February 2, 2016

Dr. Robert Gibbens, DVM

Western Regional Director

USDA, APHIS, Animal Care

2150 Centre Ave. Bldg. B

Mail Stop #3W11

Fort Collins, CO 80526

Via e-mail: Robert.M.Gibbens@aphis.usda.gov

Dear Dr. Gibbens:

Please consider this to be a formal complaint on behalf of Friends of Woodland Park Zoo Elephants regarding

the January 30, 2016 death of Chai, a 37-year-old female Asian elephant held at the Oklahoma City Zoo

(license # 73-C-0002) in Oklahoma City, Oklahoma.

According to the zoo (http://www.okczoo.com/news/m.blog/56/oklahoma-city-zoo-saddened-to-announce-

death-of-adult-female-asian-elephant) staff “discovered her [Chai] in the elephant yard Saturday morning.”

Comments made by a zoo spokeswoman to The Seattle Times (http://www.seattletimes.com/seattle-news/chai-

the-elephant-moved-from-seattle-found-dead/) confirm that Chai was not monitored overnight by zookeepers. It

is unclear whether night watch staff, if any, conducted regular inspections or whether video cameras are

installed on any part of the elephant exhibit. There is, therefore, no indication of how long Chai was recumbent,

or whether earlier staff intervention could have prevented Chai’s death or remediated any suffering. There is as

yet no announced cause of death.

At age 37, Chai’s death was premature, considering the possible life span of Asian elephants is up to 70 years in

the wild. Chai's age was well under the median zoo death age (according to the zoo's statement) of 47. It is

unclear whether Chai was left outside by the keeper staff when they left for the night and also whether she had

free access to both the indoor and outdoor areas of the exhibit. The temperature in Oklahoma City dropped to

the low 30s during the night in question (http://w1.weather.gov/data/obhistory/KPWA.html); clearly it would be

a violation of safe-handling provisions, cited below, for an exhibitor to fail to provide animals adequate

protection from the cold. We contend that elephants, particularly newly-introduced elephants and elephants

where temperatures can drop to the point of being dangerous to them, must be monitored, or at least checked on,

during the 13-plus hours that keeper staff is absent.

Further, medical records indicate that Chai suffered from chronic foot disease, confirmed by two independent

veterinarians (see links below). It is inconceivable that the Oklahoma Zoo was unaware of Chai’s medical

condition, or that the condition was a potential cause of premature death, and one of the leading causes of death

in captive elephants. It is also our contention that Chai’s known medical issues should have been cause for

greater vigilance on the part of zoo management and staff, including some form of nighttime monitoring, and

that the zoo’s failure to provide nighttime monitoring to an elephant known to have chronic and potentially life-

threatening health issues violates provisions of the Animal Welfare Act (AWA), which provide:

Sec. 2.40 Attending veterinarian and adequate veterinary care (dealers and exhibitors).

(b) Each dealer shall establish and maintain programs of adequate veterinary care that include:

(1) The availability of appropriate facilities, personnel, equipment and services to comply with the

provisions of this subchapter;

(2) The use of appropriate methods to prevent, control, diagnose, and treat diseases and injuries, and

the availability of emergency, weekend, and holiday care.

Sec. 2.131 Handling of animals.

(a) All licensees who maintain wild or exotic animals must demonstrate adequate experience and

knowledge of the species they maintain.

(b)(1) Handling of all animals shall be done as expeditiously and carefully as possible in a manner that

does not cause trauma, overheating, excessive cooling, behavioral stress, physical harm, or unnecessary

discomfort.

Sec. 3.132 Employees.

A sufficient number of adequately trained employees shall be utilized to maintain the professionally

acceptable level of husbandry practices set forth in this subpart. Such practices shall be under a

supervisor who has a background in animal care.

Please note that on July 22, 2015 the USDA found the Oklahoma City Zoo to be noncompliant with numerous

provisions of the AWA affecting several species, including elephants. According to the inspection report,

inspectors found rodent droppings on the floor of the elephant food preparation area which “can create

unsanitary conditions that lead to potential spread of disease.”

(http://www.freewpzelephants.org/docs/USDA_Inspection_Report_OCZ_citations.pdf)

We urge the USDA to take immediate action to fully investigate the circumstances of Chai’s death, including all

medical records and necropsy reports. We suggest that this review should include an independent assessment of

the necropsy findings. We further suggest that your agency should review footage of any video, including

closed circuit television, that may have been taken prior to and during the time when Chai was in the yard

unattended. There should also be review of the exhibitor's policies that address whether the elephants are

confined to the indoor exhibit overnight, or confined to the outside, or have free rein between inside and out.

Finally, we ask that USDA evaluate the night watch logs, if any, and determine the exhibitor's policy for

overnight checks on the elephants. Should violations of the AWA be found, we further urge the USDA to take

appropriate enforcement action.

Thank you for your prompt attention to this matter.

Sincerely,

Nicole Meyer

Statement by Dr. Mel Richardson on Chai’s medical condition, see page 21:

http://www.freewpzelephants.org/largefiles/Optimal%20Future_KP_4-12_web.pdf

Declaration by Dr. Philip Ensley on Chai’s medical condition:

http://www.freewpzelephants.org/docs/Declaration_Ensley.pdf