BILL ANALYSIS                                                                                                                                                                                                    



                                                                  AB 3027
                                                                  Page  1

          Date of Hearing:  April 25, 2006
          Consultant:     Scott Hinkle


                         ASSEMBLY COMMITTEE ON PUBLIC SAFETY
                                  Mark Leno, Chair

                    AB 3027 (Levine) - As Amended:  April 20, 2006
           

          SUMMARY  :   Requires that, by January 1, 2009, each person who  
          possesses, keeps, or maintains elephants at a stationary  
          facility shall make an outdoor space with a minimum of five  
          acres available to those elephants, provided that no more than  
          three elephants inhabit any five acres and that an additional  
          one-half acre shall be made available for each additional  
          elephant.  Specifically,  this bill  :  

          1)Provides that on or after January 1, 2008, it shall be  
            unlawful for a person, within California, who houses,  
            possesses, is in contact with, or travels with any elephant to  
            use or be in possession of any of the following while present  
            around the elephant:

             a)   Ankus, bullhook, or similar device.

             b)   Any chain used to restrain an elephant except if  
               utilized for the shortest amount of time necessary to  
               provide actual medical treatment.

          2)Requires that, on or after January 1, 2009, each person who  
            possesses, keeps, or maintains elephants at a stationary  
            facility will provide the following:

             a)   An outdoor space with a minimum of five acres available  
               to those elephants provided that no more than three  
               elephants inhabit any five acres and that an additional  
               one-half acre shall be made available for each additional  
               elephant.

             b)   The substrate will not consist entirely of concrete,  
               steel, gravel, sand, or other material that is detrimental  
               to the health of the elephant.  Most of the space made  
               available to the elephant(s) must be of an appropriate,  
               soft, natural substrate as not to cause or aggravate feet  








                                                                  AB 3027
                                                                  Page  2

               problems and allow for normal wear of the feet.

          3)Requires that, on or after January 1, 2008, each person who  
            possesses, keeps, or maintains any elephant on traveling  
            display shall provide the following:

             a)   An indoor, climate-controlled space that is, at a  
               minimum, 1,800 square feet for a single elephant and an  
               additional 900 square feet for each additional elephant.

             b)   An outdoor space that is, at a minimum, 1,800 square  
               feet for a single elephant and an additional 900 square  
               feet for each additional elephant.

             c)   The substrate will not consist entirely of concrete,  
               steel, gravel, sand, or other material that is detrimental  
               to the health of the elephant.  Most of the space made  
               available to the elephant(s) must be of an appropriate,  
               soft, natural substrate as not to cause or aggravate feet  
               problems and allow for normal wear of the feet.

          4)Provides that any person, owner, or manager who violates any  
            provision of this section shall be guilty of a misdemeanor.

          5)Provides that each day a violation continues constitutes a  
            separate and distinct offense. 

           EXISTING LAW  :

          1)Provides that elephants must be kept outside on natural  
            substrates as much as possible.  Institutions should consider  
            designing exhibitions that allow elephants outdoor access 24  
            hours per day, weather, heath and safety permitting.  During  
            daylight hours, elephants kept outdoors can tolerate moderate  
            temperature extremes.  Provisions must be made to protect  
            animals from adverse weather, including intense sunlight,  
            chilling rain, sleet, etc.  Animals kept outdoors must be  
            monitored frequently at temperatures below 40 degrees.   
            Facilities may install outdoor heat sources to extend the  
            amount of time the animals are able to remain outside.   
            [American Zoological Association (AZA) Standards for Elephant  
            Management and Care Section 1.1.1.]

          2)Provides that indoor space must provide adequate room for  
            animals to move about and lie down without restriction.  A  








                                                                  AB 3027
                                                                  Page  3

            minimum of 400 square feet is required for a single animal,  
            approximately 800 square feet for two animals, and so on.   
            Because of their size and space requirements, bulls or cows  
            with calves much have minimum of at least 600 square feet.   
            (AZA Standards for Elephant Management and Care Section  
            1.4.1.)

          3)Provides that outdoor yard must have at least 1,800 square  
            feet for a single adult individual and an addition 900 square  
            feet must be added for each additional animal.  If this space  
            is the only location of exercise, then it is recommended that  
            the space per elephant should be even greater.  (AZA Standards  
            for Elephant Management and Care Section 1.4.2.)

          4)Provides that outdoor yard surfaces must consist primarily of  
            natural substrates (e.g., soil, sand, grass) that provide good  
            drainage and have cleanable, dry area for feeding.  (AZA  
            Standards for Elephant Management and Care Section 1.4.5.)

          5)Provides that while outdoors, elephants must have access to  
            sand or soil at all times for dust bathing.  (AZA Standards  
            for Elephant Management and Care Section 1.4.6.)

          6)Provided adult males (six years and above) may be housed  
            alone, but not in complete isolation (opportunities for  
            tactile, olfactory, visual, and/or auditory interaction with  
            other elephants must be provided).  (AZA Standards for  
            Elephant Management and Care Section 2.2.5.)

          7)Provides that zoos should make every effort to maintain  
            elephants in social groupings.  It is inappropriate to keep  
            highly social female elephants singly.  Institutions should  
            strive to hold no less than three female elephants wherever  
            possible.  All new exhibits and major renovations must have  
            the capacity to hold three of more female elephants.  (AZA  
            Standards for Elephant Management and Care Section 2.3.1.)

          8)Provides that electrical devices designed for use on  
            livestock, such a commercially manufactured electric prods and  
            shocking collars/belts, are prohibited as routine training  
            tools or for handling animal during exhibition.  (AZA  
            Standards for Elephant Management and Care Section 5.1.1.)

          9)Provides that the AZA considers the following training  
            tools/techniques to be inappropriate for use at member  








                                                                  AB 3027
                                                                  Page  4

            institutions (AZA Standards for Elephant Management and Care  
            Section 5.1.2):

             a)   Insertion of any implement into any bodily orifice  
               unless directed by a veterinarian specifically in  
               connection with training for a medical or reproductive  
               procedure.  (AZA Standards for Elephant Management and Care  
               Section 5.1.2.)

             b)   Striking an elephant with anything more substantial than  
               an ankus (a traditional training tool used by elephant  
               trainers).  (AZA Standards for Elephant Management and Care  
               Section 5.1.2.)

             c)   Striking an elephant with any sharp object, including  
               the hook of an ankus.  (AZA Standards for Elephant  
               Management and Care Section 5.1.2.)

             d)   Striking an elephant on or around any sensitive area,  
               such as the eyes, mouth, ears of genital region.  (AZA  
               Standards for Elephant Management and Care Section 5.1.2.)

             e)   No tools used in training should be applied repeatedly  
               and with such force that they cause any physical harm to an  
               animal (i.e., breaking of the skin, bleeding, bruising,  
               etc.).  (AZA Standards for Elephant Management and Care  
               Section 5.1.2.)

             f)   Withholding or reducing an animal's daily-recommended  
               amount of food and or water.  (AZA Standards for Elephant  
               Management and Care Section 5.1.2.)

             g)   Withholding veterinary care for any reason.  (AZA  
               Standards for Elephant Management and Care Section 5.1.2.)

          10)Provides that protracted and repeated use of corporal  
            discipline in training is of serious ethical concern and AZA  
            considers abusive training practices to be unacceptable.  (AZA  
            Standards for Elephant Management and Care Section 5.1.2.)

          11)Provides that chaining is acceptable as a method of temporary  
            restraint.  However, elephants must not be subjected to  
            prolonged chaining (for the majority of a two-hour period)  
            unless necessary for veterinary treatment or transport.   
            Institutions that regularly use chains for some portion of the  








                                                                  AB 3027
                                                                  Page  5

            day must alternate the chained foot on a daily basis.  (AZA  
            Standards for Elephant Management and Care Section 5.5.1.)

          12)Provides that it is a misdemeanor for any owner or manager of  
            an elephant to engage in abusive behavior towards the  
            elephant, which behavior shall include the discipline of the  
            elephant by any of the following methods:

             a)   Deprivation of food, water, or rest.

             b)   Use of electricity.

             c)   Physical punishment resulting in damage, scarring, or  
               breakage of skin.

             d)   Insertion of any instrument into any bodily orifice.

             e)   Use of martingales.

             f)   Use of block and tackle.

          13)Provides that any traveling circus or carnival that performs  
            in California shall do both of the following:

             a)   Notify each entity that provides animal control services  
               for a city, county, or city and county in which the  
               traveling circus or carnival intends to perform of its  
               intent to perform within that jurisdiction.  Notice shall  
               be given at least 14 days prior to the first performance in  
               that city, county, or city and county.

             b)   Provide each entity that provides animal control  
               services for a city, county, or city and county in which  
               the traveling circus or carnival intends to perform with a  
               schedule of its performances in California.

             c)   Any violation of this section shall be punishable by a  
               fine of not less than $500 and not more than $2,000 for a  
               first violation, and not less than $1,500 and not more  
               $5,000 for any subsequent violation.

           FISCAL EFFECT  :   Unknown

           COMMENTS  :   









                                                                  AB 3027
                                                                  Page  6

           1)Author's Statement  :  According to the author, "Already 250  
            pounds and three feet tall at birth, elephants can grow to  
            weigh more than seven tons and stand as high as 13 feet.  They  
            are the largest land mammal on earth, highly intelligent,  
            socially complex and emotionally advanced.  In the wild, they  
            are constantly on the move, often covering dozens of miles in  
            a day.  Yet, many elephants in captivity in California -  
            mostly in zoos or traveling circuses- spend their lives  
            confined to a space of less than one acre.

          "Any elephant in captivity must also be trained, and circuses  
            and zoos have a sad history of training elephants through a  
            combination of physical and mental abuse.  Ask yourself:  how  
            is it that a 10,000-pound behemoth follows the lead its  
            150-pound keeper?  For many years, the only answer was to  
            'break' an elephant by subjecting it to a variety of painful,  
            degrading physical and emotional tactics until the elephant  
            submits out of fear and exhaustion.  There are trainers who  
            defend such techniques as necessary evils.  But, in fact,  
            elephants (and many other animals) in captivity can be trained  
            to cooperate with keepers voluntarily through a method known  
            as 'protected contact'.  One-half of the zoos with elephants  
            in America have adopted this practice, but in California some  
            zoos and all circuses have not.  They use chains to place  
            elephants in painful stress positions or in a bullhook, a  
            weapon that gets defended as a guide. 

          "I have introduced this bill to force vital and long overdue  
            reforms which will change the way elephants are cared for,  
            housed, and trained in California.  It is not radical, but  
            reasonable, based on standards already met by the Oakland Zoo,  
            which provides ample space for its elephants and employs care  
            techniques that are free from the threat of physical and  
            mental abuse.

          "It is clear that many who care for these animals, especially in  
            zoos, have the best interests of the elephants at heart and  
            are working hard to provide them with the best care possible.   
            And, unintentional as it may be, it is also clear that  
            elephants are suffering.  We can turn our backs and look away  
            or we can work together to provide them with a better life.   
            We must find a way to give these elephants the level of care  
            they deserve.  If we truly value our humanity, it requires of  
            us nothing less."









                                                                  AB 3027
                                                                  Page  7

           2)Background  :  According to the background provided by the  
            author:

              a)   Use of Bullhooks  :  "The bullhook is a training device  
               used to break and control elephants.  It is also called an  
               'ankus', 'elephant goad', or 'elephant hook'.  The handle  
               is made of wood, metal, plastic, or fiberglass, and there  
               is a sharp steel hook at one end.  Its shape resembles a  
               boat hook or fireplace poker.  Some bullhooks have long,  
               'shepherd's crook' cane-style handles, allowing the trainer  
               a firmer grip so that greater force can be exerted while  
               pulling and yanking the hook deeper into an elephant's  
               flesh. 

             "Both ends are used to inflict damage.  The trainer uses the  
               hook to apply varying degrees of pressure to sensitive  
               spots on an elephant's body (see diagram), causing the  
               elephant to move away from the source of discomfort.  The  
               trainer can also hold the hooked end and swing the handle  
               like a baseball bat, inducing substantial pain when the  
               elephant is struck on the ankle and other areas where there  
               is little tissue between skin and bone.

             "Some examples of bullhook use as documented by humane  
               investigators and United States Department of Agriculture  
               (USDA) inspectors:  in San Jose, California, humane  
               inspectors found that seven Ringling Brothers. and Barnum  
               and Bailey Circus elephants had injuries behind or on the  
               back of their left ears.  Some of the elephants had scars  
               behind their left ears.  Almost all of the injuries  
               appeared to be fresh, with bright red blood present at the  
               wound sites.'  These bloody wounds were likely caused by  
               the bullhook.  In fact, Ringling opposes a proposed USDA  
               policy that states, 'An ankus may not be used in an abusive  
               manner that causes wounds or other injuries.'  Former  
               Ringling employee Glen Ewell said that beating elephants  
               with bullhooks was a normal routine and that 'Ringling even  
               employs a guy to use some special powder to stop up the  
               bleeding when an elephant is hooked too hard.  They call it  
               spot work.'  The powder is Wonder Dust, or something  
               similar, used to conceal the wound and stop the bleeding.

             "USDA inspectors noted and described bullhook wounds on Clyde  
               Beatty-Cole Brothers Circus elephants:  'Helen and Bessie  
               both have several white circular inactive ankus scars.   








                                                                  AB 3027
                                                                  Page  8

               Bessie has white circular inactive ankus scars under her  
               chin, on the neck, and dorsal areas.  Helen also has the  
               same type of scars behind her right eye and at the dorsal  
               right ear.  She also has two longitudinal scars on her  
               tail.  . . .  Two of the six elephants had obvious hook  
               mark wounds on their rear legs.  Some hook marks were also  
               observed under the jaw of one elephant.  . . .  [F]our of  
               the six elephants were observed with what appears to be  
               hook marks.  These wounds were small in size, round, some  
               were healing, while others were red in appearance.  These  
               wounds were present on rear legs, above tails, and on [the]  
               back of front legs.'  Within hours of being punctured by a  
               bullhook, a welt or boil may erupt.  The wound may grow  
               larger if it becomes infected.

             "The use of the bullhook is used to create human social  
               dominance over the elephant, and is used to inflict  
               negative reinforcement and corporal punishment in the  
               management of elephants.  This device is used to deliver  
               aversive stimuli, which cues behavior, and to deliver  
               physical punishment to the elephant.  Handlers and trainers  
               are always in physical possession of the bullhook when they  
               are around elephants and use the device as a constant  
               reminder of who is in control. 

             "While performing, an elephant responds to verbal commands  
               from a trainer carrying a bullhook and moderate pressure  
               from the bullhook because the elephant has been conditioned  
               through violent training sessions to know that refusal to  
               obey will result in severe punishment later.  Moments  
               before the performance, while out of view of the public,  
               trainers may give the elephants a few painful whacks to  
               remind them 'who is the boss' and ensure that the elephants  
               perform the specified tricks on command.

             "Because a dispirited elephant submits to a dominant trainer  
               toting a bullhook, circuses mislead the public with  
               spurious claims that a bullhook is only used to guide or  
               cue an elephant.  In fact, the circus industry now calls  
               the bullhook 'the guide' as a public relations ploy to make  
               the implement sound friendlier. 

             "The difficult tricks that elephants are forced to perform  
               place a great deal of stress on their muscles and joints.   
               The exaggerated maneuvers are physically strenuous and no  








                                                                  AB 3027
                                                                  Page  9

               elephant would perform them on command, over and over,  
               hundreds of times a year without the constant threat of  
               punishment.  The circus industry claims that the elephants  
               perform tricks that they would normally perform in the  
               wild.  However, in the wild, an adult elephant would lie  
               down in slow, gradual movements no more than once or twice  
               per day and would not lie down and rise very quickly  
               several times as in a single circus show.  In addition,  
               elephants would not play with balls, do headstands, crawl,  
               or twirl.  If it were possible for an elephant to simply be  
               'guided' to perform rapid successions of headstands,  
               hind-leg stands, lying down, crawling, and twirling, the  
               trainer would be carrying a soft, cotton wand, not a hard,  
               pointed object."

              b)   Chaining  :  "Chaining is one of the most common methods  
               of confining elephants in captivity.  Chaining severely  
               restricts an elephant's movements - even elementary ones  
               such as lying down, walking, or socializing with other  
               elephants.  The resultant inability to move results in  
               neurosis and stereotypic behavior in elephants.  This  
               behavior, which indicates psychological distress, is not  
               observed in elephants in the wild.  A study conducted by  
               Texas A&M University concluded that stereotypical  
               behaviors, such as swaying and head bobbing, increase when  
               elephants are chained.  This bill will prohibit chaining, a  
               practice that most zoos housing elephants in California  
               have ended, but that continues in traveling displays.

             "Because chains immobilize elephants, they are forced to  
               stand in their own excrement, which can cause rotting in  
               the pads of their feet and urine burns on their legs.  In  
               observations of captive elephants, foot problems seen  
               include rot, sole cracks, hoof overgrowth, cracked nails,  
               and infected cuticles.  In addition, overnight chaining,  
               especially on concrete, has been implicated in causing  
               arthritis and lameness.  Foot infections and arthritis are  
               the leading reasons for euthanizing captive elephants and  
               the immobilization of elephants through lack of space and  
               chaining are major contributors to foot-related maladies.   
               According to documents obtained from USDA, many elephants  
               in captivity suffer from lameness, foot abscesses, and  
               arthritis.  Numerous deaths of captive elephants are  
               attributable to these ailments, which are not suffered by  
               their wild counterparts.








                                                                  AB 3027
                                                                  Page  10


             "Major circuses, such as Ringling Brothers and Barnum and  
               Bailey Circus, state that elephants are chained only at  
               night and during travel.  This claim is freely made in news  
               articles published throughout the country - probably in an  
               attempt to assure a concerned public that the elephants are  
               not spending their entire lives constrained and unable to  
               freely move about.  But circuses have rigorous travel  
               schedules; circus trains may traverse the country for as  
               long as 24 hours at a time, for up to 11 months out of  
               every year.  On average, traveling circuses are in a new  
               city every week.  Further, elephants require only a few  
               hours of sleep each night and in the wild forage for as  
               many as 18 hours per day.  Being chained at night means the  
               elephants are spending long waking hours with chains  
               holding them in one position.  As if nighttime and travel  
               chaining were not bad enough, there is recent proof of  
               elephants in circuses chained during broad daylight - a  
               line of Ringling Brothers elephants were photographed being  
               chained within seconds of each other in 2005. 

             "In addition, many stationary facilities also use chains to  
               confine elephants.  Zoos that use free contact generally  
               use chains to confine the elephants.  Free contact is based  
               on human social dominance over the elephant and is reliant  
                                                                                   upon the use of negative reinforcement and corporal  
               punishment in the management of elephants.  The main tool  
               used in free contact is an ankus or bullhook, along with  
               chains."

              c)   Spatial Needs  :  "Elephants need adequate space in order  
               to stay healthy.  In captivity, elephants are denied the  
               appropriate space to freely move around.  The majority of  
               stationary facilities housing elephants in California fail  
               to provide the space necessary for the elephants to engage  
               in normal behavior seen in their wild counterparts.  On  
               average, zoos accredited by the American Zoos and Aquarium  
               Association provide multiple elephants a space consisting  
               of one to two acres - much of which is not freely available  
               or accessible to the elephants.  Elephants in traveling  
               displays are provided far less room.  Traveling elephants  
               are provided minimal space at the various venues where they  
               are performing - generally a small area in the arena  
               parking lot.  Generally, the elephants have a small dirt  
               area in front of a tent, into which they are chained at  








                                                                 AB 3027
                                                                  Page  11

               night.  This area is extremely small and does not provide  
               the elephants with the opportunity to exercise  
               appropriately.

             "Given the small space provided, elephants are often standing  
               in their own waste and urine for as many as 16 hours a day.  
                In addition, elephants in captivity stand on inappropriate  
               substrates consisting mainly of concrete, gravel, sand, or  
               other material that is detrimental to the health of the  
               elephant.  Lack of space and poor substrates lead to a  
               variety of physical and psychological problems, including  
               arthritis, recurring foot infections and abscesses,  
               obesity, digestive disorders, and stereotypic/neurotic  
               behaviors such as swaying, pacing, and head-bobbing.  These  
               conditions can lead to premature death in captive  
               elephants. 

             "More than one-half of 46 elephants who died at accredited  
               zoos nationwide since 2000 failed to reach their 40th  
               birthday, dying far short of their 70-year life expectancy.  
                Elephants in traveling displays also display serious foot  
               problems, as evidenced by available USDA records.   
               Elephants in captivity should be living longer than their  
               wild counterparts given that they are protected from  
               poaching and are provided food and veterinary care.   
               Instead, the leading causes of euthanasia in captive  
               elephants are foot disorders and arthritis. 

             "In the wild, elephants walk up to 30 miles daily and are in  
               constant motion for as many as 18 hours each day on  
               different substrates, allowing the pads of the elephants'  
               feet to remain healthy.  Elephants in the wild walk on soft  
               natural surfaces such as grass, mud, and clay.  They do not  
               experience any of the maladies that afflict captive wild  
               elephants.  The opponents of this bill will argue that  
               there is no scientific evidence that elephants require  
               ample space and suggest that elephants only walk for long  
               periods of time in the wild because they are in search of  
               food and water.  This assertion, however, is not supported  
               by the vast amount of empirical evidence showing the  
               spatial needs of elephants.  For example, Dr. Joyce Poole,  
               a scientist with the Amboseli Elephant Research Group in  
               Kenya, states that the 'evidence that elephants need space  
               is unmistakable.'  She further notes that, 'In captivity,  
               confined in small spaces, under the constant command of a  








                                                                  AB 3027
                                                                  Page  12

               trainer and kept in socially deprived conditions, elephants  
               become dysfunctional, unhealthy, depressed, and aggressive.  
                Inactivity leads not only to obesity, but also to foot  
               diseases, joint problems, and arthritis.  Female zoo  
               elephants are 31% to 72% heavier than their wild  
               counterparts.'  If appropriate space were provided to  
               captive elephants, scientists and elephant experts agree  
               that the majority of foot and joint problems in captive  
               elephants would disappear. "

           3)Issues of Concern for Zoos  :  According to material supplied by  
            the California Association of Zoos and Aquariums, "This bill  
            could actually end up reducing the quality of life for very  
            elephants it proposes to help.  This bill demonstrates a lack  
            of understanding of the management and care of elephants."

              a)   Space Requirements  .  "The space requirements have two  
               major problems:

               i)     "There is  no scientific basis  for the formula set  
                 forth in this bill.

               ii)    "When the formula contained in this bill is applied,  
                 elephants actually end up losing space (calculated in  
                 square feet) with each additional elephant past three.   
                 The calculations are attached are listed below.  If  
                 enacted, this bill could force the removal of up to 34  
                 elephants from AZA-accredited zoos and an affiliated  
                 member."





           ---------------------------------------------------------------- 
          | Number of  |  Required  |   Total    |Square Feet | Acres Per  |
          | Elephants  |  Acreage   |Square Feet |    Per     |  Elephant  |
          |            |            |            |  Elephant  |            |
          |------------+------------+------------+------------+------------|
          |     2      |     5      |  217,800   |  108,900   |    2.5     |
          |            |            |            |            |            |
          |------------+------------+------------+------------+------------|
          |     3      |     5      |  217,800   |   72,600   |1.6         |
          |            |            |            |            |            |
          |------------+------------+------------+------------+------------|








                                                                  AB 3027
                                                                  Page  13

          |     4      |    5.5     |  239,580   |   59,895   |    1.4     |
          |            |            |            |            |            |
          |------------+------------+------------+------------+------------|
          |     5      |     6      |  261,360   |   52,272   |    1.2     |
          |            |            |            |            |            |
          |------------+------------+------------+------------+------------|
          |     6      |    6.5     |  283,140   |   47,190   |    1.1     |
          |            |            |            |            |            |
          |------------+------------+------------+------------+------------|
          |     7      |     7      |  304,920   |   43,560   |     1      |
          |            |            |            |            |            |
          |------------+------------+------------+------------+------------|
          |     8      |    7.5     |  326,700   |   40,837   |    0.94    |
          |            |            |            |            |            |
          |------------+------------+------------+------------+------------|
          |     9      |     8      |  348,480   |   38,720   |    0.88    |
          |            |            |            |            |            |
          |------------+------------+------------+------------+------------|
          |     10     |    8.5     |  370,260   |   37,026   |0.85        |
           ---------------------------------------------------------------- 

              b)   Where Do They Go  ?  "This bill does not specify where the  
               elephants (potentially up to 34 animals) should go.  There  
               are currently  only two identifiable 'elephant sanctuaries'   
               that exist and that could possibly accept some of the  
               animals:  Performing Animal Welfare Society's ARK2000  
               facility (PAWS) in Galt, California, and the Elephant  
               Sanctuary in Hohenwald, Tennessee.  There are no other  
               identified locations that would qualify.  Though the  
               Oakland Zoo qualifies with its present number of elephants,  
               it would not meet the space requirements of this bill with  
               the addition of any more animals.

             "From the available information on the Web sites for the two  
               sanctuaries, it appears that they have only female  
               elephants.  PAWS (Galt, California):  three African and  
               five Asian, and Elephant Sanctuary (Hohenwald, Tennessee):   
               eight Asian and three African.

             "There is no evidence that either facility is prepared to  
               accept bull elephants, though they have the space.   
               Effective management of bull elephants would require  
               additional investment in the physical plants of both  
               properties."









                                                                  AB 3027
                                                                  Page  14

              c)   Economics  :  "This bill takes no costs into  
               consideration.  In addition, Section 2 eliminates any form  
               of reimbursement to the affected parties.

               i)     "There is no consideration given to the annual  
                 operating expense of caring for up to 34 additional  
                 elephants.  Per the PAWS Web site, the annual expense of  
                 caring for each elephant is $50,000.   This brings the  
                 potential total expense to $1.7 million annually  .  In  
                 2003-04, the Santa Barbara Zoo moved its two female Asian  
                 elephants to the AZA-accredited Fresno Zoo while  
                 construction took place on their renovated exhibit.   
                 During that time, the Santa Barbara Zoo paid the Fresno  
                 Zoo a fee of $13,500 per month, which equates to an  
                 annual cost of $81,000 per animal.

               ii)    "There is no consideration given to the cost of  
                 moving elephants to a sanctuary.  Per the PAWS Web site,  
                 the cost of moving the elephants from the San Francisco  
                 Zoo to the Galt site was estimated at $20,000 (a distance  
                 of approximately 104 miles) for two animals.   This could  
                 represent a total expense as much as $340,000  .  The Santa  
                 Barbara Zoo spent $30,000 to move its two elephants  
                 (round trip).

               iii)   "Can PAWS afford to take on any more elephants?   
                 According to the PAWS 990 form for 2004, their total  
                 expenses for the year ($1,705,882) exceeded their revenue  
                 ($1,270,160) by $435,722 or 25%.  Adding the potential  
                 expense of an additional 34 animals would double their  
                 annual operating expense.  Per the same 990, their 2004  
                 revenues (primarily donations) were fairly consistent  
                 with the prior three years.  Can PAWS take on the  
                 financial commitment that is currently part of the  
                 operating costs of the zoos that would be affected by  
                 this bill?

               iv)    "Per the 2004 990, PAWS has a number of outstanding  
                 loans to help them meet their operating expenses:

                  (1)       "$120,795 payable on demand to the two PAWS  
                    officers, Pat Derby and Ed Stewart.

                  (2)       "$10,000 payable on demand to Linda Faso.









                                                                  AB 3027
                                                                  Page  15

                  (3)       "$50,000 payable to In Defense of Animals  
                    (IDA) on an interest-only basis ($375 per month) at a  
                    rate of 9%.  This is of particular interest as IDA is  
                    leading a national 'campaign' to get elephants out of  
                    zoos.  It is a  loan  and  not a donation  toward the  
                    expense of caring for elephants.

               v)     "Even Pat Derby of PAWS does not believe that  
                 closing elephant exhibits is the answer to improving  
                 elephant welfare:

                  (1)       "Many animal welfare advocates want to see all  
                    zoo elephants moved to such a sanctuary, but Derby has  
                    a different view.  The longtime activist thinks animal  
                    groups ought to keep pressure on zoos to improve their  
                    elephant programs.  [  San Diego Union Tribune  , "Where  
                    do Elephants Belong?" (June 19, 2005).]

                  (2)       "Animal activists should realize that trying  
                    to close elephant exhibits is not the solution.   
                    Trying to get better standards.  Everybody should be  
                    striving for that.  [Pat Derby on CBS:  The Early Show  
                    (February 27, 2006).]"

           4)Circus Background  :  According to background supplied by  
            Ringling Brothers. and Barnum and Bailey:

              a)   Ankus or Guide  :  "The ankus has been used for thousands  
               of years by elephant handlers all over the world.  It is  
               still used by mahouts, the original elephant trainers in  
               Asia.  Over time, there have been variations in appearance,  
               but the guides used by Ringling Brothers today are  
               approximately 30 to 36 inches long with a small dull hook  
               at the end.  Elephant handlers in zoos, on preserves, and  
               in circuses use the ankus.  At Ringling Brothers, the ankus  
               serves as an extension of the trainer's arm and is used  
               during performance and in daily routines as a guide.  The  
               ankus is commonly use with a voice command.  For example, a  
               touch on the side of the right leg with the command 'foot'  
               tells the elephant to lift its right foot.

              b)   Terthering  :  "Our elephants and hoofstock are  
               comfortably tethered while riding the Ringling Brothers  
               train and occasionally in the stable area.  This helps them  
               understand that they stay in one place.  This ensures their  








                                                                  AB 3027
                                                                  Page  16

               safety and the safety of the humans who work with and  
               around them.  The use of tethers also maintains more  
               sanitary conditions during feeding time, but preventing  
               manure from getting close to the food supply as well as  
               facilitating the monitoring of their food intake.  Our  
               animal care staff ensures that the tether materials we use  
               are comfortable for our animals easy to keep clean.   
               Ringling Brothers tethering practices are consistent with  
               the standards endorsed by the International Elephant  
               Foundation, the American Zoo and Aquarium Association and  
               the Elephant Managers Association."

           5)Potential Unintended Consequences  :  This bill would increase  
            the space requirements for stationary facilities housing  
            elephants to five acres per three elephants and an additional  
            one-half acre per additional elephant.  Currently, only the  
            Oakland Zoo meets the proposed space requirements.  Due to the  
            fact that the Los Angeles City Council just approved a  
            proposal by the Los Angeles Zoo to build a three- and one-half  
            acre exhibit for their elephants, it is unlikely that the Los  
            Angeles Zoo would be able to accommodate the five-acre  
            requirement set forth in this bill.  

          This bill will most likely force California zoos to remove their  
            elephants from their exhibits.  While this may, in fact, be  
            the result the proponents of this bill are seeking, the result  
            may end up being more harmful to the elephants that leaving  
            them in the care of zoos in California.  The proponents of the  
            bill have suggested that if the elephants are unable to be  
            housed in zoos, they would then end up residing in elephant  
            sanctuaries.  While this result might be ideal for the  
            elephants, it is unlikely to happen.  Even if in the unlikely  
            situation that the elephant sanctuaries could afford to take  
            in the 34 elephants in California zoos, more than likely the  
            AZA would just transfer the elephants to a different zoo in  
            another state.  In the likely case that the elephants would be  
            transferred to zoos in other states, there is no guarantee  
            that the elephants would be end up with more space, more care,  
            or better weather conditions that they currently have in  
            California.  In fact, the elephants could quite easily end up  
            with less space, less care and worse weather conditions.     
           
           6)Arguments in Support  : 

              a)   Animal Protection Institute  :  According to the Animal  








                                                                  AB 3027
                                                                  Page  17

               Protection Institute, "Elephants need adequate space in  
               order to stay healthy.  In the wild, elephants walk up to  
               30 miles daily and are in constant motion for 18 hours each  
               day.  Lack of space leads to a variety of physical and  
               psychological problems including arthritis, recurring foot  
               infections and abscesses, obesity, digestive disorders, and  
               stereotypic/neurotic behaviors like swaying, pacing and  
               head-bobbing.  In fact, elephants in captivity die  
               prematurely.  More than one-half of 46 elephants who died  
               at accredited zoos since 2000 failed to reach their 40th  
               birthday, dying far short of their 70-year life expectancy.  
                Elephants in captivity should be living longer than their  
               counterparts in the while given that they are protected  
               from poaching and provided food and veterinary care.   
               Instead, the leading causes of euthanasia in captive  
               elephants are foot disorders and arthritis.

             "In addition, bullhooks and chains are commonly used to train  
               and control elephants at zoos and in traveling shows.   
               These practices are not only antiquated but cruel and  
               inhumane.  Both ends of the bullhook inflict damage and are  
               used to dominate the elephant and cause pain.  There is an  
               alternative method that can be used.  In fact, most of the  
               accredited zoos in California are now utilizing a training  
               method called 'protected contact' which relies solely on  
               positive reinforcement.  Training tools of this method are  
               treats, praises, whistles, and a soft-ended wand that  
               resembles a giant Q-tip.

             "The practice of chaining is one of the most common methods  
               of confining elephants in captivity and goes hand-in-hand  
               with the use of the bullhook.  Chaining severely restricts  
               an elephant's movements - even elementary ones such as  
               lying down, walking, or socializing with other elephants.   
               The resultant lack of movement due to chaining results in  
               neurosis and stereotypical behavior in elephants.  This  
               behavior, which indicates psychological distress, is not  
               observed in elephants in the wild.

             "Elephants are highly intelligent, social animals who live  
               extended family groups and mirror humans in terms of  
               emotion, age progression, longevity and social bonds.  This  
               bill will set minimum standards of care and excellence for  
               elephant handling for the rest of the nation to follow.   
               This bill addresses the most egregious training methods  








                                                                  AB 3027
                                                                  Page  18

               employed by elephant handlers, as well as animal welfare  
               concerns facing elephants and offers a solution.

              b)   Animal Legal Defense Fund  :  According to the Animal  
               Legal Defense Fund, "The ankus or bullhook is the most  
               inhumane, commonly used method to train and control  
               elephants in both zoos and traveling circuses.  It is used  
               to inflict pain and dominate the elephant.  However, there  
               is an alternative.  A more humane training method that uses  
               only positive reinforcement is called 'protected contact'  
               and several elephant handlers are currently using this  
               method.  Chaining is also inhumane.  Elephants in the wild  
               travel several miles a day, eating and socializing with  
               other elephants.  Chaining prevents elephants from  
               expressing natural elephant behavior and even basic needs  
               such as lying down, which leads to neurosis and  
               psychological distress.  Walking over large area also  
               affords elephants the proper amount of exercise needed for  
               good health, and keeps their toenails and foot pads worn  
               down.  The leading causes of euthanasia of captive  
               elephants are foot ailments and arthritis.  Even with  
               veterinary care, adequate food, and protection from  
               poaching, elephant in captivity die far sooner than  
               elephants in the wild, due to the various forms of neglect  
               and abuse mentioned above.  This fact is something you  
               would not expect from elephants afforded human  
               'protection'.

             "Public safety is also a concern.  Elephants who are under  
               stress from the cruel training method and close confinement  
               mentioned above are more likely to try to escape or  
               otherwise rebel, resulting in rampages that severely injure  
               or kill handlers and members of the public.  This bill, by  
               prohibiting such methods and confinement, helps to ensure  
               the safety of California's citizens."

              c)   The Human Society of the United States  :  According to  
               the Human Society, "Under traditional conditions in zoos  
               and circuses, elephants live their entire lives in close  
               confinement, and often in shackles.  This is a far cry from  
               the lives led by the elephants in the wild who may walk 30  
               to 50 miles a day as they travel to sources of food and  
               water.  Deprived of stable social structures, stressed  
               inappropriate environmental conditions, and traumatized by  
               physical disciple in training captive elephants often  








                                                                  AB 3027
                                                                  Page  19

               experience shortened life spans.

             "The standards for the humane handling, care, treatment and  
               space requirements of exhibition animals under the federal  
               Animal Welfare Act administered by the USDA are minimal in  
               nature and poorly enforced due to limited personnel and  
               funding.  Facilities which are not in full compliance with  
               the AWA are frequently given only a warning, and persistent  
               violators are rarely prosecuted by USDA.  Standards are  
               neither species-specific, nor designed to provide a  
               consistent level of care.

             "Given the immense size of power of elephants, many training  
               methods are designed to establish dominance over them and  
               include striking them in sensitive areas with sharpened  
               hooks, beating them with clubs and other objects and  
               depriving them of food.  Many elephant handlers are now  
               using an alternative training method called protected  
               contact which relies on positive reinforcement.  Training  
                                        tools for this method are treats, praise, whistles, and  
               soft-ended wand that resembles a giant Q-tip."

           7)Arguments in Opposition  :

              a)   California Association of Zoos and Aquariums  (CAZA):   
               According to the CAZA, "We respectfully encourage your 'NO'  
               vote on this bill when this bill is heard by your committee  
               on April 25.  Seven American Zoo and Aquarium  
               Association-accredited and one AZA-related institution  
               provide habitats for 38 elephants in California.  Passage  
               of this bill will force the closure of the elephant  
               exhibits at the Fresno, Los Angeles, Santa Barbara, Vallejo  
               (Six Flags), and San Diego Zoos and the San Diego Wild  
               Animal Park, which will result in the relocation of 34  
               elephants and deny almost 8 million zoo visitors the  
               opportunity to personally experience the majesty of  
               elephants. 

                i)     What This Bill Does  :  "This bill would mandate that  
                 no more than three elephants inhabit any five acres  
                 outdoors at an undefined 'stationary facility' and that  
                 each additional elephant be provided with an additional  
                 half acre.  Stated another way, this bill would require  
                 each of three elephants be provided 72,600 square feet of  
                 outdoor space and 21,780 square feet of space outdoors  








                                                                  AB 3027
                                                                  Page  20

                 would be required for each additional elephant after  
                 three.

                ii)    Problems with this Bill  :

                   (1)       Arbitrary Acreage Requirements  :  "This bill's  
                    mandate that no more than three elephants inhabit any  
                    five acres outdoors at a 'stationary facility' and  
                    that an additional one-half acre be made available for  
                    each additional elephant are arbitrary in that no  
                    peer-reviewed zoological science exists to support  
                    them.  The habitat areas provided to the  
                    above-referenced 38 elephants exceed the peer-reviewed  
                    standards of care set by the AZA.  

                  "The AZA's 'Standards for Elephant Management and Care'  
                    are more stringent than those of state regulatory  
                    agencies and the USDA's Animal and Plant Health  
                    Inspection Service.  Members of AZA's Elephant  
                    Steering Committee have more than 330 years of  
                    experience with elephants.  

                  "As Zoological Society of San Diego Executive Director  
                    Douglas G. Myers said in his March 27th letter to the  
                    author, 'Accredited zoos are internationally  
                    recognized as experts in animal care and species  
                    propagation.  Should not this expertise be utilized to  
                    advise . . . policymakers as to the appropriate  
                    habitat?'

                   (2)       Expansion of Elephants Habitat Halted  :   
                    "Passage of this bill would stop the privately-funded  
                    efforts of the Zoological Society of San Diego to  
                    expand the elephants' habitat at the San Diego Zoo.   
                    Similarly, expansion of the elephants' habitat at the  
                    Los Angeles Zoo from one-half acre to three- and  
                    one-half acres could likewise be constrained.

                   (3)       Uprooting of 34 Elephants in California :  
                    "Passage of this bill would uproot 34 elephants from  
                    their homes.  This bill offers no plan for the  
                    relocation of these affected elephants.  Moreover, and  
                    more importantly, CAZA is unaware of any documented  
                    evidence that proves the two entities in our country -  
                    one entity in California (Performing Animal Welfare  








                                                                  AB 3027
                                                                  Page  21

                    Society) and one in Tennessee - have all the necessary  
                    resources (acreage, habitat, staff, financial support)  
                    to accept and properly care for the unique needs of  
                    each of these 34 Asian and African elephants.  Indeed,  
                    it is unclear whether these two facilities provide  
                    state-of-the-art veterinary, nutrition, and enrichment  
                    programs for their existing elephants.

                  (4)       "More importantly, closure of elephant  
                    habitats in accredited zoos would directly and  
                    immediately result in:

                    (a)         "An impairment in the gains made in the  
                      zoological knowledge of elephant physiology and  
                      communications that study and observation in a zoo  
                      setting provides.  This, in turn, will hinder  
                      advancements in the science used to both conserve  
                      the declining numbers of African and Asian elephants  
                      and establish self-sustaining populations of  
                      elephants.

                    (b)         "California families in major metropolitan  
                      areas no longer being able to share the experience  
                      of having their children learn about, understand,  
                      appreciate, and grow to love elephants.  

                    (c)         "The majority of Californians losing the  
                      opportunity to view up close these magnificent  
                      creatures and, therefore, any possibility that these  
                      people would be inspired to act for conservation of  
                      this endangered species and their habitats.

                iii)   Conclusion  :  "The CAZA is comprised of dedicated  
                 animal-care experts who are committed to ensuring that  
                 elephants are part of the world's future.  Passage of  
                 this bill will eliminate excellent elephant programs that  
                 currently provide exceptional care and contribute to  
                 research and conservation efforts on behalf of all  
                 elephants in Asia and Africa."

              b)   Association of Zoos and Aquariums  :  According to the  
               Conservation Education Committee (CEC) of the AZA, "One  
               focus of the Board-appointed CEC is to enhance and measure  
               the impact that a zoo or aquarium visit has on the over 143  
               million annual visitors - a number great than half the  








                                                                  AB 3027
                                                                  Page  22

               total population of the United States.  The 22 AZA  
               facilities in California along draw nearly 16 million  
               visitors annually.  For many of these guests, the  
               opportunity to view and learn about the diversity of animal  
               life on our planet would not be possible without a visit to  
               our facilities.  Guest and program evaluation firms, all  
               confirm the same basic principle:  the more a person leans  
               about or becomes emotionally connected to an animal, the  
               more likely that individual will take positive action to  
               help save wildlife.  Indeed, motivation to action is  
               dependant on these connections and cannot happen without  
               them.  It is this interest in and fascination with wildlife  
               that draws people to our accredited zoos and aquariums each  
               and every day and helps increase funding for conservation  
               programs in the wild.

             "AZA professionals have a tremendous amount of knowledge  
               regarding the needs of the elephants entrust to their care  
               and they have set many guidelines that must be follow for a  
               facility to receive or maintain accreditation.  These  
               guidelines are set in place to ensure the well-being of  
               elephants in all AZA-accredited institutions.  The CEC  
               fully supports these standards and practices created by our  
               colleagues in the animal science and research arm of AZA.   
               None of us want to see any animal maintained in sub-par  
               conditions, nor do we wish to see an animal in any  
               situation that will negatively affect its psychological  
               well being.

             "While the CEC certainly supports any and all legislation  
               ensuring that an elephant holding facility meets certain  
               animal welfare standards and practices, we oppose this  
               bill.  The setting of an arbitrary minimum size for an  
               elephant exhibit (five acres in this case) is just that -  
               arbitrary.  This size is not based on any research or  
               fact-based knowledge.  The welfare of a group of elephants  
               is related is related to many variables such as behavioral  
               enrichment opportunities, veterinary care and day-to-day  
               husbandry, not a specific amount of acreage.  The idea of  
               the 'wild' elephant herd is a fast-dying possibility as  
               most elephants in Africa/Asia are either protected in  
               human-managed game reserves where their movement is  
               restricted or use as beast of burden by locals.

             "The effect of the minimum size will have far reaching,  








                                                                  AB 3027
                                                                  Page  23

               negative impacts.  If the exhibit size requirement portion  
               of this bill goes into effect, only one AZA facility in the  
               entire state will satisfy the requirements, leaving the  
               other facilities - many with two to three acre exhibits -  
               with no choice but to send their animals to other  
               facilities.  Unfortunately, there is limited space in  
               AZA-accredited facilities so these animals with need to be  
               sent to so-called 'sanctuaries'.  These sanctuaries - while  
               they might have a larger space - do not even meet the  
               minimal AZA standards for elephant care.

             "Most importantly, most of your 33 million plus residents  
               will never get the opportunity to one again experience the  
               awe, amazement and emotional connection that comes from  
               viewing a living breathing animal as magnificent as an  
               elephant.  If effect, their motivation for supporting  
               conservation action programs aimed at saving elephants will  
               be taken away."

              c)   GAJAH:  Journal of the Asian Elephant Specialist Group  :   
               According the Charles Santiapillai, Ph.D., editor of GAJAH,  
               'I am an Associate Professor of Zoology at the University  
               of Peradeniya in Sri Lanka.  My main research interest at  
               present is the conservation and management of the Asian  
               elephant.  Since the 1980's, I have been a member of the  
               Asian Elephant Specialist Group (AsESG), and the editor of  
               its journal GAJAH.  One of my publications includes "The  
               Asian Elephant: An Action Plan for its Conservation",  
               published by the World Conservation Union in 1990.  I am  
               also a member of the Task Force convened by the Government  
               of Sri Lanka to prepare a National Policy for Elephant  
               Conservation in Sri Lanka.  I am 61 years old. 

             "I understand this bill being proposed in the State of  
               California stipulates the provision of a minimum of five  
               acres for three elephants in captivity, with one-half acre  
               being set aside for every additional elephant.  Such  
               legislation will make it almost impossible for many zoos in  
               the United States to maintain elephants in captivity, given  
               the space limitations. 

             "But is this reasonable, vis-?-vis what is being done  
               extremely well here in Sri Lanka, where elephant management  
               in captivity can be traced back to more than 2,000 years.  
               Since 1980, elephants rescued from the wild are being  








                                                                  AB 3027
                                                                 Page  24

               maintained at the Elephant Orphanage in Pinnawala - a  
               facility run by the Government of Sri Lanka.  Here in a 9  
               ha (22.2 acres) coconut estate, some 66 elephants of all  
               sizes are being maintained, almost all of them in excellent  
               health and well cared for by experienced and dedicated  
               mahouts (elephant keepers) and veterinarians.  This  
               translates into a density of 7.3 elephants per ha (or three  
               elephants per acre).  The National Zoological Gardens in  
               Dehiwela (Sri Lanka) too maintains elephants in captivity  
               in much smaller enclosures, given the limitations of space.  
                But the animals are well looked after and are in very good  
               health. 

             "This bill is too restrictive and unrealistic.  Where does  
               one draw the line between sanity and stupidity?  Items such  
               as ropes, chains, ankus, etc., are needed in the management  
               of elephants in captivity by mahouts (elephant keepers),  
               who unlike biologists studying elephants in the wild from  
               the comfort and safety of their air-conditioned, four-wheel  
               drive vehicles, need to interact at close range with  
               elephants.  Instead of banning items such as ropes, chains  
               or hooks, we need to promote their prudent and judicious  
               use.  People who look after elephants and other animals in  
               the zoos and other captive facilities are far more humane  
               than some of the animal rights activists, who can be  
               deluded, deranged and even dangerous at times. 

             "There is a growing concern among the educated public of the  
               need to care for animals, in particular elephants in  
               captive facilities.  One of the concerns is the limitation  
               to animal movement imposed by space in zoos.  This is  
               understandable, given that most zoos are in urban areas  
               where space is limited.  Nevertheless, there are facilities  
               and institutions in the United States where elephants are  
               indeed very well looked after and cared for.  There is,  
               therefore, a need to identify such institutions and  
               facilities and recognize their contributions to the  
               conservation of elephants and provide a balanced assessment  
               of their activities to the general public.  These agencies  
               recognize the importance of a well informed public.  A  
               knowledgeable and concerned public will then remain a  
               source of support and constructive enquiry to the  
               conservation of elephants both in the wild and in  
               captivity.









                                                                  AB 3027
                                                                  Page  25

             "Some conservationists have pointed out that elephants in  
               captivity tend to be aggressive, neurotic and prone to a  
               variety of diseases and suffer from infertility.  But they  
               fail to realize that life in the wild is not a bed of roses  
               for elephants either.  In Sri Lanka, one can see wild  
               elephants with gunshot injuries and suppurating wounds.   
               Elephants are routinely shot, maimed, poisoned or killed by  
               irate farmers as they interfere with agriculture.   
               Currently, over 100 elephants are slaughtered in the wild  
               annually as a consequence of the escalating human-elephant  
               conflict.  Wild elephants also kill between 30 to 50 people  
               every year in the island.  Poor health is not peculiar to  
               animals in captivity; even in the wild, one can see  
               elephants in poor body condition as a result of prolonged  
               drought or through competition for grazing with domestic  
               cattle.  As far as infertility in captivity is concerned,  
               evidence from Sri Lanka points to the opposite: elephants  
               are breeding well in captivity, without the need for  
               artificial insemination. 

             "Last year, I was able to spend a short sabbatical in the  
               United States during which I visited a few facilities (such  
               as zoo, sanctuary, safari park and circus) in which  
               elephants are managed in captivity.  I was greatly  
               impressed with the level of care given to the elephants in  
               places such as Center for Elephant Conservation at Polk  
               City (Florida), Annheuser-Busch Adventure Park in Tampa  
               (Florida), Disney's Animal Kingdom at Lake Buena Vista  
               (Florida), the Memphis Zoo (Tennessee), the Tulsa Zoo  
               (Oklahoma), the Little Rock Zoo (Arkansas), the Ringling  
               Brothers and Barnum & Bailey Circus at Corpus Christi  
               (Texas), and the Riddle's Elephant and Wildlife Sanctuary  
               at Greenbrier (Arkansas).  In all these facilities, the  
               elephants are managed extremely well and looked after with  
               great care by experienced and dedicated keepers.  The level  
               of veterinary care given to the animals is excellent and  
               veterinarians are on call 24 hours per day.

             "None of the elephants that I saw was overworked,  
               undernourished, abused or obese. None of them showed any  
               foot disease or exhibited neurotic behavior.  The Center  
               for Elephant Conservation in Florida has over 100 acres of  
               land for its elephants to range freely, while the Riddle's  
               Elephant & Wildlife Sanctuary has over 300 acres of land.  
               There are excellent facilities to monitor the elephants'  








                                                                  AB 3027
                                                                  Page  26

               body weight and physical condition.  The 'protected  
               contact' approach practiced in these facilities ensures the  
               safety of the elephant keepers, and helps minimize risks.   
               The bond between the elephant and its keeper is so good  
               that there is no need to use excessive disciplinary action.  
                The animals are well trained to obey basic commands. 

             "It is therefore a pity that an increasingly vocal and  
               influential group of animal rights activists is unable to  
               separate the lasting wheat from the fading chaff.  While  
               everyone working for the conservation of elephants must  
               fight for animal welfare, no one should allow people's  
               emotions to be exploited by animal rights activists.  As Dr  
               Graham Child (Zimbabwe) argues, they play on people's  
               sensitivity against cruelty to animals, and in the process  
               have 'gained prominence as a form of remote political  
               coercion'.  They have power without responsibility - a  
               privilege only politicians and prostitutes enjoy.  The  
               matter is serious, and an editorial in a recent issue of  
               Nature highlights the need for scientists to speak up  
               against the unreasonable stand of the animal rights  
               activists.  'The reluctance to talk to the public about  
               their research merely plays into the hands of the  
               extremists who would be delighted to see scientists stay  
               silent.' 

             "United States legislators should study how well elephants  
               are managed in Asia, both in the wild and in captivity.   
               There will always be elephants in captivity in Asia given  
               their religious and social significance.  No amount of  
               protest or agitation from the animal rights activists will  
               ever stop pageants such as the Peraheras in Sri Lanka at  
               which numerous elephants take part.  Elephant management  
               and conservation should be based on science and not on  
               sentiment.  The animal rights movement, like the Taliban,  
               is a form of extremism and it is time that scientists spoke  
               up in defence of captive elephant facilities.  Remaining  
               silent would only spur the animal rights activists to  
               venture into even more hare-brained schemes, such as  
               banning the keeping of dogs in captivity. Animal welfare  
               should take precedence over animal rights."

              d)   Feld Entertainment, Inc  :  According to Feld  
               Entertainment, "Feld Entertainment, Inc. is the world's  
               leading producer of live family entertainment and the  








                                                                  AB 3027
                                                                  Page  27

               parent company of Ringling Brothers and Barnum and &  
               Bailey.  Ringling Brothers is one of the oldest, largest,  
               and is the most well-known traveling exhibitor of live  
               animals in the world.  Ringling Brothers have 54 Asian  
               elephants, the largest herd in North America as well as the  
               most successful breeding program outside of Asia.  We are  
               committed to providing all of our elephants with the  
               highest and best standards of care in all respects and can  
               honestly say that not entity knows more about the proper  
               handling, training and veterinary care of elephants than  
               Ringling Brothers.

             "Ringling Brothers has reviewed this bill and, regretfully,  
               we must oppose the bill.  This bill is ill-advised and  
               would interfere with proper elephant husbandry and  
               management by imposing baseless restrictions and  
               requirements that do nothing to enhance the individual  
               elephant welfare, and would actually be detrimental to  
               elephant conservation.  In fact, if enacted, this bill may  
               ultimately doom the already endangered Asian elephant  
               species to extinction.

             "This year, Ringling Brothers is caring for and transporting  
               three circus productions containing over 150 individual  
               animals through approximately 120 cities, including eight  
               in California.  A trip to Ringling Brothers' circus has  
               long been a treasured pat of the American childhood,  
               evoking happy memories of family and fun.  Our shows not  
               only entertain, but also teach the value of teamwork and  
               the important role we all have as caretakers of the animals  
               who share our planet.  The sights, sounds and smells of  
               that first trip to the circus stay with us always.  Yet,  
               because it would prohibit the use of recognized and  
               legitimate tools of animal husbandry, this bill would, in  
               effect, prevent us from bring our circuses to California.

             "While the circus family works with a variety of rare or  
               exotic animals, there is no question that the animal most  
               closely identified with the circus is the elephant.  As we  
               enter out 136th year of providing quality family  
               entertainment, Ringling Brothers and Barnum & Bailey is  
               recognized as a leader in the care and well being of Asian  
               elephants.  With so many years of experience, Ringling  
               Brothers has gained extensive practical and scientific  
               knowledge of elephant behavior and social structure, and we  








                                                                  AB 3027
                                                                  Page  28

               regularly work with some of the world's leading experts in  
               elephant care.  Although there is a great deal of emotional  
               rhetoric surrounding the issue of elephants in zoos and  
               circuses, we hope that when you examine the facts about  
               Ringling Brothers and our commitment to elephants you will  
                                                                                        agree that this bill is neither necessary nor appropriate.

             "A discussion of what is best for elephants should focus not  
               on arbitrary number, but on whether or not their physical,  
               social, and mental needs are being met.  One look will show  
               you that Ringling Brothers' elephants are healthy,  
               thriving, vigorous and content:

               i)     "Our elephants are among the most physically active  
                 anywhere, and this is NOT a function of the size of the  
                 space where they eat and sleep.  Each week includes daily  
                 exercise and activities (walks, practice sessions,  
                 rehearsals, and performances) that help maintained their  
                 physical fitness.

               ii)    "Each week, our elephants consume fresh, nutritious  
                 food that is purchased locally and delivered to each  
                 performance site.  They also regularly receive enrichment  
                 in the form of edible plants such as bamboo, sugar canes,  
                 tree limbs and fresh fruits and vegetables.

               iii)   "Our elephants travel and live in social groups,  
                 often with siblings and other family members.  In this  
                 way, our elephants are able to maintain and enjoy stable  
                 social relationships.  In fact, some of our elephants can  
                 spend part of each day resting, playing or socializing.

               iv)    "Ringling Brothers' elephants receive constant,  
                 24-hour care with their primary caregivers living with  
                 them at each venue, and a team of trainers, handlers,  
                 veterinarians, veterinary technicians, and animal  
                 behaviorists who work to ensure their well-being.

               "All Ringling Brothers' animals travel in custom-built  
                 enclosures and carriers that meet or exceed all  
                 applicable federal and state requirements.  Our circus  
                 trains include cars specially designed for the safe and  
                 comfortable transport of elephants.

               "At Ringling Brothers, we have strict policies on the  








                                                                  AB 3027
                                                                  Page  29

               appropriate use of all tools, and several of the practices  
               and devise listed in this bill would violate our policies  
               as well as existing animal welfare and cruelty laws.  For  
               example, the withholding of food or water from any animal  
               for any reason other than veterinary care is prohibited.   
               All of our animal care policies are simple and  
               straight-forward, are made known to all animal care  
               personnel and prominently posted on our circus units.

               "We do not tolerate misuse of any equipment, including what  
               the elephant community calls a 'guide', referred to in the  
               bill as an 'ankus' or 'bullhook'.  Like all tools, it is  
               subject to misuse; but when used properly, it is a safe and  
               responsible part of elephant management.  Its size and  
               function has evolved over time; it now primarily serves as  
               an extension of the trainer's arm during performance and in  
               daily routines to guide the animals.  It functions much  
               like the reins for a horse or a leash for a dog, typically  
               in conjunction with a voice command.  It is used in  
               training to help the elephants understand the meaning of a  
               verbal cue and in some circumstances when noise or  
               distractions prevent the elephant from hearing a verbal  
               cue.

               "Similarly, tethering elephants during transport and  
               overnight is well recognized means of ensuring their  
               safety.  When tethered, the elephants have room to lie  
               down, move around and interact with each other.  Tethering  
               ensures that the elephants respect each other's physical  
               space - especially during meal times.  Chains are used for  
               tethering because they are sanitary, strong, and safe for  
               the elephants.  Our tethering practices are consistent with  
               the policies and requirements of the USDA.  More  
               importantly, they reflect the cumulative experience of not  
               only Ringling Brothers' experts but of elephant experts  
               from around the world.

               "The use of guide and tethers are standard management  
               practices approved by the USDA, the American Zoo and  
               Aquarium Assocation, AZA, the International Elephant  
               Foundation (IEF), and Elephant Managers Association (EMA).   
               Our policies and elephants care practices are consistent  
               with those set out in the Elephant Husbandry Resource  
               Guide, which was published by the IEF with the support of  
               the AZA and EMA.  This guide reflects the recognized,  








                                                                  AB 3027
                                                                  Page  30

               state-of-the-art, industry standards for safe and humane  
               care and management of elephants.

               "All circuses and zoos are required to be licenses by the  
               USDA and are subject to the unannounced and regular  
               inspections by the USDA seven days per week.  The Federal  
               Government also sets standards for the transportation of  
               elephants that all circuses must follow.  These regulations  
               address everything from the size and nature of encloses to  
               ambient temperatures, to food, water and exercise during  
               transport.  In addition to federal regulation, our  
               traveling shows are subject to stat and local laws  
               governing the care ad well being of animals.  We are  
               regularly inspected in almost every one of the cities we  
               perform in and such inspections consistently find the  
               Ringling Brothers animal care is excellent and meets all  
               applicable requirements.

               "While our entire herd includes 54 Asian elephants, at any  
               time we have 20 to 22 Asian elephants on our circus units.   
               The remainder is cared for at one of our two permanent  
               facilities in Florida.  The Ringling Brothers and Barnum &  
               Bailey Center for Elephant Conservation is a  
               state-of-the-art facility dedicated to the research,  
               reproduction and retirement of Asian elephants.  This  
               center is completely funded by Ringling Brothers, with a  
               portion of every circus ticket sold going to support our  
               efforts, and is staffed by highly-qualified individuals who  
               dedicate themselves seven days per week, 52 weeks per year,  
               to our mission.  It is home to the most successful Asian  
               elephant breeding program outside of Asia, having  
               celebrated nineteen births since 1992.  In addition, a  
               number of our retired elephants live at our Retirement  
               Center in Williston, Florida, where they embody our cradle  
               to the grave commitment to elephant care.

               "Sadly, the Asian elephant is an endangered species, with  
               fewer than 35,000 remaining in the world as their natural  
               habitat is continually eroded away.  Each day, more and  
               more of the so-called 'wild' disappears and elephants are  
               thrown into conflict with humans.  As caretaker of the  
               largest herd outside of Asia, our commitment goes beyond  
               the animals in our care to the entire Asian elephant  
               species.  We regularly work in cooperation with zoos,  
               researchers, and other on reproduction, conservation, and  








                                                                  AB 3027
                                                                  Page  31

               research studies, and are please to share out wealth of  
               elephant husbandry knowledge with the scientific and  
               conservation communities to achieve our mutual goal of  
               preserving this magnificent species.

               "For millions of families, the opportunity to see elephants  
               up close in a performance setting is a unique and treasured  
               experience.  It is well established that public exhibition  
               of elephants is zoos and circuses are a crucial aspect of  
               conservation education.  The affection and awe that  
               elephants generate among our audience helps focus attention  
               on the current challenges facing the survival of this  
               species and engenders a respect that no television show or  
               move can replicate.  In fact, independent studies have  
               shown that the opportunity to experience animals up close  
               in an entertainment setting significantly contributes to  
               the public's awareness of and interest in preserving these  
               magnificent animals.  This is especially true for children,  
               who not only become more aware of the animals and their  
               special needs and abilities, but also experience first hand  
               the importance of caring for and respecting all animals.

               "Unfortunately, by imposing unrealistic and subjective  
               requirements on zoos and circuses with elephants, this bill  
               would take away that important experience.  While we  
               commend and support you objective on ensuring elephant  
               welfare, this bill as written will not do anything to  
               advance it.  Instead, it would deny the people of  
               California the opportunity to see some of the most well  
               cared for elephants on the planet."

           REGISTERED SUPPORT / OPPOSITION  :   

           Support 
           
          American Society for the Prevention of Cruelty to Animals
          Animal Legal Defense Fund
          Animal Protection Institute
          Animal Switchboard
          Association of Veterinarians for Animal Rights
          California Animal Association
          California Animal Control Directors Association
          California Federation for Animal Legislation
          California Lobby for Animal Welfare
          California Lobby for Animal Welfare








                                                                  AB 3027
                                                                  Page  32

          Captive Wild Animal Protection Coalition
          Doris Day Animal League
          Friends of the Folsom Zoo Sanctuary
          Humane Society of the United States
          In Defense of Animals
          Performing Animal Welfare Society 
            Save The Elephant Campaign 
          San Diego Animal Advocates
          Senior Citizens for Humane Legislation and Education
          United Animal Nations
          Nine private citizens

           Opposition 
           
          AEG
          Animal Operations Director, Disney's Animal Kingdom
          Brockett's Film Fauna Brevard Zoo
          California Association of Zoos and Aquariums
          California Labor Federation
          California Teamsters Public Affairs Council
          Cameron Park Zoological and Botanical Society
          Carson and Barnes Circus
          Chair, Animal Health Committee, Association of
            Zoos and Aquariums
          Conservation Education Committee
          Denver Zoo
          Dickerson Park Zoo
          Elephant Managers Association
          Elephant Taxon Advisory Group
          Elephants of Africa Rescue Society
          Ellen Trout Zoo
          Feld Entertainment
          Happy Hollow Zoo
          Have Trunk, Will Travel
          International Animal Welfare Alliance
          International Elephant Foundation
          Little Rock Zoological Gardens
          National Animal Interest Alliance
          Riverbanks Zoo and Garden
          Rhode Island Zoological Society
          Roger Williams Park Zoo
          Underwood Ranches
          Sacramento Zoo
          Sacramento Zoo Education Department
          Saint Louis Zoo








                                                                  AB 3027
                                                                  Page  33

          Santa Barbara Zoo
          Species Survival Program
          Tulsa Zoo and Living Museum
          Wild Things
          Zoological Society of San Diego
          28 private individuals
           

          Analysis Prepared by  :    Scott Hinkle / PUB. S. / (916) 319-3744