as mandated by the AWA. Therefore, we request the USDA to look into these animal deaths, and to assess whether they do indeed constitute a pattern of negligence and non-compliance with federal law.

WHISTLEBLOWER ALLEGATIONS

As stated above, Premier Parks took over management of the park in 1997. This company has since been taken over by the Six Flags Corporation. To our knowledge, the Six Flags/Premier Parks corporation has limited animal care experience. We have received anonymous reports from workers at Marine World alleging high turnover, inadequate staffing, and a "burden of secrecy" in which employees are afraid to speak out about animal care and other concerns because of fear of being fired.

These employees have also alleged the folowing animal care transgressions, some of which, if true, constiute threats to public safety:

* Sometime around May 2000, a 7 foot python allegedly escaped from the reptile housing area and has not been recovered.

* Sometime around July 2000, an old camel named Miles allegedly died. It is alleged that employees did not attend to his body quickly enough. Rigor mortis set in and when they attempted to move his body, they could not get him into the pick-up truck bed as they planned, and they actually debated hacking the legs off to move his body. The incident may violate legal regulations for the proper disposal of animal carcasses. It certainly represents a callous lack of respect.

* In August 1998, employees allegedly observed the tiger involved in the tiger-mauling incident. It is alleged that "the tiger's eyes were as huge as saucers" and that "the tiger had been beaten severely." According to this report, the tiger appeared to be "different and dangerous" the day after the mauling incident.

* In August 2000 after Vigga died, her body was immediately hauled out of the tank and allegedly dragged into the land animal food kitchen. According to the report, her body was too wide where the fins were, so they hacked them off, and continued dragging her into the building. Once they had finally gotten her body into the building, they it up into over twenty 55 gallon drums and hauled her body away in these drums. Some staff was allegedly very suspicious and concerned about the lack of a real autopsy and felt that just taking the heart and maybe part of a lung while destroying the rest of the body was not a thorough investigation of her death.

The signers of this letter have no way of confirming the validity of these allegations, as the reports were made in an anonymous manner. We do, hoever, request that the USDA investigate the validity of these charges, and whether Six Flags/Premier parks maintains sufficient numbers of properly trained staff to provide animal care in accordance with the standards set forth by the AWA.

IMPACT OF THRILL RIDES/ THEME PARK ATMOSPHERE ON ANIMALS

Since the Premier Park takeover, Marine World has added a growing number of roller coasters and other thrill rides and attractions. This has increased noise levels at the park dramatically. The increased noise level has likely increased stress on all the animals confined at the park, particularly the sonically-sensitive creatures like dolphins and elephants.

We request that the USDA assess the impact of Marine World's thrill rides and the growing crowds on anmal well-being at the park, and whether or not the changing environment of the park has compromised its ability to provide animal care in accordance with federal law. It is the signers firm belief that the theme park atmosphere and the well-neing of its exotic animals are completely incompatible.

RESTRICTION ON PARK'S ACQUISITION OF NEW ANIMALS

We believe that the concerns about animal care at the Marine World are serious enough to warrant the USDA to place a restriction on the park's ability to acquire new animals while the investigation is underway. We believe that this step is necessary after the death of Kayla, the 2-year old elephant who died after just six months at the park, to prevent more animal deaths from occurring.

Thank you for your consideration of this request.

Sincerely,


Suzanne Roy
Program Director
In Defense of Animals

ON BEHALF OF

Mark Berman, Program Coordinator
Earth Island Institute

Cathy O'Brien, Founder
Observe Respect and Compassion for Animals