Comment from Carole Baskin, Big Cat Rescue

Document ID: APHIS-2006-0159-0007
Document Type: Public Submission
Agency: Animal And Plant Health Inspection Service
Received Date: October 27 2008, at 09:58 PM Eastern Daylight Time
Date Posted: October 28 2008, at 12:00 AM Eastern Standard Time
Comment Start Date: October 23 2008, at 12:00 AM Eastern Standard Time
Comment Due Date: February 20 2009, at 11:59 PM Eastern Standard Time
Tracking Number: 8077fe63
View Document:  View as format xml

This is comment on Proposed Rule

Handling of Animals; Contingency Plans

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The State of Florida has a disaster plan requirement that is a good starting point. You can download it here and it is incorporated by reference in my comments: www.floridaconservation.org/permits/Docs/CWIDisasterPlan.pdf This is only the bare minimum however and like any plan is only as good as its implementation. No amount of paper work or planning can prevent a disaster where exotic animals are concerned. Keeping exotic animals in cages does nothing to protect them in the wild. The biggest problem with this proposed round of comments is that this is just more wasted time and energy when the solution is much simpler and has far more public support. The solution is to end the private possession and trade of exotic animals. In an online poll where 8,260 people responded we asked: Would you support a ban on exotic animals as pets? Answers Votes Percent Yes 6,338 77% No 1,922 23% Web site resources on dealing with emergencies involving exotic cats: http://www.bigcatrescue.org/emergency.htm http://www.bigcatrescue.org/zzBCRmanual/ANIMALEMERGENCY.htm http://www.bigcatrescue.org/000news/0articlesbybcr/hurricanes2005.htm Contingency plans should be submitted along with USDA renewals and if found lacking, the USDA license should not be renewed. These plans should be provided in a format that can be posted online for public scrutiny as the public is often the only line of defense the animals have from the inadequacies of their owners. There are not enough inspectors currently to provide even the most minimal assurance of care. Adding to their job the necessity of being the only ones responsible for monitoring the disaster plans means that plans will not be thoroughly scrutinized, much less enforced. This rule was proposed in the wake of the 2005 Hurricane season and while some exotic animals were displaced or killed, there was only one exotic cat fatality to my knowledge and that Lynx was in Belize. The disaster that causes hundreds of exotic cats (mostly tigers) to be killed and displaced each year is the lack of financial planning for the life of the animal. 1. Zoos breed indiscriminately and discard the animals because they have no facilities to keep the adults when they are breeding to satisfy the public’s desire to see babies. 2. Circus acts discard their big cats when they mature and will not perform. 3. Hundreds of big cats are bred for photo booths and petting sessions and discarded when they are over a few months old because they become a financial liability. 4. Pseudo sanctuaries and hoarders collect big cats to gain public sympathy and support, but the support rarely is sufficient for the next year’s care, so more animals are “rescued” in a reverse pyramid scheme that ultimately collapses. www.911AnimalAbuse.com lists 60 shameful facilities and 37 have been shut down or fined by USDA in just the past couple of years. When these facilities collapse there is nowhere for their wild cats to go due to a lack of financial preparation or responsibility. 5. Pet owners buy exotic cats from USDA facilities and yet are almost never willing to provide lifetime care to the animals they buy. Exotic cats make bad pets and there is no legitimate second market for an unwanted exotic. Ways to effective address these issues would be to ban the breeding and trade of exotic animals, especially exotic cats. A more complex approach would be to institute a permit requirement for breeding each species, whereby the funds necessary to cover lifetime care for that animal were deposited into an interest bearing account held by USDA/APHIS. The interest on the collective funds would be income to USDA to enable enforcement of the AWA. The principle would be returned at the end of the life expectancy, if the animal died prior to normal life expectancy to thwart those who would kill the animals at a young age to replace them with babies. If animals capable of breeding are housed together, some prorated amount should be required on deposit each year to offset the unreported births that will result. http://www.bigcatrescue.org/big_cat_news.htm documents 560 incidents in the U.S. involving captive exotic cats since 1990. The U.S. incidents have resulted in the deaths of 20 humans, 15 adults and 5 children, the additional mauling of 183 more adults and children, 159 escapes, the killing of 88 big cats, and 119 known confiscations. Since most of these disasters involving humans are the direct result of poor judgment of the owners of exotic cats, these prohibitions should be enacted: 1. No exotic cat should be taken from his or her primary enclosure, or off site except for the purpose of a scheduled veterinary visit or in the transfer to another licensed facility. 2. No contact should be allowed between the public and any exotic cat. The public should be defined as anyone who is not the owner, a full time paid employee, a documented full time volunteer who can prove no less than 8 hours per week of services to the facility for no less than 2 years prior to contact or the attending veterinarian. 3. A distance of no less than three feet should be maintained between the caged exotic cat and the public and no devise for reaching, touching or feeding the cat should come within three feet of the cat so that the cat cannot hook such item and pull the person unexpectedly close. 4. Primary cages should be built in such a manner that the exotic cats can be closed into a separate section to create the required safe space for keepers to clean the empty sections without coming too close to the cats. 5. Transport cages or temporary cages should be designed in such a way that food and water may be offered and the cage cleaned without endangering the keeper. 6. Pound for pound exotic cats are 12 times stronger than a man. For that reason alone, there is never a time that an exotic cat on a leash is truly restrained. Leashes are for pets, not wild animals. I saw semi tractor-trailers in treetops after hurricanes passed through Florida. I have seen entire expanses of interstate torn up and blown away. There is no way to safely transport a big cat from one location to another. Tornados hit without warning and big cats have escaped from car crashes. The prudent thing to do is to keep exotic cats off the road unless it is absolutely necessary for their well-being. The facility grounds should be required to be in areas that are not prone to flooding, fires, and earthquakes. In an emergency it should always be preferable to provide on site care than to expose the cats to the dangers of being off site. Circus acts that use big cats have already been banned in other countries and it is time they are banned here as well. 10,890 people responded to our online poll when we asked: Should big cats be made to perform in circus acts? Answers Votes Percent Yes 1,142 10% No 9,748 90% Results were similar when polls asked if big cats should be exhibited at fairs. The public doesn’t want to see it. USDA shouldn’t be allowing it. If roads can be blown away in a hurricane or tornado, or disappear entirely in the aftermath of an earthquake, there is no structure that can be guaranteed to contain a big cat under such powerful forces. There is no legitimate reason to collect or breed exotic animals for life in cages. Being held captive in environments that are profoundly more restrictive than their natural range does not enhance the animal’s welfare. All humane issues aside, there just is no way to safely contain a dangerous exotic animal and no legitimate reason to be doing so in the first place. Please use this critical time to gather useful information on ways to phase out exotics held captive. It is about time the Animal Welfare Act actually gave the animals some relief from antiquated practices. For the cats, Carole Baskin, CEO of Big Cat Rescue an Educational Sanctuary home to more than 100 big cats 12802 Easy Street Tampa, FL 33625 813.493.4564 fax 885.4457 http://www.BigCatRescue.org MakeADifference@BigCatRescue.org

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