Please send your comment to oppose the Florida Fish and Wildlife Conservation Commission's (FWC) Rule for Elephant Rides: 

Deadline April 20, 2018

The Florida Fish and Wildlife Conservation Commission (FWC) recently held a "stakeholder" meeting in Lakeland, Florida to discuss issues relating to fencing, administration, and animal welfare pertinent to elephant rides in Florida. We believe that these issues are up for discussion as a result of pressure from the animal rights extremists, and for no other reason. 

If you care about the future of elephant rides continuing in the state of Florida, please send a comment OPPOSING a rule change to the FWC portal before April 20, 2018. 

Please feel free to reference the information below for your talking points, and then click the "Comment" button below to submit your comment in the Florida Fish & Wildlife Commission (FWC) comment portal. 

Many thanks!

The Cavalry Group Team



      • Exhibitors must obtain proper permitting and licensing to give elephants rides•

That regulation is already a standard requirement for all USDA license holders. 

      • Qualifications for elephant ride authorization 

Elephant ride Permit holders in the state of Florida have already proven qualifications to receive permitting. This is redundant. 

      • Defining safety barriers

Barriers are already federally required and mandatory , for anyone exhibiting elephants and /or giving rides.   Construction fencing is used on construction sites throughout the state of Florida , and aluminum rail fencing is used on every carnival midway in the state of Florida. Both are considered “safety fencing “ and used as such . Both are more then sufficient safety barriers. These are barriers for the general public , and not meant to contain the elephants. There is a secondary barrier specifically for containing the elephants, that is also already a federal regulation in place .   

      • Defining safety barrier distance

The distance is usually set by the licensee based on location and available space. Setting a specific distance on said barriers is extremely restrictive, making it nearly impossible for permit holders to stay in compliance with such restrictive limitations. Licensees are permitted and licensed for reasons just such as these types of judgment calls in specific situations . To impose such restrictions is impeding on permit holders rights to preform rides in an safe, efficient and financially beneficial manner.  Each individual permit holder is experienced and aware of what distance is safe, based on their own animals and the confines of each location. A suggested  minimum of a 12 feet distance provides a workable distance to confine the elephant from the general public,and is acceptable. Again, There are already two barrier systems in place, an elephant safe barrier and then a safety barrier for the public. 

      • Establishing the number of public allowed inside of barriers

This issue is extremely important . By restricting the amount of public allowed within the safety barrier FWC would be infringing on the permit holders right to operate a business. Such bias is concerning and alarming . With the current USDA regulations there is already sufficient public safety protocol in place protecting licensees and the general public. As there is more danger for the general public walking down the street then there is attending an elephant ride the fact that this issue is being brought up at this time might lead permit holders to think that these proposals are being formulated by special interest groups who are not permit holders and do not have any experience with captive animal care. 

      • Elephant Tuberculosis (TB) Exposure and Public Safety

Based on the CDC 2016 incidence reports and the 2017 recommendations of stakeholders task force on management and research of Tuberculosis of elephants , this is now the standard followed by ALL state veterinarians offices.

TB is a communicable disease common to elephants and humans, but TB is not highly transmissible . Only through PROLONGED contact in an enclosed “shared air” environment can one contract TB from an actively shedding patient. 

Currently there are 480 elephants inside the USA, 231 of those are Asians, with the rest being African elephants. NO African elephant in a zoo or circus has ever tested positive for Mycobacterium Tuberculosis. Only Asians are currently transmitting . 

At this time African and Asian elephant exhibitors that are USDA/APHIS/AC class C are required to to submit to yearly triple sample TB trunk wash cultures. ALL TB positive animal are NOT allowed to travel or give rides. However , sanctuary elephants are not required to be TB trunk wash tested due to their lack of travel/public exhibition. The incidence of TB in these facilities is exponentially higher . 

The chance of the general public contracting TB from an elephant during a ride exhibition at a zoo/Park/circus is virtually zero . 

In the rule FWC change, they propose changing the word “may” to “shall” in the paragraph regarding FWC removing an elephant from rides/exhibition is extremely concerning for permit holders, as it changes the option to a non option . The word “may” suffices, as each situation is handled independently and on a circumstantial basis. Removing “may” and instituting “shall” is final ,conclusive and interminable. Such terminology is egregious, flagrant and capricious.  

FWC is an agency which is supposed to provide fair and unbiased supervision to an industry that already has regulations and standards for all its licensees and permit holders. These types of radical and unnecessary rule changes are concerning and alarming to its stakeholders. 

Such irregularity and inconsistency from FWC appears to give merit to certain assumptions that these recent rule changes are due to the constant pressure and harassment from animall rights extremists and their organizations which are perpetuating misinformation and propaganda. Accordingly, FWC shouldn’t be intimidated by such groups and should facilitate stronger permit holder communications and encourage those with the experience and education to be included more clearly in any rule changes or regulation revising as it adjusts with current laws and legislation. 

In changing “may" to "shall" in the language of the FWC rule change, this verbiage would grant FWC the permission to take custody or control of a privately owned ,multimillion dollar entity that is considered private property by the law, thus effectively removing an animal from its rightful owner before due process .  

In the state of Florida currently there are only 4 elephant ride permits being utilized , and that all of these permit holders have maintained this permit , on record, for years with no accidents or incidents involving safety protocol. 

Please send your comment OPPOSING a Rule Change to the FWC comment portal by clicking the Comment button. Also, please send your email to the list of legislators listed below:







 

The Cavalry Group • P.O. Box 147 • Grover • MO  63040 •  Ph: 855-748-4210

 
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