ZAA

WHAT IS ZAA?

and

WHY SHOULD ZAA ROADSIDE ZOOS NOT BE EXEMPT FROM LAWS BANNING PRIVATE OWNERSHIP OF BIG CATS?

2021 UPDATE RE ZAA POSITION ON THE BIG CAT PUBLIC SAFETY ACT:

When the Big Cat Public Safety Act was first introduced a few of the roughly 60 ZAA zoos, most notably "Doc" Antle's operation in Myrtle Beach, offered cub petting, so ZAA opposed the bill. By 2020 Antle was no longer a ZAA member and no other members offered cub petting. Once that was the case, the bill no longer affected ZAA zoos exhibition offerings since it exempts USDA licensed exhibitors as long as they do not offer cub petting.

In Spring 2020 issue of their Journal ZAA announced that they had adopted new rules prohibiting cub petting, explaining to members that public contact was “the core issue accounting for the majority of the negative PR” they were receiving. At the time we thought “wow, they have grown up.” An April news report indicated that they had abandoned their opposition to the bill and were now neutral. https://www.eenews.net/stories/1062798701. The news report also noted that the same lobbyist who represents ZAA also represents Antle, who still offers cub petting.

Early this year ZAA suddenly reversed position and announced they oppose the provisions of the bill that ban public contact, a political position that is in direct contradiction to their own standards which forbid cub petting and a provision that does not affect any of their members in any way. We have no way to know what role their lobbyist played in this decision. But if he supported it, it raises in our mind the question of whether their lobbyist is working in their best interests or representing Antle’s interests at their expense, particularly given their own admission that most of their negative PR was due to support of cub petting.

As part of their argument to membership for this change in position, ZAA states that "This bill places enforcement under the FWS putting the agency in direct conflict with the USDA Animal Welfare Division. FWS is not structured to handle inspections and enforcement" (emphasis added). This raises the spector of zoos being inspected by both USDA and FWS. The only time FWS would visit any of their facilities is if there was a report of illegal cub petting, which ZAA zoos can avoid by simply abiding by their own standards and not offering cub petting. And there is absolutely no "conflict" between USDA and FWS.  The bill does not change USDA's role at all except possibly making their inspecting job easier since without the cub petting that drives 90% of the breeding there would likely be fewer tigers for USDA to inspect.

ZAA actually did the "right thing" in the spring of 2020 by ending cub petting by their members and ending their opposition to a bill that would stop so much misery. We believe the organization and its members are now being misled by false arguments into  taking a position that is contradictory to their own standards.

AZA vs. ZAA. The large zoos with high standards of care in the United States are accredited by a well established and respected professionally run organization called the Association of Zoos & Aquariums, commonly known by the acronym AZA.

While AZA zoos are not “perfect” and as a sanctuary we differ in philosophy in certain ways from zoos, the important things to understand about AZA in our opinion are that they have generally established high standards of animal care, they have a strong history of providing veterinary care, they do not do cub petting or photo ops with tiger cubs or other big cat species, they breed under a science based Species Survival Plan where they track the genetic history of the animals to maintain pure bred subspecies so the animals can have some conservation value, they do not breed freak hybrids like ligers, they do not breed the genetically defective and heavily inbred white tigers.

Also important is that AZA does very intense multiday inspections by a team of independent experts before accrediting or renewing the accreditation of a zoo, and will decline to renew an accreditation if the standards are not met.  One example is discussed below.

In contrast, ZAA (Zoological Association of America) is primary a collection of road side zoos who have chosen a name that has an acronym deceptively close to AZA.

ZAA typically claims that it is the “little guy’s AZA,” that it maintains high standards, that it does thorough independent inspections before “accrediting” member zoos, that it somehow supports or enhances conservation and education, in particular that holding baby tigers supports conservation, that there is some value to breeding freak hybrids like ligers and tigons that do not appear in nature, and that a USDA exhibitor license means the animals are treated humanely.

Upon closer examination we believe you will find that NONE of these statements are true and that ZAA is simply a clever, well marketed sham intended to give a legitimate façade to roadside zoos that regularly violate the Animal Welfare Act, support abusive practices like cub petting, breed freaks that do not occur in nature, mistreat animals and mislead the public for profit.

And, importantly, this mistreatment is totally UNNECESSARY from a business standpoint.  There are many financially successful sanctuaries and zoos that treat animals well and that provide a truly educational experience for visitors.  The claim by ZAA zoos that they need engage in activities that inherently mistreat animals like cub petting and performances in order to survive financially is contradicted by the many good operators who succeed because they do NOT engage in these abusive practices.

Below we address each of what we believe are the misrepresentations typically made by ZAA.

Standards.  One revealing example is the size of enclosure required for big cats. For two tigers AZA requires 1800 sf, the size of a small house, and a pool to swim in.  ZAA allows two tigers to spend their entire lives in a 19’ x 19’ sf concrete, chain link box, with no pool. To put this in terms of human conditions, the difference between the two standards is like the difference between living in a nice modest size house and living in a refugee camp tent. Two tigers spending their lives in the small ZAA enclosure would be like letting a domestic cat spend its entire life in a large dog carrier.  Who would consider that humane?

Inspections. As with standards, a few examples show the ZAA claim that they do meaningful inspections to be false. The inspection for acceptance into ZAA for the Wright Park Zoo took a mere 2.5 hours and was done by two individuals, one of whom was the clearly not independent vet for that zoo. The Montgomery Zoo was accredited without even the pretense of an inspection, i.e. no inspection at all.

There is simply no legitimate comparison to be made between ZAA’s minimal or nonexistent perfunctory inspections to the intense multi day, multi faceted inspections by experts done by AZA.  And AZA actually enforces its standards and will fail to renew a zoo’s accreditation for violations. This happened in 2008 to Lowry Park Zoo in Tampa after the zoo terminated CEO Lex Salisbury for mismanagement. Salisbury had been a long time advocate of private ownership and involved in the formation of ZAA in 2005.  To this day he is on the Board of Directors of ZAA. After his departure from Lowry the new management returned the zoo to meeting AZA standards and was reaccredited by AZA.

Dual accreditation.  One of the ways ZAA creates the illusion of legitimacy is to point to a few members who are also accredited by AZA. Why would a zoo who meets the much higher standards of AZA allow its name to be associated with a bunch of roadside zoos in ZAA?

As noted above, AZA actually enforces its standards. In particular, as evidence has mounted that most elephants suffer horribly in traditional zoo environments and AZA has raised its standards of care for elephants, a few AZA zoos do not want to comply with the elephant standards or other high AZA standards. The most often suspected reason for AZA zoos joining ZAA is to gain leverage to push back at AZA with the threat that if AZA presses them too hard to comply, the zoo will drop its AZA accreditation and only be ZAA accredited, believing, most likely correctly, that members of the public will be none the wiser due to the confusingly similar acronyms.

ZAA sometimes points to these few members who are AZA accredited as examples of the institutions they accept, misleadingly suggesting that these are representative of the ZAA population. In fact these few zoos that are also accredited by AZA are outliers, and most ZAA zoos operate far, far below AZA standards to say the least.

Conservation. ZAA claims that holding tiger cubs somehow educates people and causes them to be more concerned about conservation. In fact, the opposite is true. There is significant and growing empirical evidence that allowing people to interact with wild animals increases the public’s demand to keep those animals as pets, undermines conservation efforts by decreasing public awareness about the plight of endangered species, and decreases support for conservation programs. When true sanctuaries and good zoos give guided tours where people view adult tigers and learn about them from the guide or from audio recordings, the visitors can learn. People who are petting tiger cubs are not listening. If they learn anything at all they learn the wrong message, i.e. to want exotic animals as pets.

For more detail on cub petting see CubTruth.com

ZAA further claims that the breeding done at its zoos has a conservation purpose. Except for breeding that may be done under the Species Survival Plan (SSP) by the few AZA accredited zoos that are in ZAA, none of ZAA’s breeding enhances conservation. To have conservation value, captive breeding of endangered tigers and other jeopardized species must be carefully managed to preserve genetic integrity, as is done under the SSP. ZAA zoos do not track the genetic history of their animals. In the case of tigers, the tigers that are rampantly bred by ZAA zoos for cub petting are all tigers of mixed subspecies, generally inbred, who are referred to as “generic,” “junk,” or “mutt” tigers and have no conservation value whatsoever. Breeding horribly inbred and genetically defective white tigers and breeding freak hybrids like ligers is also done at ZAA facilities and sends a misleading message that is inconsistent with conservation principles.

Finally, the rampant breeding of tigers and other big cats, and the lack of tracking requirements and mechanisms in the United States, impairs U.S. efforts to urge other nations to conserve the tiger in the wild. China, which seeks to legalize tiger farming, claims that raising and slaughtering tigers to supply the market for their parts will curb poaching of wild tigers. In fact, the opposite is true.   Increasing the supply by tiger farming would expand the overall market, thereby creating an increased demand for wild tiger products and providing more incentive to poach. China is able to undermine U.S. opposition to tiger farming by correctly pointing out that the U.S. has also failed to restrict the breeding and sale of privately owned captive big cats.

A few states have ZAA exemptions. ZAA likes to point to a few states that have exempted ZAA along with AZA from legislation banning private ownership of big cats. What ZAA never points to are the states like California, Texas, Louisiana and Michigan, and Clark County, Nevada, that rejected heavy lobbying efforts by ZAA, recognizing what we view as their sham “standards.” In Michigan, Governor Rick Snyder rejected efforts to exempt ZAA from the law, stating that doing so “could lead to gaps in public health protection and animal welfare.”

So how did ZAA get exempted from exotic ownership bans in a few states? It started in Ohio. In 2011, after years of having no state laws on exotic animals, Ohio saw the horror of the Zanesville massacre in which Terry Thompson released over 50 dangerous animals and committed suicide and law enforcement officers had to shoot most of the animals. When Ohio decided to pass a law banning private ownership of dangerous exotic animals, Governor Kasich turned to local celebrity Jack Hanna from the Columbus Zoo for advice.

Why would Jack Hanna want to exempt ZAA? When Hanna appears on television with animals, viewers assume that his animals come from the Columbus Zoo and live there in conditions consistent with AZA standards. But it is well known among industry insiders that many of Jack Hanna’s “Ambassador Animals” used on popular late night and morning television shows do not actually come from the AZA accredited Columbus Zoo, as viewers would expect. While the animal handlers seen with Hanna are often wearing Columbus Zoo uniforms, many of these handlers do not actually work for the Columbus Zoo. They are in many cases private breeders, exotic animal owners, or from roadside zoos like ZAA zoos and from entertainment animal “brokers.”

To seek exemption in other states ZAA cleverly hired Alan Smith, its Executive Director until late last year. Smith was previously the Chairman of ALEC (American Legislative Exchange Council) where he became very well known to state legislators and had a history of advocating for laws that diminished animal protection and safety, like so called “ag-gag” bills. Smith was a smooth talker with strong personal connections in some state legislatures and managed to leverage the Ohio law to mislead a couple other states into exempting ZAA.

A USDA license does NOT insure humane treatment. ZAA claims that USDA regulation is all that is needed to insure humane treatment. This is not true. USDA cites many bad actors, including many ZAA zoos, year after year for many years with no action except continued citations. In some cases USDA finally, after years of citations, levies a fine. The fines on average are discounted 86% from what Congress authorized. The cases most often settle for a few thousand dollars, simply a modest cost of doing business for the violators. Very, very few violators, only the very worst of the worst, lose their license. And even then, we frequently see them simply continue to operate under someone else’s license. Thousands of animals live in miserable conditions, including those at ZAA zoos, despite USDA efforts at enforcement of the Animal Welfare Act. Below is a chart showing a sampling of the kinds of serious citations almost half of the ZAA “accredited” zoos have received from USDA.

For more detail on why regulation does not work visit https://bigcatrescue.org/abuse-issues/issues/why-regulations-dont-work/

Public Safety. Tim Harrison, Retired Police Officer/Firefighter/EMT-Paramedic, and currently an Adjunct/Instructor for TEEX/National Emergency Response and Rescue Training Center at Texas A&M College's Disaster City, has this to say about ZAA's failure to have concern for the safety of the public and safety of first responders:

"What bothers me the most is that the ZAA has constantly fought us on basic public safety regulations/laws that would protect the real first responders ( Law Enforcement Officers, Firefighters, EMT-Paramedics and Animal Control Officers) to big cat escapes, attacks and owner releases. ZAA does this to continue their agenda of breeding, selling and exhibiting big cats to the uneducated and untrained public, a money making business. I consider the ZAA , "Animal Pimps", caring little for the safety of the animals or the public (Public Safety Officers). ZAA believes that anyone should be able to buy and own a large predatory animal, that should be enough for any prudent person with common sense to know that this group is bad. As I always say, you can buy a tiger but you cannot buy common sense".

In the words of Sheriff Matt Lutz of Zanesville, Ohio, whose officers sadly had to shoot and kill 50 big cats and other large dangerous animals in the notorious incident where they were let loose by their owner in 2011,

“Our deputies go through immense training, a lot of different training on how to handle emergencies. But handling exotic animals is not part of our training, and neither should it be. So that's the first thing that comes to mind when you try to start talking about acquiring these things, is the pressure that it puts on the local sheriff's office or local police departments. Not to mention that once we handled our situation, the stress and trauma that it caused each individual officer.”

There is simply no reason to subject the public or law enforcement officers, who already put their lives on the line every day, to the additional unfamiliar and unnecessary danger of big cats being exhibited at roadside zoos.

Conclusion. ZAA is an organization that deserves credit for only one thing: doing a masterful job of marketing itself as an accrediting body that has high standards of animal care and enforcing them. In our view this is nothing more than a sham, providing the appearance of legitimacy to a collection of roadside zoo exploiters of animals who as a group consistently mistreat animals for profit, and not only do not foster conservation but promote activities and messages that HARM conservation.

ZAA HISTORY OF ANIMAL WELFARE ACT VIOLATIONS

ZAA (The Zoological Association of America), whose acronym is deceptively similar to the well respected AZA (Association of Zoos & Aquariums), misleading presents itself as the “little guy’s AZA.”

In actual fact ZAA is for the most part a collection of roadside zoos that as a group have a history of serious violations of the Animal Welfare Act like failure to provide adequate medical care. Below are a sampling of such violations and some incidents that occurred at 25 of the 61 “accredited” zoos.

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	FACILITY	LOCATION	NOTES
1	Bearizona	Williams, AZ	2016 cited for animals killed by other animals. 2014 cited repeatedly for failure to provide adequate veterinary care to sick animals and for allowing an unqualified employee to administer anesthesia. Transferred a black bear to Lee Greenly, owner of Minnesota Wildlife Connections, who had previously allowed a customer to illegally kill a captive-reared bear contained in a 3 acre enclosure with a bow-and-arrow. (Greenly’s USDA license was revoked for more than a dozen violations.)
2	California Living Museum	Bakersfield, CA	2016 cited for failure to observe animals on a daily basis, failure to promptly communicate health issues with the attending veterinarian, failure to separate incompatible animals.
3	Catoctin Wildlife Preserve	Thurmont, MD	2009 cited for failure to adequately train and appropriately supervise employees after a keeper who was on the job only two months was mauled by two jaguars. 2007 cited for failure to provide minimum required space to three bears.
4	Cougar Mountain Zoo	Issaquah, WA	2015 USDA issued official warning for failure to provide veterinary care to an emaciated animal.
5	Gulf Breeze Zoo	Gulf Breeze, FL	Cited repeatedly for failing to provide sufficient public safety barriers around primate cages. Cited for an untrained and unsupervised intern who allowed the escape and subsequent death of an animal.
6	Have Trunk, Will Travel	Perris, CA	Cited for unsafe handling of elephants during rides. According to In Defense of Animals HTWT was caught on video viciously beating elephants, using an electric shock device, and striking a baby elephant over the head and pulling her trunk. These elephants were also observed chained for 12 hours a day, barely able to move back and forth, let alone walk.
7	Lion Habitat Ranch	Henderson, NV	Cited for allowing public to have unsafe contact with adult lions. 2010 cited for declawing 2 lion cubs.  Affiliated w https://911animalabuse.com/predators-unlimited/
8	Montgomery Zoo	Montgomery, AL	2014 cited for failure to provide veterinary care to newborn rhino that subsequently died. 2012 cited for failure to provide minimum space to a black bear kept in a cage where the bear could not even stand upright on her hind legs. 2013 visitor scratched by jaguar. 2014 fined $8107 by USDA for the escape of a tiger and a hyena from poorly maintained cages, a barn fire that killed to animals, allowing unsupervised contact with animals in the petting zoo, and failure to repair rusty primate cages. Accredited with no inspection at all.
9	Myrtle Beach Safari	Myrtle Beach, SC	AKA T.I.G.E.R.S. Kevin Antle. 2016 cited for failure to have an adequate veterinary care program for a recurring problem of tiger cubs infected with ringworm. (Ringworm is typically caused by filthy conditions and is highly contagious to humans.) US Fish & Wildlife Service denied application to export and re-import 18 tigers to and from Mexico citing, among other things, substandard conditions. One of the most notorious cub petting operations, supplier of cubs to other cub petting operations. Warehouses tigers in box stalls in a horse barn.
10	Oswald's Bear Ranch	Newberry, MI	Cited for using physical abuse on bear cubs used for photo ops and for allowing children to have unsafe contact with the bears.
11	Panther Ridge Conservation Center	Wellington, FL	2010 jaguar tore off woman’s thumb. 2008 owner Judy Behrens attacked by two cheetahs during fund raising event and airlifted to hospital. 2009 cited for declawing two clouded leopards.
12	Pittsburgh Zoo & PPG Aquarium	Pittsburgh, PA	2016 cited for failure to provide seas lions with shade and unhealthy chlorine levels in their pool, both of which may contribute to long history of sea lions with painful eye disorders at the facility.  An internal USDA document contained a list identifying facilities with animals who were at risk of tuberculosis due to exposure to Hawthorn’s elephants including Pittsburgh Zoo.
13	Safari Niagara	Stevensville, Ontario, Canada	2008 fined $2000 after pleading guilty to making a false statement to a conservation officer regarding native wildlife kept at the facility.
14	Six Flags Discovery Kingdom	Vallejo, CA	Cited for unsafe public contact with an elephant. 2014 several university students bitten during petting session with 3 month old lion cubs. 2014 cited for the deaths of two dolphin calves apparently related to poor water.
15	Southwick's Zoo	Mendon, MA	Used for public rides an elephant named Judy from the notorious Hawthorn Corporation. Judy had previously almost killed people on a rampage at a church event. A few years later all of Hawthorn’s elephants were seized for abuse. In 2010, another performing elephant named Dondi became ill and died at the Southwick's Zoo at the young age of 33. She had been housed alone at Southwick's and forced to do tricks for audiences. A necropsy revealed that Dondi's molars had fallen out and that her lungs were riddled with tuberculosis, which is transmissible to humans. As of 2015, Southwick's had contracted with a California-based elephant rental company, "Have Trunk Will Travel," to provide elephant rides at the zoo. According to In Defense of Animals HTWT was caught on video viciously beating elephants, using an electric shock device, and striking a baby elephant over the head and pulling her trunk. These elephants were also observed chained for 12 hours a day, barely able to move back and forth, let alone walk.
16	Tanganyika Wildlife Park	Goddard, KS	Cited for allowing lemur to have contact with human infant
17	Triple D Game Farm	Kalispell, MT	2013 Cited for declawing 2 month old tiger cub. Dealt w/ Big Cats of Serenity Springs.
18	Two Tails Ranch	Williston, FL	Owned by circus. 2013 woman hospitalized for months with life threatening injuries after attack by elephant. Zoo failed to report the attack, fined $857.
19	Virginia Safari Park	Natural Bridge, VA	2016 10 year old girl hospitalized from camel bite. Settled for $155k.
20	Wild Wonders	Bonsall, CA	Cited repeatedly for failure to provide animals with minimum space, filthy rodent infested conditions and feeding a diseased goat carcass to wolves.
21	Wildlife World Zoo and Aquarium	Litchfield Park, AZ	2016 cited for failure to provide supplemental heat to 59 primates housed outdoors in 36 degree temperature – numerous primates were huddled together shivering. Cited for failure to provide adequate shelter from the cold, filthy and rodent infested conditions, inadequate public safety barriers, and inadequate veterinary care. 2015 cited for concealing areas that contained regulated species from the inspector, failure to have staff present while visitors were having contact with giraffes and kangaroos, filthy cages, enclosures in disrepair, unsanitary feeding practices, filthy water receptacles, and housing animals near a foul-smelling garbage dump.
22	Wright Park Zoo	Dodge City, KS	40 USDA citations including failure to provide veterinary care, cages in disrepair, repeatedly failing to have an adequate enrichment plan for primates, poor sanitation, failure to provide any bedding during bitterly cold temperatures to wolf dogs. 2015 USDA issued official warning. Accredited by ZAA based on an inspection that only took 2.5 hours with one of two inspectors being the zoo’s own veterinarian, i.e. clearly not “independent.”
23	Zoo at Forest Park	Springfield, MA	2015 the public learned of two likely preventable primate deaths.  A marmoset died from injuries sustained in a fight with other monkeys, and a tamarin died from exposure to cold temperatures after the zoo failed to have a back-up generator when an electrical malfunction shut off power to a heating system. In June 2016, a monkey named Dizzy escaped the zoo after a distracted employee failed to lock the enclosure. He roamed the zoo grounds for 3 days before being safely recaptured.
24	Zoo World Zoological and Botanical Conservatory	Panama City Beach, FL	2015 8 year old boy scratched and bitten by lemur. Cited for insufficient safety barriers around primates and big cats. 2015 cited for failure to provide relief from excessive heat to primates showing signs of heat exhaustion on a day when the heat index was 115 degrees in the shade. 2014 cited for failure to fed a veterinarian-approved diet to adult big cats and cubs, failure to provide environmental enrichment to a solitary lemur, failure to provide a sufficient public safety barrier around a kangaroo enclosure, and housing two newly acquired tiger cubs at locations that had not been inspected and approved. 2013 cited for staff ignoring instructions from the veterinarian including feeding sugary foods to a diabetic monkey, failing for months to provide supplements to squirrel monkeys suffering from calcium deficiency, feeding a lion the morning after anesthesia interfering with veterinarian’s ability to evaluate the lion’s condition, and inadequate drainage in a lion’s cage that resulted in an anesthetized lion being dropped by staff while wading through knee deep mud causing an extremely painful injury that led to the lion’s euthanasia. 2016 USDA issued official warning for repeated failure to adequately clean and sanitize primate cages, repeated failure to maintain cages, and inadequate public safety barriers.
25	Zoosiana - Zoo of Acadiana	Broussard, LA	2009 USFWS denied a Captive-Bred Wildlife registration application citing inadequate space and lack of cage furnishings.

For more detail on the differences between AZA and ZAA click here to download the very complete HSUS Fact Sheet.