PETITION TO END THE EXHIBITION AND EXPLOITATION  OF ELEPHANTS IN CIRCUSES,ZOOS AND AMUSEMENT PA

PETITION TO END THE SUFFERING  OF ELEPHANTS IN CIRCUSES,ZOOS AND AMUSEMENT PARKS 
In memory of beloved Tyke, a brave soul!
(AND TO ALL OF THE OTHER'S WHO HAVE DIED IN CIRCUSES AND ZOOS, INCLUDING MONA WHO WAS EUTHANIZED ON JUNE 21, 2007 AT THE BURMINGHAM ZOO)
 
THE FOLLOWING IS EXCERPTED FROM A LETTER THAT WAS WRITTEN  BY THE U.S. DEPARTMENT OF AGRICULTURE REGARDING THEIR RESPONSIBILITY TO ENFORCE THE ANIMAL WELFARE ACT IN RESPONSE TO A LETTER THAT WAS SENT TO THEM REGARDING  CONCERNS OVER ELEPHANT WELFARE.

"Our agency of the U.S. Department of Agriculture enforces the Animal Welfare Act (AWA)., which requires that people who exhibit animals to the public be licensed with us and meet our established minimum standards of animal care and treatment. Accordingly, these individuals must provide their animals with, among other things, a balanced diet, clean and structurally sound housing, protection from extremes of weather and temperature, and veterinary care. If an elephant or other regulated animal demonstrates tangible and/or clinical signs of a medical condition, exhibitors are required to have their attending veterinarian evaluate and address the problem. In addition, we enforce handling requirements designed to prevent the mistreatment of animals during training and performances. These standards prohibit the use of physical abuse to train or work animals and require exhibitors to handle animals in a manner that does not cause trauma, unnecessary discomfort, or behavioral stress."

Chester A. Gibson
Deputy Administrator
Animal Care

It has become increasingly more evident to the public over the last decade and in the past few years due to the premature deaths of many elephants in captivity, that elephants in circuses and zoos needs are not being met. In fact, in many cases the elephants are suffering from stress and medical conditions directly related to lack of exercise, being kept in tiny enclosures, lack of socialization, and even abuse, (such as in the case of circuses that use "bull-hooks" to train the elephants). Some of these medical conditions include, arthritis and foot diseases, unnatural behaviors such as head bobbing and swaying back and forth due to boredom and frustration, and premature deaths. Elephants normally live to be between 60 to 70 years old. Many elephants have died an untimely and miserable death after years of suffering at about half that life span. For example, at the Los Angeles Zoo alone, 13 elephants have died premature deaths.

Please sign this petition for these gentle, noble and highly intelligent magnificent animals, who although they cannot speak for themselves, are reaching out for help in the only way that they know how. All one has to do is see the sad conditions that these elephants are forced to endure and how miserable and depressed it makes them. Go to the zoo where you live if there is an elephant exhibit. Observe and open your eyes and your hearts, and then you will know the truth. Also, BOYCOTT circuses that have elephants. Most of them use BULL-HOOKS to train the elephants. If elephants need to be abused to be controlled, this is another reason THEY DO NOT BELONG IN CIRCUSES. There are alternatives, such as behavior modification and positive, loving reinforcement, that works. Besides, circuses and zoos do not provide elephants with the room that they require to walk several miles a day to maintain their health.

As depicted in a videotape released by People for the Ethical Treatment of Animals,  (PETA), "An elephant learns that a hook can cause pain when he or she is immobilized and beaten relentlessly by mahouts who repeatedly embed the pointed hook into the elephant's sensitive skin, causing bloody wounds. These sharp, metal hooks are regularly used to show and then remind the elephant who's boss. For elephants in captivity, many zoos have modernized their practices by disposing of bull-hooks and chains and instead using operant conditioning and protected contact to manage elephants. In protected contact, elephants are never dominated, punished, or forced to perform tricks. They learn to voluntarily cooperate with routine husbandry procedures through the systematic use of positive reinforcement only."

"A zoo really isn't conducive to the health of elephants and the feet are a large part of it. You just have to accept this as a chronic condition because you aren't going to cure it." - Blair Csuti, zoologist and editor of " The Elephant's Foot."

Chicago City Council Member Mary Ann Smith, chair of the City Council Parks and Recreation Committee, has introduced an elephant-protection ordinance that would require more space, better living conditions and improved treatment for elephants in the Windy City. The ordinance would mandate that any elephants brought into the city be given many acres to roam. It would also ban painful devices commonly used by circuses and some zoos to discipline elephants, including steel-tipped bullhooks and electric prods.

IDA has been working with PETA and Friends of Wankie to promote the ordinance. If the ordinance passes, Chicago will enjoy the strongest elephant-protection law in the U.S. and can be sure that no elephants will suffer the tragic and untimely fate of Tatima, Peaches and Wankie again in Chicago. Now that the ordinance and resolutions have been introduced, they will be voted on in upcoming committee hearings. If the committees vote in support of the ordinance and resolutions, the full City Council will vote on them at a council meeting. If this ordinance passes, it would be a landmark and set an example for the rest of the country in the care of elephants.

By signing this petition, the undersigned requests that the exhibition and exploitation of elephants in circuses and zoos be made illegal unless the needs of the elephants be met and abusive practices, such as bullhooks end. We also support the petition presented by, In Defense of Animals, the The Animal Welfare Act be enforced, a "petition seeking an interpretive rule and enforcement under the Animal Welfare Act to eliminate violations of the space and conditions regulations for elephants at zoos" ( and circuses). The full IDA Petition is below. Also, for more information go to: WWW. HELPELEPHANTSNOW. Please sign the "Free Billy Petition" from his tragic life at the Los Angeles Zoo. Go to;

http://www.thepetitionsite.com/takeaction/171715744

Also,go to -
 
http://www.petatv.com/tvpopup/video.aspvideo=carson_barnes&Player=wm
to watch a video of elephant cruelty using a bullhook.

 IDA PETITION: The petition seeks to compel the USDA to enforce the AWA provision requiring zoos and circuses to provide conditions consistent with elephants' health and well-being. It also asks the department to confiscate elephants suffering from "extreme cases of zoo-induced ailments." In a letter to IDA, Dr. Chester A. Gipson, deputy administrator of the USDA Animal and Plant Health Inspection Service, wrote: "We acknowledge that these are important issues and that many parties have an interest in them." The USDA agency will publish the IDA petition in the Federal Register to garner public response. "APHIS will review all information in determining what, if any, regulatory actions address the best interest of the animals," Dr. Gipson wrote.

The following is an excerpt  of the petition by IDA to the United States Dept. of Agriculture's Secretary Mike Johanns;

CITIZEN PETITION BEFORE THE
UNITED STATES DEPARTMENT OF AGRICULTURE

____________________________________
        )
IN DEFENSE OF ANIMALS        )
    131 Camino Alto, Suite E,        )
    Mill Valley, California 94941        )
                        )
        v.                )
                        )
MIKE JOHANNS                )        Docket No.______________
    Secretary of Agriculture        )
    U.S. Department of Agriculture    )
    1400 Independence Ave., S.W.    )
    Room 200A                )
    Whitten Building            )
    Washington, DC  20250        )
                        )
DR. CHESTER GIPSON            )
    Deputy Administrator            )
    Animal Care                )
    U.S. Department of Agriculture    )
    4700 River Rd                )
    Unit 84                )
    Riverdale, MD  20737-1234        )
____________________________________)


PETITION SEEKING AN INTERPRETIVE RULE AND ENFORCEMENT UNDER THE ANIMAL WELFARE ACT TO ELIMINATE VIOLATIONS OF THE SPACE AND CONDITIONS REGULATIONS FOR ELEPHANTS AT ZOOS

    Pursuant to the Right to Petition Government Clause contained in the First Amendment of the United States Constitution, the Administrative Procedure Act, and the U.S. Department of Agriculture%u2019s (USDA) implementing regulations, petitioner respectfully requests that the USDA issue an interpretive rule and enforce the Animal Welfare Act (AWA) and the agency's implementing regulations by requiring that zoos that exhibit elephants fully comply with the agency's adequate space and conditions regulations.  This action is necessary in order to prevent chronic and life threatening foot and joint problems that are the leading cause of suffering and premature death for elephants in zoos. Specifically, petitioner seeks the following
USDA should issue an interpretive rule explaining its adequate space and conditions rules for elephants at zoos, circuses and other exhibitors.  Petitioner requests that the interpretive rule specify the following:

(a) Inadequate space provided for captive elephants (including indoor and outdoor enclosures) and inadequate  conditions (including amount of time confined, type of substrate, and cleanliness of floors) cause foot and joint problems in elephants.  The presence of foot and joint problems in elephants is a sign that exhibitors are not meeting the AWA%u2019s requirements for adequate space and conditions.

(b)  Elephant enclosures shall be large enough to allow exhibited elephants to exercise similarly to how elephants exercise in the wild;

 (c) In order for USDA to effectively enforce the adequate space and conditions rules, elephant exhibitors are required to send their medical records to USDA regional inspectors quarterly to review.  Inspectors will review the records prior to visiting the exhibit and observe the physical condition of the elephant during their on-site inspections.  This visual observation includes picking up the elephants%u2019 feet to observe problems with the feet;

 (d) When the agency finds that elephants are suffering from chronic foot and joint problems, the agency will conclude that this is an indication of inadequate care, inadequate space and living conditions.  USDA will cite violators of the adequate space and conditions regulations and require that the exhibitor enlarge the space and improve the conditions or move the elephants to a better environment, such as a sanctuary; and

(e)  The agency will consider exhibitors to be in violation of the adequate care, space and conditions regulations when elephants develop chronic foot problems, and the symptoms of those problems are treated (through the use of antibiotics, anti-inflammatory and pain-killing drugs) without addressing the cause (inadequate space and conditions).  

USDA should immediately inspect all elephant exhibitors beginning with the zoos discussed in this petition that currently have elephants suffering from chronic foot and joint problems and confiscate elephants in poor condition.  These zoos include: National Zoo, Lee Richardson Zoo, Abilene Zoo, Reid Park Zoo, Los Angeles Zoo, and Cameron Park Zoo.
 
PETITIONER

Petitioner, In Defense of Animals, (IDA) is a nonprofit international animal protection organization dedicated to ending the exploitation and abuse of animals by defending and advocating for their rights, welfare and habitat. IDA%u2019s efforts include educational events, cruelty investigations, boycotts, grassroots activism, and hands-on rescue through its sanctuaries in Mississippi and Cameroon, Africa.

STATEMENT OF FACTS

Elephants, like humans, live in multi-faceted societies.  They are highly intelligent, possess complex emotions, exceptional memory and live unusually long lives.  They can remember other individuals after more than a decade of separation, and are capable of emotions such as joy, anger, grief, sympathy, playfulness, and revenge.  Numerous scientific observations suggest that: (1) Elephants recognize their own image in a mirror indicating that elephants are self-aware; (2) Elephants have the capacity for both empathy and anticipatory planning, including the possibility of imagining future events, such as pain to themselves and others; and (3) Elephants suffer long-term psychological effects of trauma and abuse, which may be expressed in the form of inappropriate and hostile behavior.  Taken together, these scientific discoveries show that USDA needs to fully enforce the AWA to ensure that captive elephants are provided with humane care.
USDA's action to ensure humane care should begin with examining the space allotted and conditions provided to captive elephants.  USDA's animal welfare regulations require that an exhibited animal must have sufficient space and be exhibited under conditions consistent with its good health and well being.  In assessing whether an animal has adequate freedom of movement, USDA looks at what is normal for the species under natural conditions.  In addition, USDA looks at the condition of the elephant to determine whether there is evidence of  inadequate space and conditions.
    The industry standards set by the American Zoo and Aquarium Association for Elephant Management and Care require 400 square feet indoors for a single animal and 600 square feet for a male or female with a calf.  Outside requirements are 1,800 square feet for a single animal with an additional 900 square feet for each additional animal.  This space standard is far different from what is normal for elephants under natural conditions (i.e. in the wild).  For example, elephant expert Joyce Poole explains that
    In Amboseli, elephants inhabit what is regarded as a relatively small area for wild elephants. Members of this elephant population range over approximately 5,000km2 [3,100 square miles].  Each elephant and its family have a core area of use encompassing at least 194km2 [120 square miles].  Elephants travel 8 to 20 kilometres [5-12 miles] a day, frequently walking further in areas of lower resource availability, or when a male is searching for females.  Figures for Asian elephants are similar with home ranges averaging 350 km2 [270 square miles] for males and 100 to 115km2 [62-71 square miles] for females and daily movements ranging between 8 to 22 km [5-14 miles].
    
    Clearly, the 400 square feet recommended by the AZA is a much smaller space requirement than the 120 square miles used by elephants under natural conditions.  Thus, USDA enforcement actions, as requested herein, should not overlook exhibitors following the AZA industry standards.  Even facilities that meet the AZA standards may have elephants that are in poor health, due to the limited amount of space provided, resulting in the exhibitor not being in compliance with the AWA.  
    Many of the health problems elephants have in zoos involve chronic foot and joint damage. This problem is widespread among zoo elephants and has become the number one cause of suffering and premature death for elephants at zoos.  More than 50 percent of captive elephants develop foot-related problems.  
    Experts agree that the reasons elephants at zoos are suffering from foot and joint problems are directly attributable to their inadequate space and living conditions.  For example, most elephants at zoos live on hard concrete surfaces and compacted soil, stand for long hours in their own waste, and are confined in small spaces for long periods of time prohibiting sufficient exercise.  Due to the inadequate amount of space and inappropriate living conditions, elephants are suffering from chronic foot and joint problems.
    This is a severe animal welfare problem that is contrary to the Animal Welfare Act and the agency's regulatory goals of providing humane care and protecting the health of exhibited animals.  Should the agency fail to address this problem, zoos will continue to lose their elephants to chronic foot disease and arthritis, the leading reason for euthanizing captive elephants.  Michael Schmidt, a veterinarian and expert in caring for elephants, explains that the unyielding surfaces that elephants are kept on cause zoo elephants' feet to become progressively worse, eventually taking a deadly toll.
    Although most elephants in zoos have foot and/or joint problems, wild elephants do not have these same problems.  The reason why wild elephants do not suffer from foot-related diseases is because they walk up to 18 hours a day on different substrates allowing the pads of their feet to remain healthy.  Captive elephants, on the other hand, stand in confined spaces on concrete and other unyielding surfaces in their own waste and urine for up to 16 hours a day.  (Elephants in zoos are commonly confined inside in barn stalls during off hours.) Due to this inactivity and such unclean and unnatural conditions, the pads on elephants' feet at zoos wear down very little leading to overgrown and cracked pads that are vulnerable to foot abscesses.  Experts agree that "elephants certainly didn't evolve to stand motionless for long periods of time" yet this is precisely how many elephants in zoos spend their days.
    An example demonstrating the correlation between inhumane and inadequate space and living conditions for zoo elephants and the development of chronic foot and joint problems occurred at the San Francisco Zoo.  At this zoo, all four elephants suffered for many years from chronic foot problems and lameness.  After the death of two of the elephants, (Maybelle, who died after collapsing and suffering for over twenty years with chronic lameness and foot problems and Calle, who was euthanized after suffering for almost ten years of chronic foot problems and lameness), the zoo was forced to review the living conditions for its elephants.  It was clearly evident that the zoo's facilities contributed to the elephants' chronic foot and joint problems and the zoo was forced to admit that its facilities were outdated and the elephants needed to live in a better environment.
After the two deaths, the zoo decided to transfer its two remaining elephants, Lulu and Tinkerbelle, in November 2004 to the Performing Animal Welfare Society's (PAWS) sanctuary in San Andreas, CA.  Unfortunately, this move came too late.  In March of 2005, Tinkerbelle was euthanized due to complications with her feet and degenerative joint disease.  Although the San Francisco Zoo transferred its remaining elephants to a place where the elephants' health could recover, it acted too late to save three of its four elephants.  This example shows the imperative nature of petitioner's requests and thus, the agency should respond quickly to prevent further animals deaths.
    Other elephant exhibitors are starting to recognize the correlation between inadequate conditions and space and chronic foot and joint disease.   For instance, the Detroit Zoo's Director, Ron Kagan, "is credited for being the first zoo director to voluntarily give up his elephants on humane grounds."  The Detroit Zoo decided to retire its two elephants, Winky and Wanda, to the warm-weather PAWS sanctuary because the elephants could not be properly housed and cared for in Detroit during the cold winter months.  Wanda had developed chronic arthritis and Winky was combating chronic foot problems.  The director recognized that when elephants are kept indoors during the winter, they cannot exercise and are forced to stand on unyielding surfaces making them prone to serious foot and joint disease.  The director explained that   "now we understand how much more is needed to be able to meet all the physical and psychological needs of elephants in captivity, especially in a cold climate." He believes that the elephants need "up to 20 acres of land to provide an adequate environment."  This amount of space is significantly larger than the one-acre enclosure in which Wanda and Winky lived at the Detroit Zoo.
    The San Francisco Zoo and the Detroit Zoo are among the zoos that have chosen to address inadequate space and conditions issues by retiring their elephants at sanctuaries.  PAWS in California is one sanctuary where elephants are being retired and another is the Elephant Sanctuary in Tennessee.  At these sanctuaries, elephants who struggled with foot diseases for numerous years are recovering.  Carol Buckley, a co-founder of the Elephant Sanctuary, has seen first hand how elephants that come to the sanctuary with severe foot problems "recover due to the vast amount of space that they have access to as well as improved living conditions which reflect a more natural environment, much like what they would experience in the wild."
    Although sanctuaries are saving the lives of many elephants with foot infections, most zoos are not choosing this option. Unlike the Detroit Zoo, many zoos are not preventing and eliminating the unnatural conditions that cause problems to elephants' feet and joints (such as getting them off concrete floors) and instead are trying to treat the problem by using pain-relieving medication, antibiotics, anti-inflammatories and medical interventions such as repeatedly trimming the rotting flesh of infected elephant feet.  These interventions do nothing to eliminate the underlying cause of the elephants' physical conditions and do not exempt zoos from providing humane living conditions.
    In order to protect the health of captive elephants, USDA needs to enforce the AWA.  The medical records from many zoos show that these zoos are violating USDA's regulations because their elephants are suffering from chronic foot and joint disease that is linked to the inadequate amount of space and conditions provided for their elephants.  Because foot and joint problems are the number one physical problem with elephants at zoos, USDA needs to take aggressive action by issuing an interpretive rule to clarify its regulations requiring adequate space and conditions for elephants at zoos.
    USDA's interpretive rule should explain that where elephants at zoos are suffering from chronic foot and/or joint problems due to inadequate space and conditions, USDA will enforce the AWA by requiring that these zoos either improve their space and conditions or relocate their elephants to a more suitable environment, such as a sanctuary, where the elephants' health can improve.  Since foot problems develop over time, USDA must ensure that zoos act to prevent foot and joint disease in younger, healthy elephants by providing them adequate conditions or relocating them to a sanctuary with appropriate living conditions. This interpretive rule should be backed by strict enforcement, including physical inspection of the elephant's feet and their medical records.  Only when elephants can live in a zoo designed to meet their biological and behavioral needs will the health conditions of these elephants be alleviated, allowing them to live healthy lives consistent with the intent of the AWA and the agency's implementing regulations.
STATEMENT OF LAW

Administrative Procedure Act, 5 U.S.C. 551 et seq.

Animal Welfare Act, 7 U.S.C. 2131 et seq.

Animal Welfare Regulations, 9 C.F.R. 1.1 et seq.

ARGUMENT

I.    USDA'S REGULATIONS REQUIRE THAT ENCLOSURES FOR     EXHIBITED ANIMALS PROVIDE SUFFICIENT SPACE AND     ADEQUATE CONDITIONS FOR THE ANIMALS.

    USDA's regulations specifically identify adequate space and conditions as an animal welfare requirement that must be met by exhibitors such as zoos.  These regulations explain that the amount of space and type of conditions must be adequate for the well-being of the animal.  
    The space requirement under 9 C.F.R. 3.128 states the following:
Enclosures shall be constructed and maintained so as to provide sufficient space to allow each animal to make normal postural and social adjustments with adequate freedom of movement.  Inadequate space may be indicated by evidence of malnutrition, poor condition, debility, stress, or abnormal behavior patterns.  

This regulation requires exhibitors to provide sufficient enclosure space for the animal by giving the animal adequate freedom of movement.  USDA has interpreted the term "adequate freedom of movement" to include the ability to exercise. The agency looks at "what is normal for that species under natural conditions."  In addition, the space requirement in 9 C.F.R. 3.128 specifies that inadequate space is evidenced by the animal's poor health. Thus, in order to determine whether a zoo is providing adequate space for an animal, such as an elephant, USDA looks at whether the enclosure is large enough to allow the elephant to exercise similarly to how the animal would move in the wild and USDA assesses the physical condition of the elephant at the zoo.  If an elephant is suffering physically and not receiving the amount of exercise that the elephant would get in the wild, then according to USDA's regulations, the zoo is violating the law.
     USDA's regulations also require that exhibitors such as zoos only exhibit animals under adequate conditions.  The regulation states that "animals shall be exhibited only for periods of time and under conditions consistent with their good health and well being."  Climate is a factor in determining whether conditions are adequate.  USDA regulations state that "when climatic conditions present a threat to an animal's health or well-being, appropriate measures must be taken to alleviate the impact of those conditions." As with 3.128, these regulatory sections also provide that the health of an exhibited animal should not be harmed by their living conditions.   Clearly, the health of an exhibited animal is a crucial factor used by USDA to determine whether the exhibition facility meets USDA's animal welfare regulations. Therefore, in applying these regulations to elephants, if an elephant at a northern zoo is housed in a small enclosure with hard unclean floors during the winter months and suffers from chronic foot and joint problems, then according to USDA's regulations, this zoo is violating the law.
    The evidence presented below shows that zoos are providing elephants with inadequate space and living conditions that are affecting their health and well being. Experts have documented the link between small enclosures and unnatural living conditions at zoos with elephants' foot and joint problems.  USDA should act consistently with its own regulations by inspecting zoos and protecting the health of exhibited elephants by requiring exhibitors to eliminate these AWA violations.

II.    ELEPHANTS IN ZOOS ARE SUFFERING FROM CHRONIC FOOT AND     JOINT PROBLEMS CAUSED BY INADEQUATE SPACE AND     LIVING CONDITIONS

    Elephants at many zoos are standing on hard concrete flooring, in their own waste for 16 hours or more, and in small confined spaces for long periods of time, especially during the winter at northern zoos, without sufficient exercise.  Experts agree that these factors are causing chronic foot and joint disease in elephants that can lead to death.  This correlation between foot and joint disease in elephants and inadequate enclosure space and living conditions is visible and prevalent at zoos across the country.  
Expert Opinion Explaining the Correlation Between Foot and Joint     Disease in Exhibited Elephants and Inadequate Space and Living     Conditions at Zoos.

    Experts agree that chronic foot disease and arthritis are the major causes of suffering and premature death for zoo elephants.  Elephant experts have identified hard flooring, unclean living conditions, and inadequate space as the primary causes of these physical problems.   To protect the health and well being of elephants, most zoos need to take immediate action by either alleviating or preventing foot and joint disease through improving the elephant's space and living conditions or moving the elephants to sanctuaries where their needs can be met.
    1.    Concrete Flooring

    Elephant experts have identified several causes for foot and joint diseases in elephants. First, concrete flooring is one of the main reasons exhibited elephants have foot problems.  Elephant experts explain that "[w]e believe that elephants spending the majority of their lives on hard surfaces such as concrete or asphalt are more prone to foot problems than elephants housed on softer or more natural substrates." Despite this information, the use of concrete flooring at zoos is widespread.  In a survey conducted among the elephant exhibitors around the country, 91 percent of exhibitors indicated that they have concrete floors and over half believed that there was a relationship between concrete flooring and foot disease.  
    In the wild, elephants walk on soft substrate such as grass, mud, clay, and sand that give under their feet allowing their toenails to dig into the earth.  These natural conditions allow elephants' feet to wear normally.  The natural conditions in the wild are in sharp contrast to the hard concrete flooring at most zoos.  This type of flooring has no give and thus, the elephant's feet wear abnormally because the animal is walking flat-footed.  Walking everyday on hard concrete surfaces can cause the elephant's pads to wear too thin, harming the underlying tissue, which can then lead to abscesses of the foot.
    Elephant expert Dr. Schmidt explains that due to the daily abuse from standing on hard flooring, "the elephants' feet become chronically infected by bacteria and fungi.  My experience has shown me that concrete flooring injures and kills elephants."  He further explains that:
" . . . over time, the daily accumulation of damage from standing and walking on flat concrete floors tends to cause joint injury and predisposes the elephant's feet to infection from abnormal wear.  As the joints and feet become progressively injured by life spent on a concrete floor, the pain the elephant feels makes it reluctant to move around as much on its sore legs and feet.  This creates a vicious circle and downward spiral of pain, followed by less movement, causing further injury, causing more pain, causing even less movement, etc.  It is a continuous, gradual process that does its damage bit by bit and this damage continues hourly, daily, weekly, monthly and through the long decades of an elephant's life in the zoo. "

    Elephant experts repeatedly point out that natural substrates should be used to prevent and alleviate foot and or joint problems because this type of substrate allows an elephant to dig and exercise and strengthen leg and foot muscles, tendons, and joints.  This exercise and activity directly supports healthy feet throughout the elephant's life. This information from elephant experts shows that rather than housing elephants on hard concrete flooring, elephants should live on softer, more natural and resilient yielding surfaces.  This change in the elephant's living conditions will help to prevent and alleviate the elephant's foot and joint problems.
    2.    Unclean Living Conditions

        Another factor that causes foot and joint problems for zoo elephants is their unclean living conditions.      Because elephants are kept in small confined spaces for long hours, they cannot avoid standing in their own urine and waste.  Most elephants have to stand in their own urine and feces for up to 16 hours during zoo off hours, until the zoo keeper comes in and cleans out the stalls.
    Elephant feces contain harmful bacteria and the urine damages the tissues of their feet.  As a result of the abnormal wear on the concrete floor, fissures and cracks develop in the feet allowing dung and urine to get inside the feet and cause harm.  When elephants get foot infections, it is difficult to treat and cure because antibiotics often do not reach the curative levels in the foot and the healing is delayed due to poor blood supply to the affected tissue.  There is also a real danger to zoo keepers and veterinarians in treating elephants with these painful conditions.  
    3.    Inadequate Space

    Finally, one of the most common causes of foot problems in elephants is due to inadequate space.  By confining elephants into small quarters and limiting their movement, they receive an inadequate amount of exercise.  Elephant experts explain that healthy feet require exercise of all joints, tendons, and ligaments.  Anything less predisposes an elephant to foot problems, especially later in an elephant's life.  Other elephant experts confirm this by stating that elephants that have significant daily exercise seem to have fewer foot problems than elephants that primarily stand throughout the day.
    Despite the physical needs of elephants, requiring sufficient space to exercise for the health of their feet, the AZA only requires that its members give an elephant a minimum of 400 square feet of indoor space and at least 1,800 square feet of outdoor space.  This amount of space is highly criticized by many elephant experts.  One former zoo curator explains that the AZA standards for elephant enclosures are far from adequate.  These standards are comparable to putting a 100 pound Labrador dog into a 5 feet by 6 feet bathroom for its entire life.  The Royal Society for the Prevention of Cruelty to Animals issued a study identifying the animal welfare problems at zoos in Europe and explained that even the minimum AZA and the European AZA standards for elephant enclosures are 60 to 100 times smaller than the smallest wild territories.  Elephants at AZA accredited zoos are known to be suffering physical problems due to the inadequate amount of space in their enclosures, clearly indicating that the AZA standards are not benefiting, but rather harming the health of exhibited elephants.  
    The AZA and some other members of the zoo community argue that there is no scientific evidence that elephants require ample space and suggest that elephants only move in the wild because they have to.  This conclusion, however, is not supported by the great amount of empirical evidence showing the spatial needs of elephants are vast. For example, Amboseli Elephant Research Group scientist Joyce Poole states that the evidence that elephants need more space is unmistakable. She goes on to explain that in captivity, confined in small spaces, under the constant command of a trainer and kept in socially deprived conditions, elephants become dysfunctional, unhealthy, depressed, and aggressive.  Inactivity leads not only to obesity, but also to foot diseases, joint problems, and arthritis.  Female zoo elephants are 31-72% heavier than their wild counterparts.   
    Wild elephants, on the other hand, do not suffer from the same ailments, such as foot disease, arthritis, and weight related diseases, as elephants in captivity. Poole explains that
in Amboseli, where the life histories of over 2,000 free-ranging elephants have been followed for 34 years and where elephants grow up in a nurturing social environment, have the freedom to move, and autonomy over their own lives, elephants do not develop foot or weight problems as they do in zoos.  Of the 2,200 elephants that have lived in Amboseli over 34 years of study, not one has had foot (other than those inflicted by humans), arthritis, or problems with overweight. In over 34,000 sightings of groups containing 1 to 550 elephants, not one elephant has been seen swaying rhythmically back and forth or showing other neurotic behaviour ultimately caused by lack of space.

    There are some zoos that exceed the AZA standard by giving elephants between one and three to four acres to move, however, even this amount of space is far from adequate.  Elephant expert Dr. Schmidt explains that while "such space may be adequate for a couple of domesticated horses or cows, it is far below the necessary space required to meet the biological and behavioral needs of these largest of the living land animals."                   Furthermore, it is important to note that even if a zoo provides a significant amount of outside space, if it is located in a cold and wet northern climate, then the elephant will spend several months confined indoors.  By warehousing elephants for the winter, zoos severely limit the amount of space elephants have to move.  Many experts conclude that the problems with elephants feet and joints will not be alleviated in northern zoos because of the inability for a northern zoo to provide the elephant with adequate space to exercise.  It is precisely this reason why the elephants from the Detroit Zoo were moved to a sanctuary.  
    Elephant experts consistently agree that elephants in many zoos have an inadequate amount of space for sufficient exercise.  For example, elephant expert Dr. Schmidt polled a dozen experienced elephant keepers at a seminar and only two thought that their elephants had enough space. Furthermore, in a survey conducted of elephant experts, only 32 percent of the participants said that their elephants receive more than 30 minutes of exercise a day.  Over half of the participants thought that there was a relationship between inactivity and foot disease and 80 percent thought that a priority should be given to giving elephants more exercise.  
    The evidence also shows that elephants in zoos live two decades less than elephants in the wild.  One of the main reasons for this difference is because elephants in the wild walk up to 18 hours a day over different substrates.  This amount of exercise protects their feet and joints from deterioration and is in sharp contrast to the 30 minutes a day of exercise many elephants receive in zoos.  To prevent and alleviate the foot and joint problems from which elephants in zoos suffer, the amount of space at zoos must be significantly increased to give elephants a sufficient amount of room to exercise.
    In conclusion, elephant experts agree that if the current inadequate space and living conditions for elephants at most zoos (consisting of hard flooring, unclean living conditions, and inadequate space to exercise) are eliminated, then the majority of the foot and joint problems in captive elephants would disappear.  USDA should enforce the AWA regulations by requiring zoos to alter the current space and living conditions to reflect a more natural environment for elephants or move their elephants to a place, such as a sanctuary, that can meet their needs.  

Examples of Zoos Where Elephants Have or Currently Are Suffering from Chronic Foot and Joint Problems Due to Inadequate Space and Conditions

    Several zoos have voluntarily decided to transfer their elephants to sanctuaries after determining that their facilities were inadequate to provide their elephants with sufficient care.  Other zoos have not taken this step and are currently exhibiting elephants even though their inadequate facilities are causing their elephants to suffer from chronic foot and joint problems.  
    In over 20 years, at least 38 exhibited elephants have died due to chronic foot and/or joint problems.  Because foot and joint problems are wide-spread among exhibited elephants, it is imperative that zoos and USDA act to prevent further elephant deaths.  Petitioners request that USDA rigorously inspect zoos by examining elephants feet, medical records, and living conditions.  By reviewing all of these factors, petitioners believe that USDA will find that the health of elephants is declining as a result of the inadequate living conditions provided at exhibitor facilities.  Based on this information, USDA must act in accordance with its own regulations by requiring that exhibitors either improve living conditions to meet elephants needs or transfer elephants to another environment that can meet their needs, such as a sanctuary.
1.    Examples of zoos that have transferred their elephants to sanctuaries after recognizing that the zoo did not have adequate facilities to properly care for the elephants         

San Francisco Zoo

    At the San Francisco Zoo, all four elephants, Maybelle, Calle, Tinkerbelle, and Lulu, suffered from foot and joint problems for many years.  After the death of two elephants, Maybelle and Calle, the zoo was forced, through strong public pressure, to review the living conditions of its elephants.  The zoo was criticized for holding the elephants in small, antiquated enclosures.  The enclosures consisted of 17,000 square feet for the Asian elephants and 10,000 square feet for African elephants.  These small enclosures prevented the elephants from getting sufficient exercise and forced them to stand on hard, dry compacted surfaces.
    The medical records of Maybelle demonstrate that she suffered from chronic foot and joint problems.  The staff at the zoo identified problems with Maybelle's feet and lameness approximately 750 times from September 1983 until her death in January 2004.  Calle also suffered from chronic foot and joint problems.  The zoo staff identified problems with her feet and lameness approximately 1678 times from Oct 1995 to March 2004.  
    The number of times these elephants suffered from problems with their feet and lameness is extraordinarily high.  In addition, their conditions were ongoing for numerous years.  These on-going problems should have prompted zoo staff to assess the elephants' living conditions as required by the AWA regulations.  These regulations state that inadequate space may be indicated by evidence of the animal's poor condition.  To determine whether the elephants had adequate space and living conditions, the zoo should have looked at whether the enclosure was large enough to allow the elephants to exercise similarly to how the elephants would move in the wild.  In this case, 10,000 square feet for Maybelle (African enclosure) and 17,000 square feet for Calle (Asian enclosure) is extremely small, given that elephants in the wild walk up to 100 kilometers (over 62 miles) in a day.
    The regulations further state that animals shall only be exhibited under conditions consistent with their good health and well being.  At the San Francisco Zoo, the elephants were kept on hard surfaces far different from the soft substrate on which elephants walk in the wild.  The medical records show that for at least 20 years, the San Francisco Zoo ignored these AWA regulatory requirements and did nothing to significantly alter the living conditions for Maybelle or any of the other elephants who suffered from similar foot and lameness problems.
    Rather than changing the living conditions for these animals by giving them more space to exercise and getting them off the hard substrate, the zoo repeatedly gave the elephants painkillers.  Maybelle, for example, was given pain-relieving medication repeatedly for at least four years and Calle was given pain-relieving drugs for at least five years.   This type of treatment was not successful because it did not improve the condition of their feet. Instead, the condition of their feet continued to deteriorate.  The zoo staff even admitted in assessing Maybelle's condition that there was no significant improvement in her mobility since being on the pain killers.  The ongoing physical problems combined with the unnatural living conditions (small enclosure and hard substrate) should have alerted the staff that the elephants' poor health was connected to their inadequate living conditions.  
    Finally, after the death of Maybelle and Calle, the zoo director decided to move Tinkerbelle and Lulu to the Performing Animal Welfare Society (PAWS) Sanctuary.  The zoo admitted that it's facilities were outdated and they wanted a better environment for the elephants and the zoo believed that the welfare of both the elephants . . .was at stake.  To ensure that the zoo does not exhibit more elephants in these small, outdated enclosures, the San Francisco Board of Supervisors passed a law requiring the zoo to meet strict conditions, including devoting at least 15 acres to the elephant habitat.
    Tinkerbelle and Lulu were moved to the PAWS sanctuary in November 2004.  Unfortunately, the move came too late for Tinkerbelle because she had to be euthanized not long after arriving at PAWS Sanctuary.  Like Maybelle and Calle, she also suffered chronic foot and joint problems.  Lulu is the only elephant still alive from the San Francisco Zoo.  She also suffered from recurring foot and lameness problems while at the zoo. Now that she is living in a more natural environment at the PAWS sanctuary , she is doing well.
    USDA needs to enforce the AWA regulations to prevent more elephant deaths like the ones at the San Francisco Zoo.  Despite the medical records showing that its elephants suffered chronic foot and lameness problems, the San Francisco Zoo did not change the elephants' inadequate living conditions and as a result, three of its four elephants died.  These elephant deaths could have been prevented if zoo staff had acted in accordance with the AWA regulations by removing the elephants from their inadequate living conditions before their health had completely deteriorated.
Detroit Zoo

    Unlike the San Francisco Zoo, the Director of the Detroit Zoo moved its two elephants, Wanda and Winky, to a sanctuary before ill health due to inadequate living conditions killed them. Detroit Zoo Director Ron Kagan retired the elephants  to the warm-weather PAWS sanctuary. Wanda had developed chronic arthritis and Winky was combating chronic foot problems.   Kagan found that the elephants could not be cared for properly in the zoo's one-acre elephant exhibit, particularly during the winter when they were confined in small stalls.  Kagan concluded that, without normal movement, the elephants' foot and joint disease would become life-threatening.  
He explained:  "Now we understand how much more is needed to be able to meet all the physical and psychological needs of elephants in captivity, especially in a cold climate."   Kagan explained further that the zoo would need to provide "up to 20 acres of land to provide an adequate environment" for these elephants.   The amount of space needed to adequately exhibit the elephants is far greater than the one-acre enclosure in which Wanda and Winky resided at the Detroit Zoo.
The Detroit Zoo is an example of a zoo acting in accordance with the AWA space and conditions regulations.  Here, the zoo director did not ignore the causes of the elephants' foot and joint problems.  He recognized that the health of the elephants was being jeopardized because the elephants could not adequately exercise when they were housed in small enclosures, especially during the winter months.  This lack of exercise was causing the elephants to develop chronic foot and joint problems.  Therefore, consistent with the AWA regulations, the director moved the elephants out of an exhibit that did not have adequate conditions and into a sanctuary with an environment that would benefit their health.
2.    Examples of zoos where elephants are currently suffering from chronic foot and joint disease due to inadequate space and conditions and therefore, require immediate USDA inspection

    There are numerous zoos throughout the country where elephants are suffering from chronic foot and joint disease caused by inadequate space and living conditions.  A few examples of zoos with these problems are the Smithsonian National Zoological Park (National Zoo), Lee Richardson Zoo, Abilene Zoo, Reid Park Zoo, Los Angeles Zoo, and Cameron Park Zoo.  As explained below, the elephants in these zoos are being held in inadequate conditions and are experiencing severe foot and joint problems.  As a result, USDA must immediately inspect these zoos and enforce the adequate space and conditions regulations.
    The National Zoo euthanized a 46-year old female African elephant named Nancy in August 2000 due to severe and chronic foot abscesses that had progressed to osteomyelitis (infection of the bone).  Before she was euthanized, Nancy had difficulty standing and developed pressure sores from leaning at night to take the pressure off her feet.  In the last months of her life, she was reported to be holding her right foot off the ground and leaning her head against the bars of her indoor stall.
A January 26, 2000 entry in Nancy's medical records reads, "Reported for lameness left front, stiffness right front . . . All the elephants have been housed indoors continuously for the past few days due to the extreme cold weather.  The floors are extremely hard (cement) and this may have exacerbated her lameness.  . . . A:  Lameness, forelimb R/O digitial osteomyelitis, hard substrate. . . . Consider recommending application of permanent soft flooring for this geriatric elephant."     
   Zoo staff treated Nancy's foot infections with extreme measures, among them frequent intravenous infusions of antibiotics through veins in her feet and stuffing antibiotic "bullets" into the abscessed cracks of her feet by plugging them with "tampons". The records do not indicate that the staff ever dealt with the cause of her problems.  Soft flooring does not appear to have been brought in and no attempt was made to relocate this elephant from these inadequate conditions.
    On June 26, 2000, National Zoo veterinarians noted that Nancy had an infected "sole defect" on her right foot that was 10 centimeters long and 5-8 centimeters wide.  A month later, the records state that Nancy's right foot was "swollen and painful", noting infection and "breakdown of tissue."  This elephants " condition continued to decline." She was euthanized on August 22, 2000.
    The National Zoo had to euthanize another elephant on January 25, 2006, a 39-year old Asian elephant named Toni suffering from severe arthritis. Medical records for Toni from June 17, 2005 report "very acute lameness" and "keeper reported that she seems more tender in hard surfaces."  The records also note that Toni is "hesitant to go down sternal on concrete" and she was observed "Cleaning her rear end against the wall as if trying to relieve some weight from the rear legs."  Toni's medical records document the long term use of Ibuprofen between 1997 and 2001, at which time, it was stopped due to concern about renal toxicity. She was later put back on pain relieving medication despite toxicity concerns because of her extreme discomfort.
    Another Asian elephant, 57 year-old Ambika, also suffers from lameness.  Medical records show that Ambika has repeatedly been on Ibuprofin the past few years.
    In the six years since the zoo euthanized Nancy from a condition known to be exacerbated by concrete, the National Zoo still keeps the elephants on hard surfaces inside the barn (concrete with one area of poured rubberized flooring) and hard compacted earth.  Zoo staff continued to treat the elephants' symptoms without addressing the cause of their problems  inadequate space and hard substrates.
Mel Richardson, DVM, a zoo and wildlife veterinarian with 36-years experience with elephants and other animals observed Toni before she was euthanized and wrote:
When I saw Toni on January 4th, 2006, I was appalled.  I have never seen an elephant in such a debilitated condition.  Toni is an elephant at least 2,000 pounds underweight with an almost contorted posture.  She moved carefully, placing each foot with deliberation and consideration as to its position.  She tried not to put much weight on each step, as if walking on eggs.  All the while she was leaning back onto her rear quarters, obviously keeping weight off of her front legs.  Her spine looked curved and her pelvis was twisted.  The fact that I could see her spine, shoulder blades, and hip bones was beyond belief.  I had expected her to be in poor shape, but this was more than I could have ever imagined.  

Dr. Richardson disagrees with the zoos attempt to blame Toni's condition on a leg injury she suffered 20 years ago at another zoo.  He states:
Elephants in the wild have sustained fractured legs and even ankylosed carpal joints, like Toni.  They have been seen to recuperate and go on to live almost normal elephant lives, albeit with a limp.  Had Toni had access to an adequate environment with enough space to roam and a natural substrate, I am certain that she could have better dealt with her injury and would not be in such a condition as today.  Toni's exhibit only allowed for exacerbation of her injury.  Lack of exercise caused muscle atrophy, removing the muscular support needed to sustain healthy joints and standing on concrete increased the trauma to joint surfaces initiating degenerative joint disease while walking on sand literally rubbed down her pads, thinning her soles and increasing her pain . . .

Dr. Richardson explains further that veterinarians are trained to prevent pain and suffering, not just treat it.  The veterinarians at the National Zoo cannot prevent the painful degenerative arthritis because "the cause of the crippling degenerative joint disease is the exhibit itself:  the concrete; the packed unyielding abrasive substrate inside and outside; the lack of exercise and normal use of the elephants feet and limbs climbing, digging, walking, wading into streams, kicking logs, and foraging . . . "
    Dr. Joyce Poole of the Amboseli Elephant Research Project in Kenya agrees with Dr. Richardson's assessment.  She explains:  
I believe that Toni's debilitating condition is caused by much more than an old leg injury.  Her condition is indicative of many of the problems experienced by captive elephants and symbolizes the dismal consequences of long-term lack of space and movement. Unfortunately, Toni is yet one more statistic, adding to the overwhelming amount of empirical evidence, showing that elephants do need sufficient space and social and environmental enrichment to maintain agility and good physical health.

The elephants at the National Zoo, including Nancy and Toni, have had ongoing foot and lameness problems for many years and the staff has even suspected their living conditions as a cause of the problem.  The medical records show, however, that the zoo failed to act in accordance with AWA regulations by removing the elephants from the inadequate living conditions. As a result, both Nancy and Toni had to be euthanized. Given this information, USDA should ensure that other elephants do not die at National Zoo by immediately inspecting Ambika and the other elephant's feet, medical records, and living conditions and require this zoo to either significantly improve the conditions under which it confines elephants, or relocate the elephants to a sanctuary where their needs can be met.
The Lee Richardson Zoo has two African elephants, Chana and Moki, who have suffered from foot problems and lameness since at least 1993.  These elephants are housed on hard concrete flooring and in extremely small enclosures.  The two indoor enclosures are 363 and 427 square feet.  The medical records from this zoo reveal that the elephants' feet are in poor condition and cite to their living conditions as possible causes.  For instance, the staff identified that the pads on the elephants' feet had "deteriorated from being on wet cement so much of the time."
The elephants at this zoo have had ongoing foot and lameness problems for at least 12 years and the staff has suspected their living conditions as a cause of the problem, however, the medical records show that the zoo has not acted in accordance with AWA regulations by removing the elephants from the inadequate living conditions.  Given this information, USDA should immediately inspect the elephants' feet, medical records, and living conditions. Based upon this information, USDA must require this zoo to either significantly improve the conditions under which it confines elephants, or relocate them to a sanctuary where their needs can be met.
    The Abilene Zoo has two African elephants, Tanzy and Tanya, with foot problems.  The elephants are housed in extremely small enclosures that consist of a 360 and a 324 square feet stalls.  As with the Lee Richardson Zoo, the staff at this zoo highlights the inadequate living conditions.  The medical records for Tanya state that the elephant's feet reveal "definite signs of standing in excess water for extended periods of time."  
On an inspection of the zoo in November 2004, the American Zoo and Aquarium Association noted that the floors of the barn were not sloped enough to allow urine and water to run off the floor "forcing the elephants to stand in moisture during the time they are in the barn."  To prevent these elephants from continuing to suffer from foot problems caused by their wet flooring and small enclosures, USDA should immediately inspect this exhibitor and require that this zoo act consistently with AWA regulations by not holding these elephants in inadequate conditions.
    The Reid Park Zoo elephants, Shaba and Connie, both suffer from recurring foot problems since at least 2000.  The indoor enclosure is 1390 square feet and the outdoor enclosure is only approximately 1/3 of an acre.  The zoo staff admits that Connie has chronic problems with her feet.  Zoo records also include an Elephant Management Plan that highlights recommendations from a group of elephant experts called the Elephant Taxon Advisory Group.  They recommend larger complex exhibits to allow the elephants to be more active which is needed for their well-being.  In reviewing the recurring foot problems with these elephants and the zoo's small enclosures, it is evident that this zoo is not acting in accordance with USDA's space and conditions regulations.  Thus, USDA should inspect these facilities and require the zoo to act consistently with USDA regulations by requiring that zoo give these elephants adequate space and living conditions or relocate them to a sanctuary.
    The Los Angeles Zoo's Asian elephant, Gita, has suffered from foot problems since at least 1977.  In 1993, the staff noted that her foot problems were chronic.  Although the Los Angeles Zoo has made changes to the living conditions for the elephants, such as giving the elephants access to the yard at night and heating the barn floors, Gita still suffers from ongoing chronic foot problems.  Les Schobert, a former general curator at this zoo believes that Gita continues to suffer from foot problems because "for many years she was confined in a small enclosure and lived on hard concrete flooring" and continues to live in conditions that do not meet her needs.  Specifically, Gita lives in a very small enclosure.  She shares approximately 6,000 square feet with another elephant and stands on hard concrete flooring and hard compacted soil. Because Gita's condition has been ongoing for at least 27 years, the USDA must inspect this zoo by examining Gita's feet, reviewing the medical records, and assessing her living conditions.  Clearly, the changes this zoo made have not been sufficient to improve Gita's condition.  USDA needs to act in accordance with its adequate space and conditions regulations by requiring this zoo to make more significant improvements to Gita's living condition or move her to a sanctuary environment that will benefit her health.  
    The Cameron Park Zoo's African elephants, Tembo and Zoe, both suffer from recurring foot and lameness problems.  These problems have been ongoing since at least 1998 for Tembo and 1999 for Zoe.  The zoo staff recognizes that the major causes of foot problems include, inadequate exercise and wear on the feet, hard substrates, obesity, and wet and/or dirty conditions. Although the staff understands the causes of foot problems, it is not evident that any changes have been made in their living conditions.  Therefore, USDA should inspect this zoo's living conditions and the condition of the elephants' feet and then recommend changes in the living conditions by either significantly improving conditions at t
Dear Administrators,

THE FOLLOWING IS EXCERPTED FROM A LETTER THAT WAS WRITTEN  BY YOU, THE U.S. DEPARTMENT OF AGRICULTURE REGARDING  YOUR RESPONSIBILITY TO ENFORCE THE ANIMAL WELFARE ACT IN RESPONSE TO A LETTER THAT WAS SENT TO YOU ABOUT  CONCERNS OVER ELEPHANT WELFARE.

"Our agency of the U.S. Department of Agriculture enforces the Animal Welfare Act (AWA)., which requires that people who exhibit animals to the public be licensed with us and meet our established minimum standards of animal care and treatment. Accordingly, these individuals must provide their animals with, among other things, a balanced diet, clean and structurally sound housing, protection from extremes of weather and temperature, and veterinary care. If an elephant or other regulated animal demonstrates tangible and/or clinical signs of a medical condition, exhibitors are required to have their attending veterinarian evaluate and address the problem. in addition, we enforce handling requirements designed to prevent the mistreatment of animals during training and performances. these standards prohibit the use of physical abuse to train or work animals and require exhibitors to handle animals in a manner that does not cause trauma, unnecessary discomfort, or behavioral stress."

Chester A. Gibson
Deputy Administrator
Animal Care


It has become increasingly more evident to the public over the last decade  that elephants in circuses and zoos needs are not being met. In fact, in many cases the elephants are suffering from stress and medical conditions directly related to lack of exercise, being kept in tiny enclosures, lack of socialization, and even abuse, (such as in the case of circuses that use "bull-hooks" to train the elephants). Some of these medical conditions include, arthritis and foot diseases, unnatural behaviors such as head bobbing and swaying back and forth due to boredom and frustration, and premature deaths. Elephants normally live to be between 60 to 70 years old. Many elephants have died an untimely and miserable death after years of suffering at about half that life span. For example, at the Los Angeles Zoo alone, 13 elephants have died premature deaths.

We, the undersigned, ask that you please seriously consider the In Defense of Animals Petition that was submitted in February, 2006 and all of the public input and comments as well as the continued suffering and further deaths of elephants held in captivity in unnatural conditions (most recently Mona, who had to be euthanized at the Birmingham Zoo on June 21, 2007). This petition seeks to compel you, USDA to enforce the Animal Welfare Act provision requiring zoos and circuses to provide conditions consistent with elephants' health and well-being. It also asks the department to confiscate elephants suffering from "extreme cases of zoo-induced ailments." In a letter to IDA, Dr. Chester A. Gipson, deputy administrator of the USDA Animal and Plant Health Inspection Service, wrote: "We acknowledge that these are important issues and that many parties have an interest in them." The USDA agency will publish the IDA petition in the Federal Register to garner public response. "APHIS will review all information in determining what, if any, regulatory actions address the best interest of the animals," Dr. Gipson wrote.

In lieu of all the information, public outcry and the documented suffering and deaths (IDA Petition for one) of these gentle, noble and highly intelligent and magnificent animals, it is respectfully requested that the USDA, (APHIS) review the undeniable testimony and truths that elephants, in fact, do not belong in circuses, zoos or amusement parks where their very sensitive requirements are not being met. Circuses, zoos and amusement parks do not provide elephants with the room or the correct terrain that they require to walk several miles a day on to maintain their health. Also, the brutal practice of using bull-hooks and other pain inflicting methods on elephants is not conducive to their health and well-being, and is an abusive practice that we respectfully request be banned.

We are in deep gratitude for your consideration and respect to this matter of profound concern to so many of us.
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