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*****THIS ALERT IS NO LONGER ACTIVE***** DO NOT SEND THIS ALERT! Thank you for the opportunity to submit comments on captive elephants in the U.S. The June 10, 2006 death of Gita, a 48-year-old elephant who lived at the Los Angeles Zoo, is the latest in a string of fatalities associated with artificial confinement. By the time keepers found Gita, she had collapsed. Swift medical attention could not save her from the foot disorders and arthritis that plague captive elephants. In captivity, elephants rarely reach their anticipated life span of 70 years in the wild. From 2000 to the present, 47 elephants perished inside facilities accredited by the American Zoo and Aquarium Association (AZA) � including Lincoln Park, Birmingham, Gladys Porter, San Francisco, Disney's Animal Kingdom, Columbus, Hogle, San Antonio, Houston, Los Angeles, Busch Gardens, Oregon, Rosamond Gifford Brookfield, Indianapolis, Kansas City, Jackson, Six Flags Marine World, Dickerson Park, Bronx, Have Trunk Will Travel, North Carolina, Point Defiance, River Banks, El Paso, Milwaukee, Denver, Omaha's Henry Doorly, St. Louis, and National Zoos. At least half died before the age of 40. Some facilities lost a number of elephants in recent years. Zoos, circuses, and other commercial venues are plainly unequipped to meet the complex physical/psychological needs of elephants. A simulated environment cannot replicate the wild where African elephants span a 120-square mile home range and walk at least 5.5 miles daily. Asian elephants cover up to 200 square miles and roam 5-14 miles everyday. Conversely, the AZA requires 1800 square feet per elephant. That's just .04 acres (compared to 640 acres in a single square mile) and roughly the dimension of six parking spaces. I fully support the citizen's petition from In Defense of Animals (IDA) that calls for enforcement of the federal Animal Welfare Act (AWA) at zoos and circuses. In fact, an ongoing lack of space, exercise, and social enrichment demonstrates the USDA's failure to uphold an AWA provision requiring zoos and circuses to maintain settings consistent with the welfare of elephants. IDA's petition also rightfully asks the USDA to seize elephants suffering from captivity-provoked infirmities. An estimated 50% endure chronic arthritis and foot abscesses from insufficient exercise and endless hours upon hardened surfaces. Some elephants succumb to zoochosis, a type of psychological distress, and tuberculosis also spreads among elephants in captivity. I strongly urge the USDA to demand compliance with the AWA, either through expanding environments to encompass hundreds of acres or by relocating elephants to free-range sanctuaries where they can move in groups, swim in watering holes, and indulge in dust baths. No manufactured exhibit, even those considered innovative or optimally maintained, can emulate the natural world. Sincerely,

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