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Petition to Amend Animal Welfare Regulations to Prohibit Public Contact Response

Dear USDA/APHIS:

As an accredited zoological institution, we have some serious concerns with the proposed changes.

First, there seems to be no evidence to warrant the proposed changes.  In all of the areas out for question (i.e. contact with dangerous animals, classification of additional dangerous animals, training, handling of young animals, etc) there seems to be no evidence or frequency of violations provided that would warrant such changes.  At best, there are only a few isolated incidents and at worst, the changes represent the ideals of an extreme minority of people that oppose all animal interactions and ultimately the public display of animals.

As you review nearly all of the support for the changes, they only share how they “feel” or make vague statements with no evidence or experience to support their position. However, taking into account the millions of people that visit USDA-licensed facilities every year without incident, it is clear evidence that current USDA/APHIS oversight is sufficient.  In addition, thousands of experienced professionals that directly dedicate their lives to care for these animals oppose these changes.

More specifically, these changes would have a significant impact on our mission, which is to strengthen the connection between people and the natural world through interactive experiences with animals like Indian rhinos, pygmy hippos, and ring-tail lemurs.  The new changes would threaten these experiences and rob the public of the opportunity to connect a little more.  In addition, we use these experiences to raise money to fund in-situ projects for the International Rhino Foundation, Cheetah Botswana, and more.   Ending these experiences would cut the funding we send to those worthy organizations.  Finally, all of the stations are supervised and help raise funds to support our zoo.  Unlike most zoos in the US, we are family-owned and unsubsidized by any level of government.  Therefore, the funds from those experiences help provide money to care for our animals in the winter, when we are closed to the public.  The proposed changes would threaten the sustainability of our facility and affect the following:

  • Negative economic impact on the local community of 12 to 15 million dollars because many of our visitors are from out of town
  • Loss of more than 70 jobs
  • Several hundred thousand dollars in lost tax revenue
  • 15 to 20k school kids, scouts and special needs kids that visit our facility annually
  • Displacement of more than 400 rare and endangered species when space is at a premium
  • 37 successful breeding programs for rare and endangered species, many of which are unique to our facility

Second, whether an animal is suitable for public contact should depend on the individual animal and observable behavior.  Very few (if any) professional exhibitors just blindly allow an animal to have contact with the public.  It is a process.  Trained handlers spend hundreds of hours with the animal observing their behaviors. They test them little by little to determine how they will handle different situations.  In the end, the people that have worked with the animal can and should make the determination if an animal is suitable.  At the same time, professional handlers work within guidelines currently established by USDA and accrediting bodies to ensure they handle and train the animals in a manner that is both safe for the public and the animal.  In other words, there is no reason for USDA/APHIS to put further restrictions on permit holders.  The current regulations are sufficient and there has been no proof otherwise.

Third, the term “dangerous” is relative and varies significantly from person to person.  Most of the characteristics used to define dangerous animals by USDA don’t inherently make an animal dangerous.  Fear and speculation seem to be driving what animals should or should not be on the list.  Just because an animal is large or a carnivore, doesn’t mean it is immediately going to cause mass casualties.  A great example would be the Mexican Red-knee tarantula, a large spider that is perceived by the public as dangerous, but it is relatively harmless.  Aside from the characteristics mentioned above, the personality of the animals can also be significantly different.  We have had large cats that you would never work with and some that you could have worked with into adulthood.

Another example would be domestic dogs. More people are attacked by domestic dogs annually than all exotic animals combined.  You could potentially even limit that to a breed of domestic dog like pit bulls or Rottweilers.  However, I doubt they are being considered for the list even though some people fear them as much as or more than wolves.

 

You can’t put all animals into nice little dangerous and non-dangerous boxes according to species.  Discretion should be given to the professionals (especially those at accredited institutions) to determine whether a species is capable of being handled and in what settings, taking into account public safety and animal welfare.  I think there should be a significant number of violations of public safety before considering whether a species should be added to the list.  Violations would include attacks causing physical harm that requires professional medical attention (emergency room, paramedics, etc. – something beyond a band-aid) or transmission of actual disease to/from that a particular species. Otherwise, incidents should be attributed to an individual animal or isolated incident.

 

As I mentioned, we allow contact with Indian rhinos, pygmy hippos, and ring-tail lemurs that are all on the dangerous animal list or may be added to it.  There have been zero incidents, which is proof that just because a species is large or has a reputation for aggression doesn’t mean it should necessarily be on the list or restricted from contact. USDA/APHIS guidelines are sufficient to ensure people can safely interact with these species and there is no evidence based on the criterion above that would require USDA/APHIS to add the proposed animals to the list.

 

Fourth, there are very few documented cases (if any) of zoonotic diseases transferring between people and animals.  There are some diseases such as Herpes and Tuberculosis that can be transmitted between certain species of animals (dangerous or not). However, USDA already requires stringent veterinary care for permit holders, especially exhibitors.

 

Individual institutions can easily determine if the animal is a threat to the public.  There are minimal risks to the individual animals.  While a small portion of the public believe that contact is stressful and detrimental to the animals, the opposite is true if a person is following current USDA guidelines for handling animals. Most (if not all) enjoy the contact like your dog or cat and it serves as a form of enrichment.  Currently, there is no data supporting public contact with animals being stressful.  All of the information is based on opinion and anthropomorphism.

 

Fifth, positive reinforcement has been widely accepted and used for every species.  It even works with the most dangerous animals of all… Humans.  Just because they are labeled as “dangerous” and put on a list doesn’t mean they can’t be trained in the same fashion.  USDA/APHIS has guidelines concerning training that are currently sufficient.

Sixth, our facility has bred more exotic cats than any other and had a significant impact on the captive populations of several species.  With our nearly 30 years of experience hand raising big cats, we have found hand-reared cats are better adjusted to zoo life. This is not our opinion, but based on directly observing the behavior of hundreds of animals over the past 30 years.  For instance, we have found big cats more easily adjust to new environments and stress less when transported to new exhibits or facilities. Another example regards breeding. Species like the clouded leopard can easily stress and zoos were having trouble breeding them.  Through hand-rearing the cubs, zoos could acclimate the cubs to humans and zoos could had more control over when and how cubs were paired for breeding. While we do not advocate for hand-rearing all species of animals, our experience as one of the most successful breeding facilities in the world for big cats is proof that hand-rearing big cats is an acceptable husbandry technique, as it does not affect their ability to socialize with other cats and better prepares them for life in a managed environment.  Arguments to the contrary of our experience are based on anthropomorphism and cannot be supported by science or otherwise.

In regards to it being stressful for the mothers, there is no evidence of that.  This is another example of people anthropomorphizing the animals.  In many cases the mothers will eat their young if we do not pull them.  This is especially true of many first time mothers.

In conclusion, we strongly urge USDA to side with the thousands of professionals that have direct experience on this matter and reject this petition.

Sincerely,

Jim and Sherri Fouts and our entire team at Tanganyika Wildlife Park

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