1. SeaWorld’s Blue World Project

2. The Commission Has and Can apply 30230 to Captive Marine Mammals Staff report page 20: "The question of whether the orcas currently in SeaWorld San Diego are subject to Section 30230 is an interpretive question.“ The Coastal Act, Section 30009 states that: “This division shall be liberally construed to accomplish its purposes and objectives“ You have applied it previously for the ONLY time the Commission had a reason for concern: CDP 6-01-129 where, according to staff: “Section 30230 of the Coastal Act, cited in the previous finding, protects marine resources and is the most applicable Coastal Act policy with regard to marine mammals that are held in captivity at SeaWorld”

3. The Strength of the Coastal Act is that it is Very Broad Section 30090 of the Coastal Act states :” This division shall be liberally construed to accomplish its purposes and objectives” The Commission has done so in many instances and has won in court. These orcas deserve your protection.

4. CONDITION ONE IS MEANINGLESS It gives SeaWorld permission to do whatever it pleases  There are no accredited reproductive guidelines for orcas  The “Pledge” can easily be circumvented  Use the new tank for breeding purposes denying additional room to the existing orcas

5. NEW CONDITION ONE SeaWorld is only permitted to hold or display the currently existing whales in its San Diego park: Corky, Kasatka, Ulises, Orkid, Keet, Shouka, Nakai, Ikaika, Kalia, Makani, and Amaya. and SeaWorld is prohibited from the captive breeding of orcas, either through mating or artificial insemination, including the collection of gametes. The Project may be used to temporarily hold beached or rescued whales at the request of one or more governmental agencies for return to the wild. IF THIS CONDITION IS NOT SUBSTITUTED IN ITS ENTIRETY PLEASE DENY THE PROJECT