June 3, 2007
Ron DeHaven
Administrator, Animal and Plant Health Inspection Service (APHIS)
U.S. Department of Agriculture
4700 River Road
Riverdale, MD 20737
Re: "Maggie" the elephant
Dear Mr. DeHaven:
As a concerned citizen, I am writing to request that the USDA act to
facilitate the immediate removal of the elephant "Maggie"
from the Alaska Zoo. Maggie has recently been twice found lying
prone and unable to rise, first on May 13 of this year, then again on
May 16. It is clear that Maggie's health has been severely
compromised; should the situation be allowed to continue, it is
possible that she may die.
Legal basis for the USDA to take immediate, strong action in this
case is provided by the failure of the Alaska Zoo to meet the
requirements of the Animal Welfare Act (AWA). A 2003
"Report from Elephant Committee to Alaska Zoo Board of
Directors" contains the following statements: "Our
management system is limited to our resources and training. We
are currently unable to do basic health management procedures."
The committee was composed of zoo board members and personnel; thus
this admission constitutes a frank violation of the AWA.
Additionally, the Zoo lacks an elephant restraint device, necessary
for veterinary treatment and husbandry purposes and thus critical to
Maggie's care. It lacks a scale for weighing elephants,
necessary for general care and for determining drug dosages when needed.
It lacks the equipment necessary to lift an elephant, and was forced
to depend on the Anchorage Fire Department to provide emergency
assistance in the two recent crisis situations. It lacks a
veterinarian with expertise in elephant care, and failed to call in
such a veterinarian on those occasions when Maggie was found lying
prone and unable to rise. It failed to adequately monitor
Maggie after the first time she was found down, with the result that
she lay prone six or seven hours on the second occasion. Beyond
all this, the Zoo has also demonstrated itself unable to provide
Maggie with the social and physical conditions she needs to maintain
her health and well-being on an ongoing basis. Because of weather
conditions, she is confined indoors much of the year in a
1600-square-foot pen with a concrete floor. Concrete flooring is
known to cause foot and joint disorders in African elephants. A
treadmill has been provided for exercise, but it has never been used.
And, despite the fact that elephants are well known to be highly
social creatures, Maggie remains without the companionship of others
of her species.
The Animal Welfare Act requires exhibitors to maintain their animals
under conditions conducive to their health and well-being. It
demands that appropriate facilities, personnel and equipment be
available to treat health problems, and that adequate veterinary care
be provided. It also requires that appropriate space be given
"to make normal postural and social adjustments with adequate
freedom of movement," and states that "Inadequate space may
be indicated by evidence of malnutrition, poor condition, debility,
stress, or abnormal behavior patterns."
By its own admission, and by the factual circumstances surrounding
Maggie's recent health difficulties, the Alaska Zoo demonstrates its
failure to meet the obligations imposed by the AWA. It is the
job of USDA-APHIS to make sure that compliance with such obligations
be met, and that those exhibitors who fail to meet these obligations
be appropriately dealt with. In the case of the Alaska Zoo, its
failures are evident. Maggie, at only twenty-seven years of
age, would normally still have decades of life ahead of her. If
she is not moved to a more adequate environment, that life may well
be denied her. It is incumbent upon the USDA to ensure that
this does not happen.
Yours sincerely & etc. . . .
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