It is of concern that nowhere in the Bunbury document is there mention of research into the agency of cetaceans and their choice to investigate, observe, interact with, or otherwise approach humans. This is a factor in interspecies contact that must be taken into account if a fully realised ecological, biocentric, and non-dominionist interaction regime is to be developed. It would be advisable, it seems to this researcher, to seek to define, from a non-hierarchical, non-anthropocentric perspective, why cetaceans seek out humans and their vessels. Whales watch humans, too. Whale-watching is a two-way experience. How humans are to manage themselves when in the presence of cetaceans is an important area of research, but it can only be fully informed if the choice, the intentional act of cetaceans to approach humans for reasons of their own, is taken into account. The Bunbury document takes a view of whale-watching as a source of negative effect, a presumption that cannot but skew the results. It would be advisable to revisit these guidelines to include the agency of cetaceans, and their interests as non-human animals with minds, agendas, interests, and desires of their own, beyond the ken of human understanding. While this is a challenging research area, many aspects of a more full understanding of the cognitive, ethological, behavioural, and historic qualities are known. Comparative Psychology is a good place to begin. (see Journal of the International Society for Comparative Psychology). See also Herzing, D. (2010) SETI meets a social intelligence: Dolphins as a model for real-time interaction and communication with a sentient species. Acta Astronautica, 67, 1451-1454. and Wilke, M., Bossley, M. & Doak, W. (2005) Managing Human Interactions with Solitary Dolphins. Aquatic Mammals, 31, 427-433. Another research group, with a mandate to report to the IWC on the Agency of Cetaceans, would be advisable, to more fully inform the LaWE. Sincerely, C. Scott Taylor BSocSc (Hon) PhD candidate University of the Sunshine Coast, Queensland Australia