April 25, 2013

Association of Zoos and Aquariums
Jim Maddy, President and CEO
8403 Colesville Rd., Suite 710
Silver Spring, MD 20910-3314

Sent via email: jmaddy@aza.org

Dear Mr. Maddy,

On behalf of In Defense of Animals (IDA), an international animal protection organization, I am writing to you regarding the San Antonio Zoo’s recent statement that it plans to keep the zoo’s surviving elephant Lucky, alone. It is our understanding that the zoo’s director, Steve McCusker, is requesting a variance from the Association of Zoos and Aquariums (AZA) in order to keep Lucky as a solitary elephant. IDA urges you to deny the variance request.

As you know, a second female elephant at the zoo named Queenie (a.k.a. Boo) died last month. This leaves the zoo, and Lucky, in the same position they were in prior to Queenie’s arrival in 2010.

The AZA has long recognized that female elephants are profoundly social and should not be housed alone. According to a guideline set forth by the AZA Standards for Elephant Management and Care, zoos should maintain elephants in groups of three, as follows:

2.2.1.1 Suggested age and sex structure of social group
Each zoo holding elephants must hold a minimum of three females (or the space to hold three females), two males or three elephants of mixed gender. If a zoo cannot meet this standard, they must apply for a variance.

In addressing a variance meant to bypass the above guideline, AZA guidelines (sec. 2.2.1.1) require the following:

Before the variance can be issued by the Accreditation Commission the zoo (a) must describe their plan to obtain additional elephants or describe their plan for deacquisitioning their elephants and (b) must describe what will occur if they experience the loss of one elephant. In most cases where an institution has one remaining elephant, the remaining elephant will receive a recommendation for relocation at another AZA institution from the Elephant TAG/SSP.

A zoo spokesperson recently stated that the zoo has no plans to bring in another elephant. In filing a variance request, the zoo indicates it intends to keep Lucky indefinitely as a solitary elephant. The AZA states in its guidelines it will not grant variances after September 2016, and it appears that variances are granted for a period of one year. IDA therefore questions what will happen to Lucky following 2016, even assuming that the AZA considers it acceptable to approve back-to-back, one-elephant variances for the next three years. If zoos can bypass AZA regulations so easily and consistently by requesting variances, what is the point of establishing guidelines? The only way to prevent the San Antonio Zoo from remaining in noncompliance is for the AZA to order the transfer of Lucky immediately to a facility with other elephants.

This cycle of acquiring elephants, and requesting variances when one dies, appears to be an ongoing problem at the San Antonio Zoo. The AZA granted the zoo a temporary one-elephant variance in 2008 after Alport died, and again in 2009, giving the zoo until March of 2010 to find another elephant. This is a clear indication that the AZA did not believe it was appropriate for Lucky to remain alone. Surely it is no more appropriate a mere three years later.

In reaching a decision to keep Lucky alone, the zoo has offered numerous excuses as to why this is an appropriate option. A zoo spokesperson recently stated that Lucky “is not a social animal” and that “she prefers to be alone, by herself.” Lucky has had several companions over the years and was reportedly bonded with Ginny, who died in 2004. This claim that Lucky is anti-social was either not made by the zoo in 2009 when the last variance was granted, or it was made, evaluated and deemed by the AZA to be an insufficient basis for overcoming the standard requiring companionship. It should not be given weight here.

The zoo’s director, Steve McCusker, also claims that moving Lucky could be risky and he “believes moving her or getting her a new partner would be detrimental to her health,” and “the stress [of a move] would probably kill her.” Elephants are frequently transferred to other facilities. There is no demonstrated reason that Lucky cannot be conditioned for a transfer. McCusker for years has claimed that Lucky is in good health; if her health has in fact deteriorated to the extent that her life is now at risk, IDA strongly urges an immediate veterinary evaluation to determine the cause of such a rapid deterioration.

IDA has ongoing concerns about Lucky’s health, if she remains at the zoo. According to a report by a local advocacy group, Lucky has been observed to regularly engage in stereotypic behaviors, indicative of compromised welfare or stress. Lucky’s feet often are observed to display tenderness, redness, swelling, and cracks. The zoo has been documented treating Lucky’s feet, and a former zoo veterinarian says Lucky suffers from arthritis. None of these issues should preclude a move, and in fact all stand as excellent reasons that Lucky should be moved to a facility with more space, softer substrates, and companionship.

IDA strongly maintains that, even if acquiring another elephant and obtaining another variance would be practicable, it should not be permitted. There have been aggression issues between elephants at this zoo for years, including between Lucky and Queenie, which was likely exacerbated by the lack of space for careful introduction or for retreat.

The zoo has stated for years it has long-term plans to house only African elephants in an expanded habitat. If transition to an African theme is still the plan, it would seem advantageous for the zoo to send Lucky to another facility now so it could focus on plans to move in this direction, rather than simply delaying the inevitable move of Lucky until she develops genuine health issues that would make a move more challenging.

IDA urges you to deny the San Antonio Zoo’s one-elephant variance request and work with the zoo to relocate Lucky to a more appropriate facility that can offer her companionship with other elephants and adequate space. The AZA’s guidelines state in Sec. 2.2.1.1 (b), “In most cases where an institution has one remaining elephant, the remaining elephant will receive a recommendation for relocation…” There is no valid reason to ignore the social needs of this elephant, Lucky, and keep her alone at the zoo.

Sincerely,

Nicole Meyer
Director, Wild & Free – Elephant Protection Campaign
Nicolem@idausa.org
206-920-2819

cc via email: Martha Fischer—Chair, AZA Elephant TAG; Coordinator, AZA SSP; fischer@stlzoo.org