SUBMISSION102810 - (SAFE) SAFE submission Application to reassess HSNO approvals for zoo animals This is a submission on the application by the Zoo and Aquarium Association for the reassessment (under the HSNO Act) of terrestrial zoo animals and aquatic mammalian zoo animals. While some zoos have in some ways evolved, and now emphasise education and conservation as reasons for existence, they are essentially no different in function than they were 100 years ago, and can be described as “circuses without wheels”. SAFE is philosophically in opposition to zoos as we believe that they are primarily designed as places for human entertainment. Keeping wild animals in captivity inherently compromises their welfare and SAFE believes that it is impossible for zoos to fully meet the animals physical and behavioural needs as required by the Animal Welfare Act 1999 (AWA). For certain species, such as elephants, there is ample evidence and consensus of expert international opinion, which shows zoos cannot adequately meet elephants needs. Many other species are unable to fulfil their basic behavioural needs such as running or flying in zoos and should therefore not be imported into New Zealand. While zoos may have good intentions there are limitations on what they can provide for animals. There are always material, space and financial restrictions. When looking after a large variety of exotic animals there are a number of problems that arise: some animals are kept because of their popularity, not for supposed educational or conservation value; some animals are not as popular as others and become ‘obsolete’ before their time; different breeding patterns lead to ‘surplus’ animals etc. Zoos do not operate in the best interests of the individual animals themselves. The following are some initial comments on the application. We would be happy to make an oral submission in support of these points. • The controls as they are proposed are good at face value. We fully agree the physical, emotional, and mental needs of the animals must be met. • SAFE’s main concern is the implementation of the proposed controls – how will these controls be measured and implemented? • SAFE is concerned that financial insecurity faced by many zoos may place the welfare of the animals at risk. Even facilities that are owned by city councils make decisions for financial reasons that may negatively affect animals. SUBMISSION102810 - (SAFE) • SAFE is concerned that many animal enclosures are designed for people first and animals second. • SAFE is opposed to facilities that let the public touch animals. • A number of exotic animals should not be allowed into New Zealand. There is a broad consensus among animal welfare researchers and experts that pachyderms should not be kept in zoos for instance. They do not thrive, zoos can’t meet their needs, and they provide no conservation benefit to wild populations. • SAFE believes zoos have the responsibility to provide a high level of evidence that the animals’ needs are met and their welfare is not compromised. It is not the responsibility for other organisations to prove otherwise. • Exotic animals should not be imported into New Zealand for private ownership. SAFE is New Zealand’s most outspoken animal advocacy group, with over 25,000 supporters, growing public recognition, and a record of achieving effective successes for animals.
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