USDA Animal Care Policy Comments

Policy #1

License renewals should meet the same criteria as initial applicants in
that no license should be renewed if the last inspection report cited
deficiencies that were not corrected in 90 days.

Denial of a license to those who have been jailed for animal cruelty
should also include those who have been jailed for any form of illegal
trafficking of narcotics and/or weapons, as these are often the same
violators involved in the illegal trafficking of wildlife.

Denial of a license to those who are under investigation for animal
cruelty should also include those who have been jailed for any form of
illegal trafficking of narcotics and/or weapons, as these are often the
same rings involved in the illegal trafficking of wildlife.

Policy#2

Exhibitors should be required to notify USDA ANY time regulated animals
are taken off site from the licensed facility, except when they are
being transported directly to and from a veterinarians office who is
licensed in that state.

Policy#3

The Program Veterinary Care should require an on site visual inspection
of the animals by the attending veterinarian no less than monthly.

\*While the AVMA may approve the reduction of canine teeth to address
human safety concerns, the purpose of the AWA is to ensure the welfare
of the animals which is not enhanced by such procedures. On the
contrary, such procedures put the animal at risk of severe pain caused
by the exposure of the pulp cavity that may not be readily ascertained
by virtue of the fact that wild animals conceal their infirmities.

Policy#5

The AWA should prohibit the exhibition of animals at auctions and other
off site venues. Due to the inherent nature of all wild animals to be
stressed by loud noises, confinement, new environments, and the close
proximity of people, an animal auction, flea market, fair ground, school
yard or shopping center parking lot exposes these animals to an
unacceptable level of stress and anxiety. These situations also expose
the public to an unwarranted level of risk, provide no real benefit, and
should be prohibited ENTIRELY.

Policy #6

Traveling acts that use big cats have been banned in other countries and
at the local level in the United states. There is no way that any
traveling display can meet the space and exercise requirements of exotic
cats and no way that the USDA can effectively monitor the daily
requirements suggested by the AWA. The minimal standards required in the
past have never been properly enforced and are detrimental to the health
and well being of the animals.

Every rescued cat that I have worked with that came from traveling acts
have suffered from a variety of injuries as a result of the confinement
including scarred hips and elbows from hitting the cage walls
constantly, missing fur on the nose from incessantly rubbing their faces
against the bars, chapped and bleeding feet from being kept on wood or
concrete surfaces, poor muscle mass from the lack of exercise, scarred
lung tissue from breathing urine laden air, blindness from repeated
photo sessions, broken teeth from biting the cage bars and a host of
psychological issues from being forced into close confinement with other
cats and the public. Since there is no way to protect the welfare of
these animals while they are on the road and with no justifiable reason
to continue the activity, it should be strictly prohibited.

If spending money cannot be considered a factor in whether an animal is
given proper medical care, then making money should not be a factor in
whether or not the animal can be induced to suffer for the purpose of
generating income for his owner.

\*Cage space is general was not a part of your policy manual, but
absolutely should be. Some states still have no regulations governing
the cage size, construction and substrates and those places rely on
USDA's standards which are cruel beyond description. Enough space to
stand up and turn around is NOT meeting the needs of any animal,
especially not large exotic cats who collectively are designed to roam
as much as 100-400 square miles, leap as far as 40 feet and run at
speeds of up to 70 miles per hour. While no cage is suitable for meeting
these needs, the minimum should be a minimum of 1200 square feet.

Large Cats (weighing more than 60 pounds)

Lion (Panthera Leo )

Tiger ( Panthera Tigris )

Leopard ( Panthera Pardalis )

Snow Leopard ( Uncia Uncial )

Jaguar ( Panthera Onca )

Cheetah ( Acinonyx Jubatus )

Clouded Leopard ( Neofelis Nebulosa )

Puma ( Puma Concolor )

And all subspecies and hybrids thereof.

\*Size and Complexity

Enclosures should provide sufficient mix of cover such as brish, tall
grasses, trees, den areas, elevated areas and opportunities to climb.
Enclosures should provide ledges or perches for sleeping and resting.

\*Enclosure size for one large animal weighing over 60 pounds should be
a minimum of 1200 square feet. Each additional animal requires an
increase of 25% of the original floor space.

\*Enclosure Construction and Elements

Solid concrete footing with the caging embedded at least 2 feet in the
ground as a base for any large exotic cat enclosure. Dens shall be
provided for each individual cat and shall be dry, and of sufficient
size to make the animal feel secure and not threatened.

Swimming pools should be required for all large exotic cats.

\*Safety

The aggressive nature of all of large exotic cats, given their physical
strength and capabilities, demand that all caregivers take extreme care
when designing enclosures for these animals to reduce the risk of
climbing, escaping, or reaching through the fencing of the enclosure.

All large exotic cats demand that walls be a minimum of 12 feet tall
with a 2 foot back drop at a 45 degree angle, or be provided with
complete top coverage if not completely surrounded at the top area by
hot wire. The cage shall be constructed of no less than 9 gauge fencing
wire for large exotic cats.

Secondary holding areas shall be provided to allow for safe movement of
animals from their primary enclosure into a secure area for feeding and
cleaning, maintenance, medical and other necessary procedures.

All cage doors must remain locked at all times.

\*Temperature/Humidity/Ventilation

While large exotic cats originate from hot, arid regions, most are very
tolerant of a wide variety of temperature extremes, at least during the
daylight hours. Normal temperatures dictate one enclosure at night. If
temperature extremes exceed those of an exotic cats native habitat,
shelters must provide heating systems for use in severe winter weather
conditions and cooling systems for extreme summer temperatures. Systems
must be properly prepared, designed, and situated to prevent destruction
by the animals.

\*Food/Watering/Feeding

Diets should be based on commercially available beef or horse-based
diets or custom made diets which provide all necessary vitamins and
minerals. Custom made diets shall be reviewed by the attending
veterinarian and/or veterinary nutritionist.

Animal carcasses may be substituted as feed on occasion to vary the diet
and provide enrichment for the animals. These carcasses must be limited
to fresh or thawed carcasses. All food shall be handled according to the
guidelines set forth in the USDA handbook.

Communal feeding is discouraged for all large exotic cats to prevent
aggression or other dominant behavior among the animals. If communal
feeding is not possible, all animals must be closely monitored daily for
changes in weight, fecal matter, and urination.

Large exotic cats must be fasted once per week to remove any existin
bacteria or parasites living in their digestive systems which have not
or will not pass on their own.

Bones should be given once a week to keep the teeth healthy.

\*Water bowls must be cleaned daily and bleached at least once per week.
Animals must have access to cool, clean water at all times. Bowls must
meet specific construction requirements for the exotic cat's size to
prevent chewing or digesting the bowls.

\*Social/Psychological/Physical and Behavioral Well-Being

Preventative heartworm medications shall be provided to all animals. At
a minimum, annual complete physicals of all animals on property must be
administered. Annual vaccinations will include feline distemper,
Rhinotracheitis, and FVRCP. Only killed Virus ( KV ) products shall be
used. Annual rabies vaccinations must be administered. Animals must be
tested for Tuberculosis when deemed necessary by the attending
veterinarian.

Areas prone to fleas and ticks shall be sprayed using only commercially
approved chemicals. These must be approved for use by the attending
veterinarian as safe for the species involved.

Some large exotic cats benefit from companionship, while others prefer
solitary enclosures. Those animals living in an enclosure alone who will
be introduced to another large exotic cat must have a mandatory 30 day
quarantine period. All introduction plans must be fully explained,
presented to the USDA and be approved by that agent before any
introduction may take place to ensure that the animals safety is the
number one priority in any introduction.

All animals must be given enrichment activity at a minimum of every
third day. These include but are not limited to boxes, balls, bones,
barrels, rawhide, pools, and scent enrichment.

\*Handling and Restraint

Large exotic cats should not be handled except for medical purposes.
Infants in captivity can be handled until the age of six months or 100
pounds, only to learn basic vocal commands and will only be interacting
with a experienced/"hands-on" individual.

\*Quarantine/Isolation

All newly acquired animals must undergo a 30 day quarantine to prevent
any spread of underlying illness or disease. All caregivers must be
required to wash their hands with bleach after cleaning feeding these
newly acquired animals and before interacting in any way with the
existing animals to prevent the spread of illness or underlying disease.
All newly acquired animals must be tested for Feline Immunodeficiency
Virus ( FIV ), Feline Leukemia Virus ( FeLV ), Feline Infectious
Peritonitis ( FIP ), and Toxoplasmosis prior to being placed with or
near other animals.

Policy #8

USDA should be required to seize and place animals when they have
suspended or revoked a license and the former lecensee continues to
operate in violation of the order. There is no reason for anyone to
subject themselves to licensing under the current situation where there
is little to no enforcement or penalties in place for acting outside the
law. Fines against the indigent are of no value.

USDA investigators who are aware of any facility in their investigatory
region who is unable to care for their large exotic cats and are trying
to place them with other facilities, MUST be required to at least
attempt to use their contacts to help place these animals. In my own
experience, my investigator was aware for one year of the malnourishment
and exceptionally poor living conditions of one particular large exotic
cat. The owner had repeated asked for the investigators assistance and
was repeatedly ignored. This cat was euthanized because the owner could
no longer properly care for the animal and was sold to a taxidermist.

Policy #11-20

All research facilities should be required to post their activities
regarding regulated animals in a place easily accessed by the public.
This would end the needless pain and suffering that animals endure due
to measures performed behind closed doors.

Feeding charts for each animal on property must be posted for all
employees and inspectors to readily note. This should include what kind
of meat is fed, if different meats are mixed together what ratios are
given to which animals, and how much each animal consumes on a daily
basis.

If any animals are currently being medicated, this should also be posted
for all employees and inspectors to readily note. This should state what
animal is on medication, and what dosage and regularity the medication
is given, as well as its expected duration.

\*\*Inspectors must be required to inspect facilities on a yearly basis,
but must also be REQUIRED to inspect at least one additional time during
the year. Most inspectors come to the same facilities around the same
time each year. This gives unfit caregivers ample opportunity to clean
up their facilities for the inspections and then let it quickly
deteriorate to its previous condition before the inspection. I have
witnessed this procedure in several places many times. 51 weeks of a
year a facility will operate on any level it pleases until it is time
for the inspector to arrive. There are animals who live in deplorable
conditions through-out the year as the caregivers know there will be no
surprise inspections or follow-ups. THIS IS COMPLETELY UNACCEPTABLE.

\*Finally,

ALL owners of large exotic cats MUST have a USDA License, State or
Federal Wildlife Commission License, or other state mandated regulatory
agency license. If you do not have the knowledge, background, training,
experience, and/or monetary abilities to care for these animals the way
they should be cared for, no one should be allowed to house them. Any
individual caught with a large exotic cat in his/her possession without
a license to have such should be required to do mandatory prison time
with a large monetary fine. If no regulations exist that punish these
private owners, the process of breeders selling to the public as pets or
to exhibitors to be used as photo cats, the animals will continue to
suffer neglect and abuse to extreme proportions. At the moment, the only
individual who pays for these crimes are the animals who are euthanized
because they are now homeless when private owners can no longer house
them or photo exhibitors can no longer use them for photos because they
have grown too large. This practice is COMPLETELY UNACCEPTABLE!

For All The Large Exotic Cats,

Valori T. Russell

Head Caretaker

Crown-Ridge Tiger Sanctuary

19620 State Route B

Sainte Genevieve, MO. 63670

1.573.883.9909 Office

1.573.535.1630 Cellular

1.573.883.7901 Fax