Correspondence

29 November 2022: letter from Zoos Expert Committee to Lord Benyon

Published 24 May 2025

The Rt Hon. the Lord Benyon, Minister of State (Department for Environment Food and Rural Affairs)

29 November 2022

Zoo Experts Committee Response to Rt Hon. the Lord Goldsmith’s Letter and Questions on the Elephant Working Group 10-Year Report

Dear Lord Benyon,

Contained in this letter is the Zoo Experts Committee (ZEC) response to the six questions posed by the Rt Hon the Lord Goldsmith of Richmond Park (the Minister) in his correspondence of the 3rd December 2021 regarding the Elephant Working Group’s (EWGs) 10-year report (the Report).

All ZEC members have reviewed the Report and we have further discussed its findings, with permissions from the Defra Secretariat, with a wide range of relevant external consultees, the identity of which can be found in the appendices below. These consultees were also asked for their responses to the same six questions posed to ZEC by the Minister, as well as their general observations and views on elephant keeping in captivity in the UK in order to ensure all opinions and relevant expertise were taken in to account in this response from ZEC.

In the first instance ZEC believes the authors and collaborators on the Report should be highly commended in their efforts to draw together the data and develop the elephant welfare assessment tools. It should also be noted that ZEC acknowledges the EWG followed the original remit given to them by Defra and the Zoos Forum.

ZEC acknowledges many of the problems around producing such a report, not least the small numbers of animals and zoos/institutions involved leading to inevitable difficulties around assessing any improvements or deteriorations and their true scientific significance. ZEC is also aware, any such 10-year report about an animal as potentially long-lived as elephants, can only be a snapshot of the individual elephant’s welfare with changes in many parameters such as longevity being very difficult to assess. In addition, questions have been raised regarding the potential for bias during collection of data for the Report, and whilst validation of methodologies has been attempted, some restrictions due to limited resources were inevitable and further refinement of methodologies used is proposed.

However, regarding the six questions posed by the Minister, ZEC believes the following answers are representative of data gathered in the Report, further clarified by those externally consulted in the appendices:

Question 1

What is your assessment of the extent to which the welfare needs of elephants kept in UK zoos are currently being met, including whether this is at an acceptable level in relation to each key elephant welfare criterion highlighted in the Zoos Forum’s 2010 report (attached)?

After review of the Report, and discussion with stakeholders ZEC’s views are as below (as per the welfare criteria from the Zoos Forum 2010 report).

Social composition

ZEC believes the Report shows an acceptable improvement from a situation in 2010 where only six of sixteen elephant keeping zoos/institutions housed any genetically related elephants to a situation in 2019 with six of twelve zoos/institutions having a more appropriate age-graded structure with multiple female elephants present.

ZEC still has concerns, highlighted by some of the consultees, that young bulls, due to their rapid sexual maturation, are still being removed from their mothers earlier than they would naturally leave their mothers in the wild and further work should be directed to determine why this is deemed necessary and attempt to reverse it.

Three elephants are recorded as being kept on their own in some collections in 2019 versus none in 2010. These are believed to be in the individual elephant’s best interests after veterinary and expert assessment due to underlying health problems and the difficulties of integration within non-familial groups. This situation should continue to be actively monitored in ZEC’s opinion.

Available environment

Space requirements have increased (total space rising from 4014m2/elephant to 6406m2/elephant) over the period of the Report which ZEC believe is acceptable. However, it should be noted that due to the small number of zoos/institutions keeping elephants, the space provision can be significantly influenced by one collection and so some collections have not shown improvements. ZEC would like to see the new standards enforced with a minimum outdoor space of 20,000m2 for five or fewer elephants and indoor space of at least 600m2 for four or fewer elephants with an added minimum of 100m2 per additional elephant.

Restraint by chaining an elephant overnight was a common practice historically but by 2019 no zoo/institution was using this practice. In 2019, chaining where practiced, was for usually less than 1 hour per day, and only used in zoos/institutions practising free contact (included 11 elephants in 5 facilities). This is a substantial improvement which has a marked impact on welfare, as chains severely restrict mobility, activity, and choice/agency in elephants. ZEC for this reason amongst others would like to see further improvements with the cessation of free contact in elephant keeping zoos/institutions and so the cessation of chaining as a routine (see Handling Methods).

Substrates have improved from 13% of zoos/institutions offering softer/natural substrates considered good for foot and musculoskeletal health to 77%. ZEC views this as acceptable but would want to see all zoos keeping elephants to urgently provide such substrates and by no later than 2030.

Choice of environment has also improved with 50% (6/12) of female/calf herds having 24/7 choice between indoor/outdoor enclosures in 2019 versus 12.5% (2/16) of zoos in 2014. ZEC however believes there is considerable room for further improvement in this area and further research required into bull elephant environment choices, particularly outdoor access 24/7.

ZEC and many of the consultees did raise the concern over suitable outdoor temperature ranges in the UK. Data is deficient as to whether the colder UK climate does significantly impact on elephant welfare, but logic dictates that where elephants have to be housed indoors due to bad weather and the housing results in significant reduction in space and environmental enrichment provision, this will have a negative welfare effect. Future research must include evidencing enclosure use in relation to climate.

Obesity, diet issues and exercise

The Report demonstrates an overall improvement in body condition from 92% of elephants being mild to moderately overweight before the EWG report to all (n=50, 2019) being at the high end of the ‘normal’ range or lower end of the ‘over condition/weight’ according to the EWG Body Condition Scores. It should be noted that some issues surround the differing mechanisms used to assess body score in the Harris et al. report (2008) versus the newly developed EWG tools meaning direct comparisons are therefore not possible and so hamper the understanding of the significance of any improvements. ZEC believes that whilst overall this criterion is believed to have demonstrated progression, body condition scores must be further improved and ZEC would like to see the continued use of the body condition scoring tools produced by the EWG in all elephants, including further refinement for African elephants, to ensure comparable data is collected going forward.

Improvements in the diet of elephants began before the Report, with amongst other things, a reduction in processed foods and increase in fibre provided by browse. ZEC believes this must continue and further monitoring to ensure year-round browse feeding in captive elephants continues.

Options for increased exercise have improved for most elephants with space provision improvements and improvements in 24/7 indoor/outdoor access but there is further work to be done (see Available environment).

Gait and lameness

The Report demonstrates that foot health has improved with the percentage of severe problems dropping from 52% (40/76) of elephants in Harris et al. (2008) to 10% of elephants (5/50) in 2019. The percentage of elephants with no foot problems remains constant at 20% over the same range. Locomotion has improved from 16% (12/76) of elephants that had no locomotion issue in 2010 to 74% (n=28) having no locomotion issues in 2019. ZEC feels this progression is in the right direction, but notes that some of the improvements are due to the death or export of some elephants who had the worst foot and gait scores. ZEC would like to see further improvements in foot and gait scores going forward.

Stereotypies

Stereotypical behaviours have reduced from 55% (42/77) of elephants demonstrating stereotypies during the day and 49% (20/41) during the night (Harris et al. 2008) to 33% (17/51) during the day and 24% (12/49) during the night in 2019. ZEC believes this is an acceptable progression but acknowledges that stereotypies may take many years to develop and once established may be permanent even with subsequent positive husbandry changes and so collection of further data to determine how these behaviours develop must be encouraged. It should be noted very low levels of aggression are currently (2019) recorded (less than 0.1% of interactions).

Other aspects of health

ZEC believes considerable improvement in the understanding of diseases such as elephant endotheliotropic herpesvirus (EEHV) infection have been made over the 10 years of the Report. As high calf mortality rates are particularly linked to this disease, such research is essential to continue in the view of ZEC and others. Tuberculosis has not been recently detected in the UK population of elephants. Those involved are to be commended for this progress and ZEC hopes continued breakthroughs will occur.

Survivorship

The Report demonstrates that the average lifespan from 2006 – 2019 among the elephants born into the UK population remains low at ~17 years, similar to previous estimates for the European zoo population. For elephants already in the UK population who survived to at least 20 years of age, some progress has been made in ensuring that these older individuals survive longer. It should be noted though that median longevity for captive born elephants remains less than 20 years due to high early mortality, often associated with EEHV infection (see ‘Other aspects of health’). Therefore, no appreciable progress has been made in ensuring longevity among the cohort of UK zoo-born elephants. ZEC notes that 10 years is also too short a period of time to fully assess whether any changes in survivorship are significant and recommends further collection of data and analysis.

Fecundity

The Report shows some improvement with a move from all female elephants being obese with abnormal cycling and low fecundity to many elephants being within normal weight and body score ranges in 2019. Fecundity however remains low. ZEC is still concerned that female elephants are becoming sexually mature and breeding at earlier ages than their wild counterparts and this may be contributing to why fecundity remains low with further research in this area being recommended.

Handling methods

The Report demonstrates that there has been an acceptable improvement in handling from 14.5% of elephants being managed using protected contact and positive reinforcement methods in the Harris et al. report (2008) to 79.2% (42/53) in 2019. ZEC believes that all elephants should be managed using protected contact and positive reinforcement training to ensure the use of the ankus and prolonged chaining of elephants is phased out as soon as possible, a view supported by the wider zoo industry (BIAZA and EAZA).

Faecal cortisol metabolites

The Report did not assess faecal cortisol metabolites and so this parameter cannot be assessed.

Overall welfare scores

These were not taken any further by the previous Zoos Forum Review of 2010 and therefore the EWG as they believed those produced by Harris et al (2008) did not contribute additionally beyond the other welfare assessments listed here.

Bull management

The Report shows improvement in social grouping and management of bulls with fewer bulls being housed separately and young bulls staying with their mothers for longer. ZEC is still concerned that young bulls are maturing, sexually, earlier than their wild counterparts necessitating their removal from female groups earlier than is desirable and views further research into the driving factors behind this earlier maturation to further improve bull welfare as essential. ZEC is also concerned that the management of adult bulls still relies on restricting their freedom of choice to available environment and appropriate social grouping for all or part of a 24-hour period, this is likely to be impacting negatively on their welfare.

Sustainability

The Report did not attempt to answer this question as elephants in the UK are managed as part of the wider European Association of Zoos and Aquaria (EAZA) ex situ programmes (EEP). EAZA has stated that the Asian elephant EEP is self-sustainable and the African elephant EEP is improving.

Summary Response to Question 1

In summary, the majority of ZEC feel that the welfare needs are being met for some UK elephants, as highlighted by the improvements in key welfare criteria above. Ongoing monitoring, using the welfare assessment tools developed by the EWG is critical to generate reliable long-term data sets focussed on individuals in relation to their particular needs. There are few data on the psychological well-being of the elephants, nor on enclosure use in relation to climate, and this should be addressed going forward.

Question 2

To what extent do you consider that the effective implementation of revised zoo elephant standards would address any shortcomings which may still exist in each of the key elephant welfare criterion?

ZEC believes that the new standards, Appendix 1.8 for elephants, will make a significant improvement on the welfare of elephants in captivity. The majority of consultees agree that they are a significant improvement and providing they are rigorously enforced with suitably qualified elephant inspectors (see Q4 and Summary point 3 below) will improve elephant welfare in captivity in the UK.

Some of the consultees question whether the revised elephant standards go far enough, particularly from a space requirement. ZEC however does acknowledge that the argument regarding enclosure complexity and usage is equally important to increasing space in improving welfare. The space increase to 20,000m2 in the new standards is significant based on the current requirements and carries a financial cost to the holding establishments but which ZEC believes is proportionate if it is used by the elephants (i.e. the increased space must be of sufficient interest to elephants and be readily accessible for most of the year).

Consultees made some suggestions as to how the elephant appendix could be further improved and these are being scrutinised by ZEC as they feed into the wider consultation on the new standards.

Question 3

What is your assessment of the scale, nature and impact of elephant-related conservation work that is currently being undertaken in those UK zoos that keep elephants?

All consultees including the EWG commented that this was not part of the Report and ZEC agrees that the EWG was not specifically tasked with this question. The total levels of elephant conservation contribution made by UK zoos is difficult to quantify currently as there is no specific requirement to record this, but it is believed to run to around £11.2 million for the period 2010-2022 with around 130 projects being identified (British and Irish Association of Zoos and Aquaria (BIAZA)). The links to conservation impact from this research can be difficult to identify.

ZEC also recognises the important impact of elephant conservation work being carried out by elephant keeping zoos including to name just two examples: work on elephant endotheliotropic herpesvirus prevention and treatment (which has been endorsed by the International Union for Conservation of Nature (IUCN) Species Survival Commission, and the United Nations environment programme goal A (target 4) of the post 2020 Global Biodiversity Framework); and development of human-elephant alert technology to reduce human-elephant conflicts via thermal camera imaging.

ZEC does expect that the impact of all conservation work will be better recorded assuming compliance with the proposed new zoo standards. ZEC does not believe that elephants should however be singled out above any other species held in zoos for special consideration from a conservation perspective.

Question 4

If elephant keeping continues, what approaches do you consider should be applied in order to ensure the effective implementation of zoo elephant standards in future?

ZEC considers that the EWG should continue beyond its 10-year remit and collect further data identified in question 1 to map the ongoing welfare of elephants in captivity in the UK. This data should be collected and managed in a way to allow potential independent scrutiny should it be required. We feel that data should be collected on indoor/outdoor enclosure usage across all seasons to better understand any variations. The EWG should report every two years to the Secretariat and ZEC who would assess whether further progress is being made or not. This view is supported by the majority of consultees.

ZEC considers it important to increase the number of expert elephant inspectors (there are currently only two) and to ensure they receive regular and suitable training so as to provide sufficient ongoing independent and rigorous assessment of elephant keeping in the UK. ZEC also recommends regular (6-12 month) meetings of the enlarged elephant inspectorate to enable regular comparisons to be made between elephant keeping zoos/institutions and that best practice is shared.

ZEC recommends that the standards require zoos to draw up an individual elephant welfare plan, and that this plan and evidence of its continuous implementation is made available to the proposed expanded elephant inspectorate for review on an annual basis rather than just at their periodical/full inspection.

ZEC agrees that the move to protected contact and the phasing out of the ankus must occur in all elephant keeping zoos/institutions as soon as is possible and no later than 2030 and because this will take time to plan and implement, a detailed plan and its expected schedule of implementation must be available to the elephant inspectorate by 31 December 2025 at the latest.

Question 5

If satisfactory standards for elephants cannot be met in some UK zoos, what is your view of the scope and capacity for transporting and rehoming the elephants in question to other places where conditions are satisfactory?

ZEC and the overwhelming majority of the consultees identified that significant welfare issues can accompany the movement of elephants and therefore a thorough plan and welfare assessment of any move must be undertaken by the zoo(s)/institutions involved prior to the move. Individual animal welfare needs must be taken in to account before any move occurred.

Moves of elephants to other zoos in the UK that comply with satisfactory standards, where this has to happen, is viewed by ZEC and the majority of consultees as the preferred choice. Standards of zoos outside the UK are difficult to assess, but many consultees viewed them as lower than those in the UK and viewed UK standards as some of the most rigorous world-wide.

Movement to sanctuaries was preferred by some, but the majority of consultees commented on the paucity of such organisations for elephants in Europe, one only being identified with a maximum capacity of three elephants. In addition, the sanctuary stance against breeding would lead to worsening social structures and this plus the lack of any independent regulatory control of these organisations in the view of ZEC makes this option currently not viable.

Relocation of elephants to the wild, whilst certainly possible, raises its own problems. These include: unsuitability of some elephants with pre-existing medical issues; identifying suitable release locations from a protection and food resource perspective; management of their welfare during transportation over long distances; amalgamating herds into stable structures from multiple captive sources and most importantly acclimatising animals previously born and raised in captivity in the UK to the wild which will require considerable post-release support and monitoring. Further considerations also include environmental challenges such as drought and human conflict including poaching. These factors mean that ZEC considers such an option not to be suitable for the majority of the UK elephant holders. If such an option is considered considerable planning and oversight by independent advisory experts is essential to ensure provisions for individual animal welfare is maintained.

Question 6

If the keeping of elephants were to be phased out in the UK, how would you recommend that this could be undertaken and implemented, and what key factors should be taken into account?

ZEC and the majority of the consultees feel at this stage there is not enough evidence presented in the Report to recommend the phasing out of elephant keeping in the UK. Points were raised by many that indeed phasing out meant clearly not breeding or importing elephants in the UK leading to worsening social structures and subsequent poorer welfare for those currently present. Those consultees who supported a phase out were in the minority but did so because they considered that the welfare and behavioural needs of elephants could never be met in captivity where the climate is considered so different to their natural habitat. ZEC and many consultees do however feel that any transfer of elephants to zoos/holdings outside of the UK raises questions of an ethical nature around the delegation of responsibility for these animals’ welfare to organisations outside of UK legislation, control and likely scrutiny.

If despite ZEC’s advice to the contrary, elephants were phased out and transferred to zoos outside of the UK, ZEC and the majority of consultees identified the possibility for other welfare problems to develop, associated with their transport and amalgamation into new herds. Any such move, in ZEC’s opinion, must require individual elephant welfare plans to be devised and the overall transfer of the UK herd would require an expert committee to oversee and manage. A mechanism to assess the ongoing welfare of the elephants moved outside of the UK would need to be devised.

ZEC recommends that to inform a decision regarding continuous keeping of elephants in captivity or phasing out that a process to debate the ethical complexities is devised.

Summary recommendations

ZEC recommends the following:

1. For the time being, and in line with the proposed new elephant standards, captive elephant keeping can continue in the UK, but must be kept under active review and must demonstrate continuous improvements in welfare.
2. The Elephant Working Group continues to collate information going forward and produces further reports at two-yearly intervals, on the welfare of elephants in captivity in the UK using the welfare tools they have already developed. Their findings, where improvement in welfare can be indicated, should be published and recommendations scrutinised and implemented where appropriate.
3. Further refinement of the welfare tool, particularly to assess psychological well-being and to gather more information on outdoor enclosure use in relation to climate.
4. Defra appoints and trains more elephant inspectors to allow regular and thorough scrutiny of the keeping of elephants in captivity in the UK
5. There needs to be evidence from all elephant keeping zoos/institutions that they have a credible plan to comply with the new zoo standards and significant changes outlined in Appendix 1.8 (Elephants) before their proposed enforcement date of 2030 and by no later than the 31 December 2025, which must be made available to the Defra appointed elephant inspectorate for assessment.
6. The development of an ethical review process relating to the keeping of elephants in captivity.

ZEC is also happy to draw up a more detailed suggested action plan for the Elephant Working Group should you feel this to be appropriate.

Yours sincerely on behalf of the Zoo Experts Committee,

Prof. Simon Girling BVMS(Hons) PhD DZooMed DipECZM(ZHM) EurProBiol CBiol FRSB FRCVS

Royal College of Veterinary Surgeons Recognised Specialist in Zoo & Wildlife Medicine

EBVS® European Veterinary Specialist in Zoo Health Management

Chair, Zoo Experts Committee

Appendix 1

List of written responses from people and organisations on the EWG 10 year report and questions posed by Rt Hon Lord Goldsmith

1. Rob Atkinson (Freelance elephant expert)
2. Katie Chapman, Darren Fellowes and Drew Mullin (Woburn Safari Park)
3. Ros Clubb (RSPCA)
4. Amos Courage and Tony King (Aspinall Foundation)
5. Gerry Creighton (Elephant management expert)
6. Otto Fad (N. American elephant welfare expert)
7. Simon Hedges (Zoological Society of London)
8. Mark Jones and Chris Lewis (Born Free)
9. Mike Jordan (Chester Zoo)
10. Jo Judge (CEO of the British and Irish Association of Zoos and Aquaria)
11. Thomas Kolpin (European Association of Zoos and Aquaria Elephant Taxon Advisory Group)
12. William Lindsay (Amboseli Trust for Elephants)
13. Nic Masters (Veterinary Surgeon and Previous Chair of EWG)
14. Fiona Sach (Zoological Society of London)
15. Miranda Stevenson (Current Chair of EWG)
16. Cerian Tatchley (Scientific Officer British and Irish Association of Zoos and Aquaria)
17. Olaf Toffels (European Elephant Group)
18. Ellen Williams (Harper Adams University)
19. Lisa Yon (EWG and Nottingham University)

Appendix 2

List of people and organisations interviewed by ZEC on the EWG 10 year report and questions posed by Rt Hon Lord Goldsmith

1. Katie Chapman, Drew Mullin and Darren Fellowes (Woburn Safari Park)
2. Ros Clubb (RSPCA)
3. Amos Courage (Aspinall Foundation)
4. Gerry Creighton (Elephant management expert)
5. Jo Judge (BIAZA)
6. Chris Lewis and Mark Jones (Born Free Foundation)
7. Fiona Sach (Zoological Society of London)
8. Lisa Yon and Miranda Stevenson (EWG)