February 2, 2016

Dr. Robert Gibbens, DVM

Western Regional Director
USDA, APHIS, Animal Care
2150 Centre Ave. Bldg. B
Mail Stop #3W11
Fort Collins, CO 80526
Via e-mail: Robert.M.Gibbens@aphis.usda.gov
Dear Dr. Gibbens:
Please consider this to be a formal complaint on behalf of Friends of Woodland Park Zoo Elephants regarding
the January 30, 2016 death of Chai, a 37-year-old female Asian elephant held at the Oklahoma City Zoo
(license # 73-C-0002) in Oklahoma City, Oklahoma.
According to the zoo (http://www.okczoo.com/news/m.blog/56/oklahoma-city-zoo-saddened-to-announcedeath-of-adult-female-asian-elephant) staff discovered her [Chai] in the elephant yard Saturday morning.
Comments made by a zoo spokeswoman to The Seattle Times (http://www.seattletimes.com/seattle-news/chaithe-elephant-moved-from-seattle-found-dead/) confirm that Chai was not monitored overnight by zookeepers. It
is unclear whether night watch staff, if any, conducted regular inspections or whether video cameras are
installed on any part of the elephant exhibit. There is, therefore, no indication of how long Chai was recumbent,
or whether earlier staff intervention could have prevented Chais death or remediated any suffering. There is as
yet no announced cause of death.
At age 37, Chais death was premature, considering the possible life span of Asian elephants is up to 70 years in
the wild. Chai's age was well under the median zoo death age (according to the zoo's statement) of 47. It is
unclear whether Chai was left outside by the keeper staff when they left for the night and also whether she had
free access to both the indoor and outdoor areas of the exhibit. The temperature in Oklahoma City dropped to
the low 30s during the night in question (http://w1.weather.gov/data/obhistory/KPWA.html); clearly it would be
a violation of safe-handling provisions, cited below, for an exhibitor to fail to provide animals adequate
protection from the cold. We contend that elephants, particularly newly-introduced elephants and elephants
where temperatures can drop to the point of being dangerous to them, must be monitored, or at least checked on,
during the 13-plus hours that keeper staff is absent.
Further, medical records indicate that Chai suffered from chronic foot disease, confirmed by two independent
veterinarians (see links below). It is inconceivable that the Oklahoma Zoo was unaware of Chais medical
condition, or that the condition was a potential cause of premature death, and one of the leading causes of death
in captive elephants. It is also our contention that Chais known medical issues should have been cause for
greater vigilance on the part of zoo management and staff, including some form of nighttime monitoring, and
that the zoos failure to provide nighttime monitoring to an elephant known to have chronic and potentially lifethreatening health issues violates provisions of the Animal Welfare Act (AWA), which provide:
Sec. 2.40 Attending veterinarian and adequate veterinary care (dealers and exhibitors).
(b) Each dealer shall establish and maintain programs of adequate veterinary care that include:

(1) The availability of appropriate facilities, personnel, equipment and services to comply with the
provisions of this subchapter;
(2) The use of appropriate methods to prevent, control, diagnose, and treat diseases and injuries, and
the availability of emergency, weekend, and holiday care.
Sec. 2.131 Handling of animals.
(a) All licensees who maintain wild or exotic animals must demonstrate adequate experience and
knowledge of the species they maintain.
(b)(1) Handling of all animals shall be done as expeditiously and carefully as possible in a manner that
does not cause trauma, overheating, excessive cooling, behavioral stress, physical harm, or unnecessary
discomfort.
Sec. 3.132 Employees.
A sufficient number of adequately trained employees shall be utilized to maintain the professionally
acceptable level of husbandry practices set forth in this subpart. Such practices shall be under a
supervisor who has a background in animal care.
Please note that on July 22, 2015 the USDA found the Oklahoma City Zoo to be noncompliant with numerous
provisions of the AWA affecting several species, including elephants. According to the inspection report,
inspectors found rodent droppings on the floor of the elephant food preparation area which can create
unsanitary conditions that lead to potential spread of disease.
(http://www.freewpzelephants.org/docs/USDA_Inspection_Report_OCZ_citations.pdf)
We urge the USDA to take immediate action to fully investigate the circumstances of Chais death, including all
medical records and necropsy reports. We suggest that this review should include an independent assessment of
the necropsy findings. We further suggest that your agency should review footage of any video, including
closed circuit television, that may have been taken prior to and during the time when Chai was in the yard
unattended. There should also be review of the exhibitor's policies that address whether the elephants are
confined to the indoor exhibit overnight, or confined to the outside, or have free rein between inside and out.
Finally, we ask that USDA evaluate the night watch logs, if any, and determine the exhibitor's policy for
overnight checks on the elephants. Should violations of the AWA be found, we further urge the USDA to take
appropriate enforcement action.
Thank you for your prompt attention to this matter.
Sincerely,
Nicole Meyer
Statement by Dr. Mel Richardson on Chais medical condition, see page 21:
http://www.freewpzelephants.org/largefiles/Optimal%20Future_KP_4-12_web.pdf
Declaration by Dr. Philip Ensley on Chais medical condition:
http://www.freewpzelephants.org/docs/Declaration_Ensley.pdf