Rescuing Orphans or Creating Them?
A rescue mission that took Cincinnati Zoo employees to Alaska in 1996 captured the hearts of Cincinnatians when zoo workers returned home with three walrus pups.When one of the walruses died Feb. 26, news reports again publicized how the zoo rescued the pups, which the zoo said had been orphaned when Native Alaskans killed the pups' mothers during an authorized subsistence hunt.What the zoo didn't publicize was that it paid the natives to allow zoo employees to be on the hunting boats while the natives found and shot four female walruses. Three of their pups, which now were orphans, were retrieved for the zoo. Zoo employees passed on a fourth pup because it was the wrong sex, and the natives killed it, too.With the desired pups in hand -- one male and two females -- the Cincinnati Zoo had become one of four U.S. organizations in four years to legally collect orphaned walruses for public display under permits granted by the U.S. Fish and Wildlife Service.These permits, which allow organizations to collect pups that are orphaned during subsistence hunting, are drawing heated criticism from the Humane Society of the United States. At issue is whether the permits are spurring the very thing federal regulators say they prohibit -- the intentional creation of orphaned pups -- while regulators are "turning a blind eye," the Humane Society says."This has been a scandal in the making for the past four years...," said Naomi Rose, marine mammal scientist for the Humane Society of the United States. Calling such excursions rescue missions "is an old scam. Nothing sounds more heroic and merciful than rescue. ... I can't believe (the Fish and Wildlife Service) bought this."Federal regulators respond that the organizations involved have complied with the rules and that regulators have not been shown any documented evidence that suggests female walruses with pups are being targeted -- an activity that would be in violation of the permit."I don't think the Fish and Wildlife Service is turning a blind eye," said Margaret Tieger, chief of the branch of permits in the service's Office of Management Authority in Arlington, Va.But lending support to the Humane Society's argument, the lead native boat captain on the Cincinnati excursion told CityBeat that, for a fee of $25,000, he and other hunters intentionally sought out female walruses to kill in order to get what the Cincinnati Zoo wanted. He began to change his story, however, after zoo officials learned of the interview and discussed it with him.The boat captain is old, an Inuit (a Native Alaskan) and English isn't his first language, said Donna Oehler, the zoo's director of marketing and public relations. In addition, she said that when the hunter spoke with CityBeat, he thought he was talking to the Cincinnati Zoo."We did not target females," Oehler said. "This was part of the subsistence hunt. ... They would have eaten the three calves. We can say that there probably would have been more walrus taken had we not been there."The pertinent question, however, is "Had the natives gone out without the zoo, would they have shot the same animals?," said Robert Hofman, scientific program director for the Marine Mammal Commission. The commission was established under the Marine Mammal Protection Act of 1972 to serve as an independent source of policy and program guidance to Congress and the executive branch on issues that affect marine mammal conservation. Under the law, Native Alaskans are allowed to hunt walruses for subsistence, meaning to get such items as food, clothing and skins to make boats. They also are allowed to sell ivory from walrus tusks after they have altered it through handicrafts.While permit applications to take walruses from the wild are reviewed by the Fish and Wildlife Service on a case-by-case basis, an organization such as the Cincinnati Zoo probably would not be allowed to hunt walruses in order to collect pups, said Lynn Noonan, senior permit biologist in the Fish and Wildlife Service's Office of Management Authority.On March 4, 1996, the zoo received a permit allowing it to collect up to four pups -- one male and three females -- by accompanying natives on a subsistence hunt as the zoo proposed in its permit application.The Fish and Wildlife Service has deemed it acceptable for zoos and other organizations to pay natives for such things as space on their boats, use of their equipment and time lost from hunting for their food -- not for hunting or capturing animals. This method of collecting pups was devised within the past decade as a more effective way of putting orphaned pups into the hands of qualified organizations that wanted them for public display, Tieger said. Before that, Tieger said the Fish and Wildlife Service in Alaska maintained a list of such organizations to contact in the event an orphan in need of care was found. But such orphans were found infrequently, she said.By allowing the organizations to accompany the hunters, orphans could be retrieved before being killed or escaping into the waters alone, where they most likely would die, the service believed.Permits issued to the collectors contain an array of restrictions. In the case of the Cincinnati Zoo, restrictions included one that read: "No encouragements (such as money, gifts, etc.) for collection of walrus should be offered that might tend to induce harvest of female walrus or female walrus with offspring beyond that which would have been taken in the absence of collection activities."Under the permit, it would not be permissible to go out and target females with pups, Noonan said. Instead, pups the organizations collect are expected to be those that are orphaned incidentally as a result of the hunt, she said.But the Humane Society's Rose said the only way to collect true orphans would be for the organizations to follow along behind the hunting parties without help from or payments to the natives.Figuring out the likely result of paying the natives should be a "no-brainer" for federal regulators, she said."I would argue that if you weren't offering any monetary compensation, they wouldn't do it for you ...," Rose said. "You'd have to trail along behind every hunt until an orphan is truly available. The minute there's money involved, who's kidding who?"Capturing Walrus Pups in AlaskaThe Marine Mammal Commission reviewed the zoo's permit application in January 1996. Noting that the application stated that the walruses collected would be orphaned "as a result of weather, accident or by the authorized native subsistence harvest," the commission recommended that the zoo be required to explain the circumstances surrounding the orphaning of each walrus and that compensation not be offered that might induce intentional orphaning. The recommendation, the commission's Hofman said, was meant to ensure that pups would not be orphaned intentionally."Waiting for a legitimate orphan, I think, would be time consuming and you have no idea what kind of condition the pup would be in once found," said Caleb Pungowiyi of the Eskimo Walrus Commission, which the Cincinnati Zoo contacted in advance for permission to conduct its collection trip.Pungowiyi said that when natives agreed to work with such organizations, the natives focused on getting what the organization wanted. The most common way was to locate and kill females with pups, Pungowiyi said from his office in Nome, Alaska. Another, he said, would be to try to capture a pup that was away from its mother, although that posed the risk of a fight.So regardless of whether the orphan truly was an orphan or whether a female was intentionally targeted, the natives simply focus on getting the job done?"That would be one way of putting it," he said.Clarence Waghiyi, the lead boat captain for the Cincinnati Zoo's excursion off the coast of Savoonga, Alaska, said that he worked in advance with Scott Drieschman of Wildlife Concepts International -- the company that helped arrange the trip for the zoo.Through Drieschman, the zoo informed Waghiyi that it wanted to collect one male and two female pups, Waghiyi said during interviews earlier this month.May 15, 1996, was their first day out. Waghiyi and some other hunters took the zoo's representatives out in two boats, Waghiyi said. They searched until they saw a herd on the ice that included females and pups. The hunters shot four females and captured four pups, he said. Two pups were male and two were female, he said. The hunters killed one of the males because the zoo's permit allowed it to take only one male while it could have taken up to three females, he said.Waghiyi said this was the only hunting he did that day and the trip was aimed only at getting the job done for the zoo. Instead of normal subsistence hunting, it was a hunt paid for by the zoo, he said. That means he looked for females with pups and killed the females, which were taken, along with the dead pup, by the natives for food and ivory, he said.Waghiyi said that the Fish and Wildlife Service had never told him that there was any problem with hunting for exactly what the zoo wanted. But he said he had been told that, in order for the pup to be an orphan, the mother had to be dead."We are real selective," Waghiyi said. "If somebody kills a female with a calf, they consider it an orphan."For his work for the zoo, Waghiyi said he was paid $25,000, out of which he had to pay the hunters on the boats -- although the zoo's Oehler said Waghiyi also had to pay several other natives for other jobs.Waghiyi said that such excursions for zoos and others collecting animals were very beneficial to the natives of Savoonga, where few jobs were available and, in his own case, had allowed him to buy a new, 18-foot boat.Almost a week after CityBeat first spoke with Waghiyi, Oehler contacted CityBeat to dispute information Waghiyi provided. During an interview March 10, Oehler said that Waghiyi's age, the fact that Inuit was his first language and bad long-distance telephone connections had left CityBeat with inaccurate and incomplete information.In addition, she said, Waghiyi had the impression that, instead of CityBeat, he had been talking with an employee of the zoo.The hunting party, Oehler said, did not target females."We followed the letter of the law," she said.In addition, she said Waghiyi and the hunters did not get the entire $25,000. Instead, Oehler said it was given to Waghiyi -- the zoo's point person -- and he had to pay several natives from that money for an array of provisions such as lodging, rights to cross land, arranging holding areas for the pups, guarding the pups, providing a truck and other equipment and for time lost from hunting.Zoo representatives said there were two hunters per boat, or four hunters. But the zoo could not provide a breakdown of all the natives who were paid because it was Waghiyi's responsibility to take care of it, Oehler said.The hunters, she said, had to be repaid for the time they lost from obtaining their food. The zoo's presence was an interruption because, once the pups were captured, they had to be taken back to the village, she said."(The hunters) wanted to continue to shoot more females and males," Oehler said.After the pups were taken back to the village, no more hunting was possible because poor weather conditions had set in, she said.There was nothing misleading, Oehler said, in publicizing the trip as a rescue mission. Had the zoo not been there, the Savoonga natives would have gone out and taken the females -- as well as the pups -- for food and other necessities, she said.Within hours of Oehler's interview, CityBeat's editor received a letter, via fax, from Waghiyi that read:"I would like you to know that the Cincinnati Zoo compensated members of my village for the use of equipment and the space in our hunting boats. The Cincinnati Zoo staff went out with us during our village's normal subsistence hunting. Calves were harvested before the zoo's staff arrived and after they left our village. If the Cincinnati Zoo did not salvage the three walrus calves, our boats would have been hunting for walrus, including calves, to eat. As lead boat captain, I directed all hunting activities and was not asked to kill specific animals for the Cincinnati Zoo."A Nov. 8, 1995, letter from zoo's intermediary -- Wildlife Concepts International -- to the Eskimo Walrus Commission, which represents communities that hunt walrus, made it clear what the zoo wanted to achieve.Drieschman, company president, wrote, "I would like to propose we collect in the last half of May 1996. We would require the collection of 1.2 (one male and two female) pups. Coordination of the collection would be undertaken by myself and Mr. Clarence Waghiyi. Financial arrangements would be negotiated with Clarence for use of boats and manpower."Contacted last fall, Drieschman refused to reveal the amounts of specific payments to the natives, what he charged the zoo for his own services or the cost of the entire trip."I think it's proprietary information," he said.At the time it was investigating an Alaska excursion, the zoo could have purchased Russian-caught walrus pups in Holland for about $55,000 a pair -- a price that was comparable to the cost of collecting pups in Savoonga, Drieschman said. But, he said, such animals obtained through dealers often had not had the proper diet and rearing and, therefore, were high-risk animals.Oehler said that all of the pups that were brokered through Holland eventually died.She said that for its entire excursion to Savoonga, the zoo paid about $50,000 in funds that were raised through private donations. No zoo general fund or taxpayers' dollars were used, Oehler said.The zoo, she said, needed the pups because of the death of the zoo's female walrus in 1995, which left the zoo with one adult male walrus. That walrus has been sent to Sea World of Florida as part of a breeding program, she said.It is the zoo's long-term hope, as the two orphans it has left mature, to build a captive breeding program, she said.The third orphan, a female walrus named Siku, died Feb. 26 after eating caulk that she removed from a pool behind the walrus exhibit, Oehler said. The caulk caused an obstruction of the colon, the necropsy report found."This caulk was recessed in a groove, and this calf had not bothered this material in the previous 20 months of using this pool," Dr. Mark Campbell, staff veterinarian, wrote in a March 15 letter to the Fish and Wildlife Service.The breeding program that will be made possible by the two remaining walruses is part of the zoo's commitment to conservation and education, Oehler said.But Rob Laidlaw of Zoo Check Canada -- a Toronto-based animal-rights group that investigates zoos -- said there was no research or education to be gleaned from capturing the Pacific walrus.Because the walrus population, through efforts to protect it, has seen a resurgence since going through cycles of depletion caused by excessive commercial hunting, there is no need to capture walrus for breeding programs aimed at preserving their species, he said. And because the walruses were removed from their natural environment, they could not behave normally or be displayed properly so the public wasn't going to learn anything meaningful from them, Laidlaw said. An array of animals, Laidlaw and the Humane Society's Rose said, have been captured under the disguise of rescue missions. Rose likened the capture of orphaned walrus pups to the import of false killer whales from Japan that was allowed by the National Marine Fisheries Service to continue until an eye witness, in 1993, reported that the false killer whales were being captured by drive fishing. This method of fishing involved herding them into shallow waters where some were set aside for sale to marine parks and the rest were slaughtered, she said. The permits had required the use of seine nets for capture, which is considered humane, Rose said.Laidlaw said that what the walrus and other animals were being acquired for was "very clear and simple.""They're box-office animals ... " he said. "It comes down to money."There are few captive walruses in the United States, which does give the Cincinnati Zoo some edge in attracting visitors, Oehler said. But, according to market research, bears, elephants and big cats remain the top attraction, with reptiles coming in next, she said.Roger Caras, president of the American Society for the Prevention of Cruelty to Animals headquartered in New York, said he did not have an absolute, first-hand opinion on the practice of acquiring walrus pups by accompanying natives on hunts. He also said he could not say for certain whether walruses belonged in captivity.But, he said, walruses are not stressed and adversely affected by captivity the way whales and dolphins -- whose capture he opposes -- are. And if a walrus is to be in captivity, Cincinnati is a good place for it to happen, he said."My position is that the Cincinnati Zoo is one of the most humane zoos in the world ... " he said. "Whether or not marine mammals should be in captivity is another question."Hunting Has Little Impact on Walrus PopulationOehler, Drieschman and others who have collected orphaned pups are adamant that, in addition to following all regulations, they have provided a humane service by saving pups that would otherwise die. In addition, because native hunters had to stop hunting when pups were captured, collection trips also likely reduced the overall number of walruses killed during subsistence hunts."We abided by the regulations ... " Drieschman said. "We've got animals that were acquired without any waste. ... They're going to kill those pups anyway. We pay them not to kill them."Though they say their excursions worked quite differently than the excursion Waghiyi described to CityBeat, representatives of the Indianapolis Zoo and the New York Aquarium for Wildlife Conservation have similar views about the impact of collection trips."Our belief is that not one more walrus was taken than would have been taken otherwise," said Louis Garibaldi, director of the New York Aquarium for Wildlife Conservation, which collected three pups in 1994 off the shores of Gambell, which along with Savoonga is on St. Lawrence Island.Judy Gagen, director of public relations for the Indianapolis Zoo, said, "(The natives) do try to shoot males, they're bigger. But they do occasionally shoot females."And if that happened when the zoo was not there, the calves would be killed, too, she said.The Eskimo Walrus Commission's Pungowiyi also said native hunters tried to shoot male walruses before females. The Cincinnati Zoo's boat captain Waghiyi would not discuss the issue.Garibaldi and the Cincinnati Zoo's Oehler said that Pungowiyi was offering a politically correct answer because the natives are sensitive about how they are viewed by the outside world, which doesn't understand the natives' customs or their methods of sustaining themselves.Fish and Wildlife estimates support that assertion. According to statistics from the service's Walrus Harvest Monitor Project, there were 3,298 walruses killed during subsistence hunts from 1995 through 1997 by native hunters from four villages -- Ingalik, Gambell, Savoonga and Wales.Of those:* About 45 percent were females, a year of age or older.* About 29 percent were males, a year of age or older.* About 25 percent were calves, male, female and sex unknown. From 1980 to 1989, the number of females shot annually ranged from a low of 38 percent of the total number of walruses killed to a high of 68 percent, according to experts' tabulations that the Cincinnati Zoo quoted in its permit application."An estimated one-third of these would have been with calves of the year," the permit application read.Wells Stephensen, a wildlife biologist with the Fish and Wildlife Service in Anchorage, Alaska, who coordinates the service's walrus marking, tagging and reporting program, said that whether a hunter was inclined to shoot males or females depended upon the hunter, what was available and what was needed."It's been my view that they take what's available," Stephensen said.Hunters have a limited time to hunt walruses as the ice recedes in the spring and the walruses migrate from the Bering Sea to the Chukchi Sea and north, Stephensen said. Locating walruses on the ice, where they can be hunted more easily, as well as combating weather conditions can be difficult and dangerous, he said.It is true, Stephensen said, that male walruses are desired because they are larger and have larger tusks, meaning more ivory. But the ivory from females can be more desirable because it is a bit more dense and less cracked, he said. Female walruses also are more desirable in some situations because their skin often is better for making skin boats, used to hunt whales, as it has fewer tears and holes, he said, adding that there were only about 20 such boats in each village.Ivory, he said, is most important to the natives of the remote villages where unemployment ranges from 80 to 90 percent."The only money some of them get will be from carvings," Stephensen said. Regardless of what hunting practices the natives use to sustain themselves or what practices zoos use to collect walruses for public display, the hunting and collecting are not having an adverse effect on the walrus population, he said.The number of Pacific walrus is estimated at more than 200,000 or about 80 to 90 percent of all walrus worldwide, according the Marine Mammal Commission's 1997 Annual Report to Congress. The population size before the walruses were exploited by excessive commercial hunting is unknown but is estimated at 200,000 to 250,000 animals, according to the report.Not All Zoos Collect the Same WayWhile zoo and aquarium representatives agree that collection activities don't harm the walrus population, they do not all conduct collection activities in the manner that boat captain Waghiyi described to CityBeat, Indianapolis' Gagen and New York's Garibaldi said."What you're describing is exactly why we don't use any middlemen," Garibaldi said.Before staff from the New York Aquarium, which relied upon a liaison who lived in Alaska to assist with negotiations, decided to collect pups in Alaska, they spent a great deal of time evaluating the best way to acquire the animals, he said. The health and background of walrus that were available from Russian sources could not be counted on, Garibaldi recalled.As for capturing the animals in the wild, he said it was illegal to capture pre-weaned animals that were not orphans. Capturing the walrus when they were older became more dangerous, he said, not only to people but to the walruses themselves, which are known to flee after being hit with a tranquilizer dart, into the water where they cannot be retrieved.It was known that a reasonable number of female walruses and pups were being taken through subsistence hunting, Garibaldi recalled, so the thinking was that it would be best to intervene in a manner that allowed the pups to live.He said that the aquarium worked for more than a year with the Fish and Wildlife Service, the Eskimo Walrus Commission and native hunters to devise a collection plan to salvage pups that were not intentionally orphaned."We did not want to be in a situation where we were paying for a pup," he said.Aquarium employees then spent about two weeks rotating among several different hunting boats as the natives from the village of Gambell hunted, he said. Only one pup could be collected per trip, which deterred hunters from hunting more females with pups than they normally would because each time a pup was collected, that hunting trip had to stop, and the boat had to return to the pup to the village, Garibaldi said."In our situation, they sometimes went out for days and didn't find anything," he said.While Garibaldi said his organization did not pay the natives as much as Waghiyi reported his crew was paid by the Cincinnati Zoo, and the aquarium paid the hunters regardless of whether they retrieved a pup, he said he preferred not to disclose specific amounts.Rotating among the boats of several boat captains in May 1995, Indianapolis Zoo employees spent nine days off the coast of Gambell, Gagen said. She said they made nine trips, with the longest one lasting 23 hours. The zoo collected two male and two female pups.Like New York, Gagen said the process that was used deterred hunters from killing more females with pups than they usually would. Because only one pup could be collected per trip, the zoo's presence was an interruption for the hunters who would have to stop hunting to return the pup to the village.As an example of the inconvenience the zoo's presence posed, Gagen cited a trip on which the hunters shot a female before seeing that there was a pup behind it. That pup now was an orphan that had to be returned to the village."That was the end of that (hunting) trip," Gagen said.Despite advanced planning and discussion, however, the Indianapolis crew ran into a problem when natives from a boat not occupied by a zoo employee brought a pup to zoo employees, Gagen said.The Fish and Wildlife Service, all collectors interviewed by CityBeat said, required that an employee be on the boat to witness a pup's capture to ensure that it was an orphan and to tell the natives whether the organization's permit allowed it to take the pup.The Indianapolis Zoo, Gagen said, immediately reported the problem to local Fish and Wildlife officers who decided it would be in the pup's best interest for the zoo to keep it.That episode, the Cincinnati Zoo's Oehler said, was a major reason that Cincinnati did not conduct a lottery that would have resulted in a larger group of native hunters working with the zoo. Taking a pup without knowing how it was captured posed a potential permit violation, and Fish and Wildlife officers, advised the zoo that a lottery could set the zoo up for the same problem, Oehler said.The decision to work with Waghiyi and his crew also was made to protect the lives of zoo employees, Oehler said. Conditions on the water were dangerous, she said, and they knew Waghiyi was well-qualified for the job.In all, Gagen said, the Indianapolis Zoo worked with seven natives who were paid less than $5,000 each.Should Money Be Changing Hands?Regardless of the amount paid to the natives, what the money was paying for or methods the organizations use to ensure that pups become incidental orphans, the Humane Society of the United States argues that the money should not be changing hands at all.The organization voiced that concern to the Fish and Wildlife Service in a Jan. 13, 1995, letter that took issue with the Indianapolis Zoo's permit application when it was being reviewed for approval."We are very concerned ... with the possibility of giving the native subsistence hunters an incentive to selectively target females with dependent young, thus creating orphans," the letter, written by Rose on behalf of the society's more than two million members and constituents, read. "One important consideration is whether the applicant intends to compensate the hunters in any way for providing orphaned walruses to the zoo collectors. If there will be compensation, clearly this will create an incentive for the hunters to selectively kill mothers."Now three years later, Rose recalled the Fish and Wildlife Service's response as inadequate."They said, 'We'll police it like a hawk ... ' " she said. "The bottom line is that the permittee polices itself."The Office of Management Authority's Tieger said that, in assuring compliance, her office relied upon written documentation from the organizations collecting pups as well as Fish and Wildlife employees from the Anchorage office. Those employees work with the organizations and monitor their activities but do not go out on the hunting boats or actually observe the collections, the employee said.The walrus program biologist, Dana Seagars, who did some of the monitoring of the Cincinnati Zoo's collection trip, has transferred to a different job with the service. CityBeat's call to him was returned by Douglas Burn, acting marine mammals management supervisor and a wildlife biologist with the service for nine years.Burn said that the collections were monitored by service representatives meeting the boats when they returned from hunting, observing what they brought back and interviewing the hunters and collectors. Seagars did that job for the New York and Indianapolis collections, Burn said, while another service representative did it for the Cincinnati Zoo.Based on those interviews and observations, the service determined that the organizations were in compliance, Burn said. But Burn pointed out that hundreds of females and often calves were killed each year in the course of subsistence hunting and only a handful of zoos or similar organizations had collected calves during the hunts. It would be difficult, he said, to determine whether, as the Cincinnati Zoo's permit prohibits, incentives had prompted the natives to kill more than they normally would."I don't know how you would make that distinction," he said.In Cincinnati's case, part of the written documentation to which Tieger referred was a report describing the circumstances surrounding each capture of a pup, which, under the zoo's permit, had to be filed within 10 days of the excursion.Last September, the Marine Mammal Commission determined that the zoo's report did not fully address all of the points required and needed clarification. Tieger's office asked the Cincinnati Zoo to submit an expanded report in which David Oehler, curator of birds, described how zoo employees, on May 15, 1996, accompanied Waghiyi and his crew on a government sanctioned native subsistence harvest. The trip took them 45 miles northeast off the coast of Savoonga, he wrote.According to the report, the Eskimo hunting party located a group of walruses, then shot and killed four females."(Zoo veterinarian) Dr. (Ken) Cameron prevented the continuation of the hunt, preventing the taking (shooting) of four pups," wrote Oehler who, according to the report, was not on the boats but was in charge of the operation's land-based activities. "All pups were held, by hand, until examined and either placed in the boats for transport or terminated for food by the hunting party. Dr. Cameron advised the Eskimos that under our permit we could not take the fourth pup since he determined it to be male. The fourth pup was taken/terminated in a manner consistent with the subsistence hunting practices of the Eskimos. ... If the zoo had not accompanied the hunting party, these pups would have been lost as a result of starvation or taken as part of the subsistence harvest."While he gave no dollar amounts, Oehler also explained in the report that members of the village were compensated for their assistance in arranging holding areas, housing and transportation.In addition, Oehler wrote, "The boat captain and his crew were compensated for allowing employees of the Cincinnati Zoo to accompany them as they conducted their subsistence harvesting of walrus. All compensation to the hunters was furnished as a result of space taken by the rescue team that displaces additional hunters within the hunting party. An additional amount of compensation was provided to the boat captain for cessation of all harvest activities in order to return to the village with the three calves."This compensation, he wrote, was for further opportunities the hunters lost in returning the boat and its occupants quickly and safely to the village."The rescue team did not direct the harvest of the four adult walrus and only directed the captain to return to the village immediately after boarding the boats," Oehler wrote.After reviewing the report, the Marine Mammal Commission's Hofman said that while there might be a "gray area" that regulators might need to address in the future, he believed that Cincinnati Zoo employees believed that their permit authorized their activities.But the Humane Society's Rose said she did not know how anyone could read the zoo's report with a straight face. "It reads like a really bad student essay," she said.If federal regulators are going to continue to allow such collections, they at least need to stop allowing organizations to disguise their excursions as rescue missions, Rose said, noting that the Humane Society had voiced that opinion when it protested the Indianapolis permit in 1995.According to that letter of protest, Marine World Africa USA had requested a permit to collect walrus orphans the year before. Marine World, the letter read, also had claimed it was rescuing four false killer whales from a drive fishery in Japan in 1993. But the National Marine Fisheries Service had chosen to do the correct thing in denying Marine World a permit, the Humane Society said."The National Marine Fisheries Service did not condone this and neither should the (Fish and Wildlife Service)," the letter read.But Tieger reiterated that her office had not received any written evidence to indicate that the process for collecting walrus pups during native hunts left room for the intentional orphaning of calves to occur.To know if there was, "I think you would have to take a specific circumstance and see if there is any data to support that," she said.Michael Gosliner, general counsel for the Marine Mammal Commission, said his organization also had not seen any documented evidence.The commission's Hofman said the commission would continue to expect that such excursions resulted only in the collection of legitimate orphans."I know that the next time an application ... comes to the Marine Mammal Commission, I expect that the recommendation that comes out of here will be a lot clearer," he said.