BOOKS: Animal Underworld

From ANIMAL PEOPLE, April 2000:

Inside America’s Black Market for Rare and Exotic Species
by Alan Green and the Center for Public Integrity
Public Affairs (250 West 57th St., Suite 1321, New York, NY 10117), 1999. 320 pages, hardcover. $25.00.

I have been waiting since November 29, 1999, for the American Zoo Association to respond to my repeated inquiries as to just what it intends to do to discourage member institutions from exporting animals to wildlife parks in China which feed live animals to carnivores. The AZA non-response was among our January/February 2000 feature topics.

I have been annoying the AZA for more than 20 years with exposes of animal transactions contradicting the intent of the AZA Code of Ethics that zoo animals should not be dispatched to abusive situations, either directly or indirectly; should not be bred other than to sustain zoo populations without wild capture; and should not, under normal circumstances, ever leave the AZA-accredited loop.

In June 1991 I was honored when then AZA-president William Conway and then-National Zoo director Michael Robinson, who just retired, denounced me by name on the oped page of The New York Times. I had pointed out how despite 1986 amendments meant to strengthen the AZA Code of Ethics, some AZA zoos continued to breed and dispose of surplus animals via canned hunts, roadside zoos, and other dubious destinations, by relaying the animals through brokers.

In November 1991 the AZA again amended the Code of Ethics to reduce the use of brokers. When in August 1994 the Humane Society of the U.S. attacked the AZA for allegedly continuing to allow accredited zoos to sell animals to canned hunts, I recognized most of the transactions cited by HSUS as having occurred and been exposed before the 1991 AZA Code of Ethics amendments, and was able to ascertain that most of the remaining handful were isolated incidents in which zoos had been defrauded and were seeking redress.

From then until late 1999, few new instances surfaced of AZA-accredited zoos circumventing or violating the Code of Ethics. Where cases were proven, along with patterns of other malfeasance, as at the Birmingham Zoo, Little Rock Zoo, and Mesker Park Zoo, in Evansville, Indiana, the AZA yanked the accreditation of the offending institutions, and the directors lost their jobs. When individual zoo staff were caught engaging in unethical deals on their own, like former San Diego Zoo reptile keeper Earl Thomas Schultz, 66, they were fired and prosecuted. Schultz, for example, was on February 16, 2000 fined $74,500 and given three years on probation, to be served following a month in a halfway house and six months of home detention.


In late 1999, however, both San Jose Mercury News reporter Linda Goldston and Center for Public Integrity staffer Alan Green extensively exposed alleged recent wholesale transgressions of the AZA Code of Ethics, which they each held were indicative of widespread failures of AZA self-policing.

Although Goldston subsequently produced a credible scoop about the AZA zoo sales to China, her initial investigative series revealed little that was not long since a matter of record. Most of the transactions she mentioned had occurred before the November 1991 AZA Code of Ethics amendments.

Soon thereafter, Green’s Animal Underworld appeared, winning rave reviews not only from activist newsletters but also from mainstream media.

We were prepared to believe that Green had done his homework, and had found significant new failures of the AZA to enforce its Code of Ethics.

As Green wrote in Animal Underworld, and insisted to us, his data was “taken from health certificates, studbooks, U.S. Fish and Widlife Service annual reports, etcetera. Every single transaction cited in my book that named an AZA zoo,” Green claimed, “was checked for accuracy with the zoo in question; they were first called, then they were each faxed specific questions about specific transactions.“

Green also told us, on February 23, 2000, “I’m happy to share my data, paperwork, etcetera, should you want any of it. Be advised, though, that lots of great things slipped through the cracks, since my collection procedures were inherently flawed.”

But Green began to balk when that same day I asked him, “In connection with researching Animal Underworld, did you ever assemble a scorecard pertaining to AZA zoos caught in dealings which appear to circumvent the ethics code? I have in mind,” I explained, “assembling a table that would look something like this—

DUBIOUS TRANSACTIONS/ANIMALS 1991 1992 1993 1994 1995 1996 1997 TOTALS

Zoo A 2/10 3/40 3/25 9/33 2/34 8/23 9/45 36/216

Zoo B 7/43 0/0 6/77 7/7 1/24 7/61 7/19 35/181

ALL 9/53 3/40 9/102 16/40 3/58 15/84 16/64 87/510

The idea would be to show at a glance,” I continued, “which zoos are involved in dubious dealings, how often; how many animals are involved; what the trends have been; whether AZA ethics code amendments have had even transient effect; and what percentage of AZA members are involved (or at least getting caught) at any given time.”

Assembling such a chart is among the first things I do in evaluating any kind of data which can be statistically evaluated, to see whether apparent patterns really exist and whether they meet an elementary test of significance, or whether they could be ascribed to a random confluence of accidents.

As Green had neither charted his data nor applied any other test of significance to it, I spent seven hours graphing all of the transactions mentioned in Animal Underworld w h i c h allegedly resulted in animals moving from AZA-accredited institutions to destinations or dealers whose practices would appear to violate the AZA Code of Ethics.

Green alleged such transactions involving 59 of the 183 AZA zoos––32%. But from the year preceding the 1991 AZA Code of Ethics amendments through 1997, the most recent year within which Green identified any specific dealings, he actually cited by zoo name, name of buyer, year of transaction, and number or approximate number of animals only 30 cases, involving 28 AZA zoos. These deals involved 397 animals total. Most of the deals were already matters of public record; many involved malfeasance which had already been prosecuted and punished. The majority of the deals Green cited, involving 24 AZA zoos and 219 total animals, occurred in 1996. Only four AZA zoos were identified in connection with more than one deal cited by year.

Multiplying the 183 AZA zoos by the seven years 1991-1997 produced 1,281 opportunities for Green to have caught an AZA zoo in a dubious deal at least once during the year. Even limiting the analysis to just the 59 AZA zoos Green mentioned, which markedly lowers the bar for a test of significance, Green had 413 opportunities.

A recurring pattern could have showed several zoos repeatedly involved in dubious dealings over the seven years; many zoos involved in one year, e.g. 1996; or enough zoos, overall, that the grid assumed something of a checkerboard appearance.


Green presented data enough to fill only 6.7% of the 413 grid squares on a chart listing only the zoos he named as being in the traffic. Even in 1996, his strongest year, Green cited specific dubious deals involving only 24% (14) of the AZA zoos he claimed were involved: 7.4% of AZA members.

That leaves most of Green’s case essentially unsubstantiated, at least within Animal Underworld. Failing to state enough “who, what, where, when” particulars to establish recurring patterns, Green instead cites many of the same cases over and over. The parade of animals going out zoo gates that Animal Underworld appears to have discovered turns out to be more like a carousel.

Like Goldston, moreover, and like HSUS in 1994, Green also describes many deals which occurred before the AZA Code of Ethics amendments of 1991, and even before the amendments of 1986. Green hints that such practices continue, yet presents little firm evidence that they do, let alone that they remain common. Meanwhile, many of the people most responsible for the long-ago transactions have been removed from executive positions, have retired, and/or have died.

After doing my initial graph, I listed (as appears on page 21) all of the AZA or former AZA zoos that Green named, along with the Animal Underworld allegations involving them.

I e-mailed it to Green on March 2. “If you see the word ‘alleged’ in the description of the transaction, it means that you did not provide the year or years in which the dealings are supposed to have occurred, and probably did not provide the number of animals supposedly involved, either,” I explained to him. “I would appreciate receiving the dates and numbers at your earliest convenience. I anticipate reviewing Animal Underworld approximately one week from now. If your allegations hold up well enough to fill in a substantial part of my graph, showing a recurring pattern of evasion of the AZA Code of Ethics, we’ll publish the graph and the AZA and member institutions will be asked to respond to it. If not, I will be questioning your investigative technique.”

Responded Green, “If you expect me to pull together all my records for you to confirm this, I’m afraid you’re dreaming. Go ahead and question my ‘investigative technique,’ if you wish. Your use of allegedly throughout this chart is, to say the least, insulting. (What do you base your suspicions on—the fact that a date isn’t included? Maybe you think it’s compelling reading to include thousands of dates in a book, but I don’t.)”

But “compelling reading” without specificity and substantion is a good definition of fiction––or libel. Credible journalism requires citing “who, what, where, when,” with specificity and routine attribution of information to sources.

If a reporter cannot do that, or does not do that, he or she is “alleging”––and may still be alleging, even when presenting the best-documented material, if interpretations are open to reasonable doubt.

Fiction asks readers to suspend disbelief, and take statements on faith. Quality journalism says, “This appears to be true because this person did it in this place, at this time. These witnesses have provided their accounts.”

Green on March 2 again claimed to have specific support for the Animal Underworld allegations. “You put in your chart, for example,” Green wrote, “that the San Antonio Zoo ‘allegedly’ sent birds to the Flamingo Hilton and Zoo Atlanta ‘allegedly’ sent animals to Robert Crowe. Allegedly? I have a health certificate for the first transaction, and the second transaction is in the studbook. In both instances—in all instances, as I just told you—these transactions were confirmed with the zoos in question. If they did not confirm the transactions, they were removed from the text.”

But if Green has such documentation, it is not cited with specificity within Animal Underworld. Except for 30 possibly isolated cases, Green has not substantiated in print that the deals he alleges occurred after the 1991 AZA Code of Ethics amendments, with the approval of the senior zoo man-agement.

Further, after failing to make his case in Animal Underworld, Green declined our offer of a second chance to substantiate his material.

Thousands of animals were sold by AZA zoos through brokers to private keepers, breeders, roadside zoos, and canned hunts before 1991––especially prior to 1986. Many of these animals became foundation stock for the exotic pet trade. While some private exotic animal keepers provide exemplary care, many are negligent, or overtly abusive. Few are properly prepared to look after their acquisitions throughout their lives. Exotic animal sanctuaries are consequently overburdened; humane societies and animal control agencies are increasingly often asked to handle species for whom they have no facilities; abandoned and escaped birds, mammals, and reptiles whose ancestors inhabited zoos have established feral populations in almost every state.

It may be that some AZA zoos are still knowingly contributing to this large, growing, and mostly undocumented non-AZA breeding pool, by breeding unnecessarily and selling surplus animals through brokers, exactly as they used to, and exactly as Green alleges. Had Green focused on particular offending institutions, or on deals occurring within a specific slice of time, he might have made a credible case.

Had Green then been able to show indifference on the part of the AZA, and on the part of the USDA Animal and Plant Health Inspection Service, whose regulatory response forms a necessary backup to AZA selfpolicing, Green might further have made the case he claims to have made for endemic institutional failure.

Describing scattered deals over a broad time frame, however, falls far short––especially when the AZA and USDA-APHIS have already responded to much of the traffic with penalties as severe as the AZA Code of Ethics and Animal Welfare Act now permit.


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