BILL ANALYSIS                                                                                                                                                                                                    



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          Date of Hearing:   April 8, 2014

                   ASSEMBLY COMMITTEE ON WATER, PARKS AND WILDLIFE
                                Anthony Rendon, Chair
                    AB 2140 (Bloom) - As Amended:  March 28, 2014
           
          SUBJECT  :   Marine Mammals; Protection of Orcas (Killer Whales)

           SUMMARY  :   Makes it unlawful to hold in captivity, or use, an  
          orca for performance or entertainment purposes, or to capture,  
          import, export, or breed an orca in captivity.  Specifically,  
           this bill :  

          1)Makes it unlawful to do any of the following:
               a)     Hold in captivity, or use, a wild-caught or  
                 captive-bred orca for performance or entertainment  
                 purposes.
               b)     Capture in state waters, or import from another  
                 state, any orca intended to be used for performance or  
                 entertainment purposes.
               c)     Breed or impregnate an orca in captivity.
               d)     Export, collect or import from another state the  
                 semen, other gametes, or embryos of an orca held in  
                 captivity for the purpose of artificial insemination.

          2)Makes a violation of the above prohibitions punishable as a  
            misdemeanor and a fine of up to $100,000 or six months  
            imprisonment, or both the fine and imprisonment.

          3)Exempts from these prohibitions an orca that is held for  
            rehabilitation after a rescue or stranding, or for research  
            purposes, provided the orca is returned to the wild whenever  
            possible or held in a sea pen that is open to the public and  
            not used for performance or entertainment purposes.

          4)Requires that orcas held for performance or entertainment  
            purposes prior to the enactment of this bill shall be  
            rehabilitated and returned to the wild where possible, subject  
            to any required state or federal permits.  Requires if it is  
            not possible to return the orca to the wild, based on the best  
            available science, then the orca shall be transferred to a sea  
            pen.  Allows the orca to be held in existing enclosures until  
            a sea pen is established.

          5)Defines various terms for purposes of this bill, including  








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            "performance or entertainment purposes" which is defined to  
            mean any routinely scheduled public exhibition that is  
            characterized by music or other sound effects, choreographed  
            display or training for that display, or unprotected contact  
            between humans and orcas.

           EXISTING LAW  :

          1)Under the federal Marine Mammal Protection Act (MMPA),  
            prohibits the take of any whale species without specific  
            authorization.  Allows permits to be issued for take of a  
            whale from the wild for a limited number of purposes,  
            including for scientific research, for purpose of public  
            display, or for enhancing the survival or recovery of specific  
            stocks.  Authorization can also be given for incidental take  
            of marine mammals in the course of conducting certain  
            activities.  The National Marine Fisheries Service (NMFS) is  
            responsible for enforcement of the MMPA.  Requirements for  
            permits for public display include that the entity offers a  
            program for education or conservation based on professionally  
            recognized standards of the public display community, is  
            registered or holds a license under the Animal Welfare Act,  
            and maintains facilities open to the public on a regularly  
            scheduled basis.

          2)Governs captive care, handling, treatment and transportation  
            of marine mammals held for public display, and maintenance of  
            marine mammal exhibits, under the federal Animal Welfare Act.   
            The Department of Agriculture, Animal and Plant Health  
            Inspection Service is responsible for enforcement of the  
            Animal Welfare Act.  Standards for maintenance and structure  
            of orca pools include: minimum horizontal dimension, volume  
            and depth requirements; a plan of care approved by a  
            veterinarian; and that animals be housed with at least one  
            compatible animal of the same or biologically related species.  
             Examples of pool dimensions include that a pool holding two  
            orcas must have a minimum diameter of 48 feet, a depth of 12  
            feet, and a minimum volume of 615 meters. 

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   Killer Whales (Orcinus orca), also known as orcas,  
          are toothed marine mammals belonging to the order Cetacea, which  
          includes whales, dolphins and porpoises.  As members of the  
          Delphinidae family, they are actually more closely related to  








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          dolphins than true whales.  Orcas are wide ranging apex  
          predators found in most oceans of the world.  They are known to  
          be highly intelligent and highly social animals, living in  
          matrilineal family groups which are among the most stable of any  
          animal species.  Family groups of orcas form pods that live and  
          hunt together, with male and often female offspring staying with  
          their mothers for life.  They are one of the world's fastest  
          moving marine mammals, able to swim at speeds approaching 35  
          miles per hour, and often covering 100 miles or more per day.   
          Orcas range in size from 16 to 30 feet in length, and may weigh  
          as much as 20,000 pounds (males average 6 tons and females  
          average 3 to 4 tons).  Their sophisticated hunting techniques  
          and vocalizations, which often include specific dialects unique  
          to a particular pod, have been described by scientists as  
          manifestations of culture.  According to NMFS, the life  
          expectancy for male orcas in the wild is on average 30 years, up  
          to a maximum of 50-60 years, and for female orcas on average 50  
          years, with a maximum life span of 80-90 years.  NMFS indicates  
          that most information on orca life history comes from long term  
          studies of wild populations in the eastern North Pacific Ocean.   


          Research off the coasts of Canada and the United States have  
          identified three main types or sub-species of orcas in the  
          Pacific: 1) Resident orcas (in coastal northeast Pacific  
          including Puget Sound area), the diet of which consists  
          primarily of fish, and which live in complex, cohesive family  
          groups called pods; 2) Transient orcas, that travel in smaller  
          groups and roam more widely along the coast from Alaska to  
          California and live mostly on marine mammals, and 3) Offshore  
          orcas that feed primarily on schooling fish and sharks, but may  
          also eat marine mammals.  This third type travel mostly in large  
          groups and were not discovered until 1988.  Two populations of  
          orcas have received special protection, the southern resident  
          population which is listed as endangered under the federal  
          Endangered Species Act, and the AT1 transient population which  
          is classified as depleted.  All populations of orcas are also  
          protected under the MMPA.

          This bill addresses the controversial practice of keeping  
          captive orcas in marine parks for public entertainment purposes.  
           Currently, there are 45 orcas in captivity in the world, 26 of  
          which were born in captivity and 19 of which were captured from  
          the wild.  About half of the orcas in captivity are owned by  
          SeaWorld, which has three marine parks in the United States.  








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          The author of this bill notes that "after the tragic death of  
          SeaWorld trainer Dawn Brancheau, the public has begun to  
          question the moral justification for keeping orcas in captivity  
          for our general entertainment.  After humans, killer whales are  
          the most socially and ecologically complex species on the  
          planet.  Scientists studying killer whales in the wild have  
          documented the close social bonds these animals share?.Killer  
          whales are capable of traveling 100 miles per day and are found  
          in all the world's oceans, yet are allowed to be held in small  
          concrete tanks.  As a state we should lead the way in ending  
          captivity for entertainment purposes?by capture or captive  
          breeding programs here in California?.If we truly want to help  
          orcas, then we should focus our efforts on restoring habitat in  
          the wild and protecting our oceans."

          The main concerns and assertions the author and sponsors of this  
          bill raise with regard to keeping orcas in captivity include the  
          following:

          1.The orca's natural environment, which includes the vast open  
            oceans, cannot be replicated in a marine park environment.   
            The species' high intelligence, large size, and complex social  
            structure make orcas unsuitable for captivity.  Reported  
            incidents of aggression among whales in captivity and  
            self-inflicted injuries are signs of the stress and suffering  
            experienced by these animals.  Adverse physical and  
            psychological effects are evidenced by unnatural behaviors  
            such as ramming, dental problems from gnawing on metal gates,  
            repetitive swimming in circles, and dorsal fin collapse, which  
            is experienced by virtually all male orcas in captivity, but  
            only 1% of orcas in the wild.

          2.Proponents assert requiring orcas to perform tricks for human  
            entertainment is demeaning and disrespectful to these highly  
            intelligent animals.  The unnatural, artificial groupings that  
            orcas are put into in captivity causes stress because it is  
            contrary to the experience of orcas in the wild, where they  
            stay in cohesive, matrilineal family groups for life.  When  
            dominance issues arise, the animals also do not have a means  
            of escape as they would in the wild.

          3.Orcas in captivity have shorter life spans on average than  
            wild orcas.  Note: This issue is debated in the literature.   
            According to NMFS biologists, prior to the year 2000 the  








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            evidence showed that the life expectancy of orcas in captivity  
            was significantly lower than those in the wild.  However,  
            according to NMFS, since the year 2000, survivorship  
            statistics have improved for captive orcas and are now  
            comparable to those in the wild.   Other scientists and  
            supporters of this bill disagree with that conclusion and  
            counter that not all deaths of newborn orcas are included in  
            the industry's statistics.  They maintain that the maximum age  
            for captive orcas is the mean age for wild ones.  

          4.Training of orcas in captivity poses serious risks to humans.   
            Since orcas have been kept in captivity, four persons have  
            been killed, and other serious injuries to trainers have been  
            reported. In contrast, there are no confirmed reports of orcas  
            seriously injuring, let alone killing, humans in the wild.   
            SeaWorld is currently under an OSHA order that prohibits  
            trainers from having human contact with orcas unless protected  
            by a physical barrier.  That order is being appealed by  
            SeaWorld in federal court.

          5.Captive breeding programs are also opposed by proponents.   
            While SeaWorld maintains that they have not captured orcas  
            from the wild for many years, proponents note they have taken  
            orcas captured in the wild by others, and the existence of the  
            entertainment industry for orcas creates continued market  
            pressure for wild captures.  In addition, supporters assert  
            that whether captive bred or wild captured, orcas are just too  
            big, too social, too intelligent, and too wide-ranging to be  
            kept in captivity.  Orcas born in captivity are still members  
            of a species that has evolved over millions of years to live  
            in the open oceans.  Supporters also raise concerns regarding  
            genetic diversity and inbreeding problems with captive  
            breeding programs, asserting this may eventually create  
            pressure to recruit more animals from the wild to address  
            genetic diversity needs of the captive population.

          SeaWorld counters the above arguments with the following points:

          1.SeaWorld contends there is nothing wrong with the current  
            approach to keeping orcas in captivity and that SeaWorld  
            provides professional and compassionate care to all the whales  
            it holds, all of which are healthy and have life spans  
            equivalent to those in the wild.  The whales receive a healthy  
            diet, veterinary care, and adequate exercise, and live in  
            socially compatible groups.  They acknowledge that while  








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            whales in captivity do not live the same lifestyle as their  
            wild counterparts, this difference does not translate to  
            negative welfare of the animals. Banning use of orcas in  
            performance and entertainment would jeopardize the health and  
            well-being of the animals which receive stimulation and health  
            benefits from the trainings and performances.  They claim  
            SeaWorld's positive reinforcement training has become the  
            model for other zoological institutions.

          2.SeaWorld contends banning captive breeding would not be in the  
            best interest of the whales as it would require separation of  
            the sexes and deny the whales the experience of having  
            offspring.  They assert their captive breeding program has  
            been very successful, is carried out according to  
            internationally recognized zoological standards applicable to  
            breeding programs, and makes it possible to display killer  
            whales to the public without collecting whales from the wild.

          3.Transferring the whales to sea pens is not a practical  
            solution and could pose security problems, water quality  
            concerns, and other risks to the whales and others.  They  
            assert there is no evidence that sea pens would provide a  
            better environment for the whales.

          4.SeaWorld asserts it's care of captive orcas benefits orcas in  
            the wild, and this bill would diminish the ability of  
            scientists and researchers to study killer whales in captivity  
            as the only way to learn how to better ensure the health and  
            well-being of killer whales in the wild.  SeaWorld contributes  
            to scientific research through its support of the  
            Hubbs-SeaWorld Research Institute.  SeaWorld is also a  
            recognized leader in marine life rescue and rehabilitation,  
            and notes that it has rescued thousands of marine animals with  
            the goal of treating them and returning them to the wild.

          5.SeaWorld notes its business provides major economic benefits  
            to the San Diego region and the state, paying over $5 million  
            in property tax in 2013 and providing 4,500 jobs during the  
            peak season.  More than 9 million students and teachers have  
            participated in SeaWorld educational programs.         
          
          Scientific Research Issues  :  One of the arguments for keeping  
          orcas in captivity is that studies of captive orcas contribute  
          to scientific knowledge of orca natural history.  SeaWorld notes  
          that research conducted on captive whales at SeaWorld have  








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          increased scientific understanding of reproductive physiology,  
          vocalization, development and learning capacity.  Researchers  
          affiliated with SeaWorld have authored numerous published  
          research studies on killer whales.  In addition to research on  
          killer whale physiology, researchers at Hubbs-SeaWorld Research  
          Institute have conducted research on bioacoustics, the study of  
          animal sound production and perception.  Additional examples of  
          research on captive orcas at SeaWorld through Hubbs include:  
          resting oxygen consumption rates and basal metabolism; studies  
          of teeth tissue to estimate age of whales; calling behaviors  
          between mothers and calves; and effects of fishing gear  
          adaptations such as audible pingers on marine mammals.   
          Researchers based at Hubbs also conduct research on marine  
          mammals in the wild, including research on marine mammal  
          strandings, and have authored field guides and other books.     

          While there appears to be agreement that past research on  
          captive orcas has provided insights into cetacean intelligence  
          and cognition, as well as information about issues such as  
          reproductive life cycles and acoustics, the continued need and  
          relevance of captive orca research to understanding of wild  
          orcas is questioned by some marine scientists.  While there may  
          be greater control in captive settings, the unknown effects of  
          living in an artificial environment on behaviors and development  
          can limit the application of such research to animals in the  
          wild.  Some scientists assert that with certain exceptions,  
          there is little research today that scientists are getting from  
          captive facilities that could not be gotten from the wild,  
          particularly with newer technologies now being used for whale  
          research.  Examples of newer technologies include small biopsy  
          darts, GPS technology, laser range finders, and satellite  
          tagging.  Consequently, it is argued that field studies designed  
          to broaden understanding of a species' ecology and behavior, in  
          order to shape conservation efforts, provide more relevant  
          knowledge than captive studies.  The physically restricted  
          conditions of captivity, the effects of the unnatural captive  
          environment on animal behavior, the small number of animals  
          involved, and the limited genetic basis of captive orca  
          populations, are said to cast doubt on the scientific basis for  
          using captive animals as models for wild animals, especially  
          given the increasing sophistication of studies on wild animals  
          and the greater relevance of data from field studies.

          It should be noted that Hubbs-SeaWorld, as described above, is  
          involved in significant research beyond its research on captive  








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          orcas, both in California and other parts of the world.  Hubbs  
          is a nonprofit entity that was founded by SeaWorld and receives  
          5-25% of their annual funding from SeaWorld, in addition to the  
          use of its marine park facilities and animals for research.  It  
          should also be noted the author of this bill expresses support  
          for the research and rescue work of SeaWorld and the  
          Hubbs-SeaWorld Research Institute, and contends these activities  
          should continue and would not be affected by this bill.           


           Public Safety Issues  :  Since orcas have been kept in captivity  
          there have been four deaths of humans involving captive killer  
          whales.  In 1991, 20 year old trainer Keltie Byrne was killed in  
          an incident at SeaLand in Canada involving three whales,  
          including a male orca named Tilikum.  The SeaLand facility was  
          subsequently closed and Tilikum was moved to SeaWorld in  
          Orlando.  In 1999, a visitor to SeaWorld entered Tilikum's tank  
          after hours and was subsequently found drowned in the tank.  In  
          2009, 29 year old trainer Alexis Martinez was killed by an orca  
          at Loro Parque in Spain.  In 2010, trainer Dawn Brancheau was  
          killed by Tilikum at SeaWorld in Orlando.  In addition to the  
          deaths there have been a number of reported incidents involving  
          serious injuries to trainers who survived.  SeaWorld has  
          maintained that the deaths were unfortunate accidents and that  
          overall the organization has a good safety record and follows  
          appropriate safety protocol.  

          SeaWorld was cited by federal OSHA for violating federal safety  
          standards in the 2010 death of Dawn Brancheau.  OSHA issued a  
          "wilful" violation order against SeaWorld and ordered that  
          trainers not be allowed in the water with the whales and must be  
          protected by a physical barrier.  SeaWorld appealed OSHA's  
          decision to an OSHA review commission.  The review reduced the  
          violation classification from wilful to serious, but upheld  
          OSHA's safety mandates.  The Administrative Law Judge (ALJ)  
          found that SeaWorld knew that training orcas involved inherent  
          risks to trainers.  According to the court decision, between  
          1988 and 2009 SeaWorld documented 100 incident reports, 12  
          documented injuries and 1 death.  The ALJ found that "no  
          reasonable person would conclude that SeaWorld was unaware that  
          working in close contact with killer whales during performances  
          creates a hazard for its trainers?SeaWorld knew its trainers  
          were at risk for being struck or drowned by a killer whale."   
          The court further found that "SeaWorld's reliance on its  
          trainers to recognize precursors and prevent unpredictable  








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          behavior by the killer whales runs counter to the requirements  
          of the Act.  The duty of care rests with the employer.  An  
          employer cannot shift this responsibility to its employees by  
          relying on them to, in effect, determine whether the conditions  
          under which they are working is unsafe."  The court found that  
          SeaWorld's own incident reports demonstrate its safety program  
          exposes its trainers to the risks of death or serious physical  
          injury, and that SeaWorld's training program cannot remove the  
          element of unpredictability inherent in working with killer  
          whales.  SeaWorld appealed that decision to a Secretary of Labor  
          discretionary review panel which declined review, allowing the  
          ruling to stand.  That decision was then appealed by SeaWorld to  
          the U.S. Court of Appeals in the District of Columbia.  Oral  
          arguments were heard in the case in November 2013 and a decision  
          is pending.

           Other Governmental Entities that have banned holding of orcas  
          for entertainment :  At least six countries have banned captive  
          orca displays, as have one state and one county (Maui, Hawaii)  
          in the United States.  The State of South Carolina's law makes  
          it unlawful to display any wild caught or captive-bred mammal of  
          the order Cetacea (dolphins and whales). India, Croatia, Costa  
          Rica, Hungary, and Chile prohibit captive orca and dolphin  
          shows.   Switzerland has prohibited the importation of any live  
          dolphin species.  Greece has a broader ban on the use of animals  
          for performance or entertainment. A proposal similar to this  
          bill is also being considered by the New York legislature this  
          year.

           Suggested Amendments  :  SeaWorld has raised concerns regarding  
          the feasibility of keeping orcas in sea pens, which may not be  
          available.  This bill provides that the orcas may be held in  
          existing enclosures until a sea pen is established.  If the  
          orcas are maintained in their existing facilities, SeaWorld  
          asserts that the prohibition on performance in this bill could  
                            prevent trainers from working with the orcas to ensure they  
          receive the exercise and stimulation the animals need.  This  
          bill provides that "performance or entertainment purposes"  
          includes, but is not limited to, any routinely scheduled public  
          exhibition that is characterized by music or other sound  
          effects, choreographed display or training for that display, or  
          unprotected contact between humans and orcas.  The "but is not  
          limited to" phrase leaves the definition of what is prohibited  
          activities open ended and uncertain.  If the committee elects to  
          approve this bill, staff recommends that amendments be taken to  








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          clarify the activities that are prohibited and allowed under the  
          bill as follows:

          (2) "Performance or entertainment purposes" includes,  but is not  
          limited to  , any routinely scheduled public exhibition that is  
          characterized by music or other sound effects, choreographed  
          display or training for that display, or unprotected contact  
          between humans and orcas. Holding of an orca is not, by itself,  
          a performance or entertainment purpose.  Performance or  
          entertainment does not include activities necessary for the  
          general health and welfare of an orca including veterinary care,  
          husbandry, and related activities necessary to provide required  
          exercise and stimulation, and the training required for those  
          activities. 

           The author also proposes the following technical amendments to  
          address possible federal preemption issues:

          Amend subdivisions 4502(a) (2) and (4) to read as follows:

          (2)  Capture in state waters, or import from another state   Sell,  
          offer for sale, trade or transfer for any reason other than  
          transport to a sea pen  any orca intended to be used for  
          performance or entertainment purposes.
          (4)  Export  , Collect,  or import from another state   sell, offer  
          for sale, trade, or transport in any manner  the semen, other  
          gametes, or embryos of an orca held in captivity for the purpose  
          of artificial insemination.   Additionally, they shall not be  
          used for performance or entertainment purposes.   Where, based on  
          best available science, it is determined that an orca has the  
          potential to return to the wild under paragraph (2)?.

          Similarly, Section 4502 (c) (3) to be amended as follows:

          (3) Until an appropriate sea pen has been established, captive  
          orcas held in the state may be kept in existing enclosures.   
          Those orcas shall not be  exported   sold, offered for sale,  
          traded, transferred for any reason other than transport to a sea  
          pen, or  used for gametes or embryos intended for artificial  
          insemination?      

           Support Arguments  :  Supporters assert the scientific literature  
          documents the damaging effects of captivity on orcas' physical  
          health and psychological well-being.  They point to the record  
          of incidents of orcas in captivity killing and seriously  








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          injuring humans, other whales and themselves, and in comparison,  
          the absence of any confirmed reports of serious injuries or  
          attacks on humans in the wild.  Supporters of this bill include  
          organizations concerned with animal welfare, environmental  
          groups, marine mammal scientists, former orca trainers, labor,  
          and numerous individual citizens.  Supporters assert the  
          conclusion from decades of cumulative results of both captive  
          and field studies is that cetaceans possess a level of  
          intelligence, awareness, and psychological sensitivity that  
          makes it unacceptable to continue to keep them in captivity if  
          not necessary for their welfare, survival, or conservation.   
          Supporters also note that a recent random poll showed that only  
          26% of California citizens support continuing to keep orcas in  
          captivity for entertainment purposes. 

          A statement signed by 35 marine mammal scientists from research  
          institutions around the world including the University of  
          California and other state universities was received in support  
          of this bill.  The statement notes that when killer whales were  
          first displayed in the early 1960s little was known about their  
          ecology and behavior, that there was a steep learning curve  
          during the first two decades and survivorship improved, but that  
          there has been little improvement since then.  They note the  
          science on the nature of killer whales makes them inherently  
          unsuited for confinement in concrete tanks.  The statement  
          supports the goals of phasing out the practice of holding orcas  
          in captivity and a ban on captive breeding.  The scientists  
          indicate that most of the orcas now in captivity in California  
          are probably not candidates for release to the wild, but could  
          be placed in well-designed and appropriately sited sea pens,  
          guided by best available science, where they would have more  
          natural surroundings, and where training for husbandry and  
          veterinary purposes could continue and the animals could be  
          viewed by the public.  

           Opposition Arguments  :  SeaWorld asserts in opposition to this  
          bill that orcas in their care are well taken care of, receive  
          regular veterinary check-ups and a balanced diet, and get plenty  
          of exercise.  They also argue that keeping orcas in captivity  
          contributes to public education and scientific research, that  
          they haven't captured orcas from the wild in 35 years and do not  
          separate calves from their mothers, and that Sea World is a  
          world leader in animal rescue.  They note in particular their  
          work on rescue and rehabilitation of stranded marine life, and  
          research they have funded through the Hubbs-SeaWorld Research  








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          Institute.  SeaWorld also notes that captive orca displays and  
          shows have served an important public education function,  
          thereby benefiting conservation of orcas in the wild.  SeaWorld  
          also claims the requirements for release or sea pens in this  
          bill are unworkable and would be harmful to the whales.  

          SeaWorld notes that 9 million visitors have visited SeaWorld,  
          and 100,000 children and teachers per year attend educational  
          programs.  SeaWorld indicates it has invested $70 million in  
          their killer whale facilities throughout their parks in the last  
          three years. Other opponents of this bill also note the economic  
          contributions of SeaWorld in San Diego, where they provide 4,500  
          jobs, serve 4.5 million visitors, and contribute millions in  
          taxes and rental income to the City of San Diego.  They assert  
          that this bill would not only harm SeaWorld but the restaurants,  
          hotels, small businesses and employees of the region, and the  
          overall tourist economy of the state.

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          Animal Welfare Institute (sponsor)
          Action for Animals
          American Society for the Prevention of Cruelty to Animals  
          (ASPCA)
          Animal Legal Defense Fund
          Born Free USA
          Dolphin Project
          Earth Island Institute, International Marine Mammal Project
          Environmental Protection Information Center (EPIC)
          Free Willy Keiko Foundation
          Humane Society of the United States
          In Defense of Animals
          Jean-Michel Cousteau's Ocean Futures Society
          League of Humane Voters
          Local 30 UNITEHERE, San Diego County Hotel and Food Service  
          Workers' Union
          Marine Connection
          Protecting Earth & Animals with Compassion & Education (PEACE)
          Public Interest Coalition
          Sierra Club California
          Whale and Dolphin Conservation
          Wild Orca
          Women Occupy San Diego








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          Numerous individuals

           Opposition 
           
          Anaheim/Orange County Visitor and Convention Bureau
           Opposition - continued
           
          California Association of Boutique & Breakfast Inns  
           California Association of Zoos and Aquariums
          California Chamber of Commerce  
           California Hotel & Lodging Association
          California Retailers Association
          California Travel Association
          City of Chula Vista
          Hotels in the Best Destinations
          San Diego Regional Chamber of Commerce
          SeaWorld
          Strategic Roundtable
           

          Analysis Prepared by  :    Diane Colborn / W., P. & W. / (916)  
          319-2096