USDA seeking Public Comments on Elephant Petition

Speak out to improve living conditions for elephants in zoos

The U.S. Department of Agriculture (USDA) is currently seeking public comments on space and living conditions for captive elephants in the U.S. This important decision is a result of intense media and public scrutiny of the plight elephants in zoos and circuses. It also follows the submission of a citizen's petition by In Defense of Animals to the USDA seeking enforcement of the Animal Welfare Act’s adequate space provision at zoos and circuses.

Specifically, the USDA is seeking comments on all aspects of elephant care, including lack of space, unnatural substrates, unnatural social groupings, and use of bullhooks, chains, electric hotshots and other instruments of force commonly used to control elephants.

Despite the poor condition of elephants, zoos are mobilizing their members to defend the status quo.








Please submit your comments to USDA by December 11.

What You Should Say

Please tell the USDA that you support all efforts to dramatically improve conditions for captive elephants in this country, including enforcing existing adequate space requirements under the Animal Welfare Act (as requested in the IDA Citizens Petition) and creating tough new standards that:

• Require exhibitors of elephants to provide large, naturalistic, climate-appropriate environments similar to those at The Elephant Sanctuary in Tennessee and the PAWS sanctuary in California. These two refuges provide hundreds to thousands of acres over which elephants can roam, socialize and maintain their health. 
• Prohibit the use of bullhooks, chains, electric shock devices and other instruments of force against elephants. 

Why Change is Needed

The reasons why the USDA must take action include: 

1. Zoos and circuses are not giving elephants the conditions they require for their health and well-being. 

2. The Animal Welfare Act requires that zoos and circuses provide elephants with adequate space. Zoos are not meeting this requirement. 

3. Elephants are big animals who need big spaces. But in too many zoos and circuses they suffer from lack of space, unnatural conditions and social deprivation that eventually cause a range of preventable ailments -- from painful arthritis and foot disease to reproductive and digestive disorders to neurotic behaviors like swaying and head bobbing.

4. Many zoos lock their elephants in barn stalls for at least 12 hours a day when the zoo is closed. And, in northern zoos, elephants are confined indoors for extended periods during the cold winter months. 

5. Additionally, circuses and many zoos control their elephants through force, domination and aggressive use of the bull hook and prolonged chaining. These methods cause constant stress as well as physical and psychological injury to elephants. 

6. Because of their intelligence, complexity and unique social and physical needs, elephants suffer in small, unchallenging zoo environments. Because of these unique qualities and complex needs, elephants deserve much, much higher standards than the ones that currently exist. 

It is critical that the letters are personalized and in the writer’s own words. Please feel free to talk about your personal experience seeing elephants in zoos and/or circuses, your profession, whether you are a parent who wants his or her children to be properly educated, etc. A personalized letter will have much more impact than a form letter.

How to Submit Your Comments

Via Internet: 

By postal mail, send an original and three copies to:

Docket No. APHIS-2006-0044
Regulatory Analysis and Development, PPD, APHIS/USDA
Station 3A-03.8
4700 River Road, Unit 118
Riverdale, MD 20737-1238

For more information, see or call Suzanne Roy at 919-732-8983 or email her at