BILL ANALYSIS                                                                                                                                                                                                    

                                                                     SB 716

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          Date of Hearing:  July 14, 2015

                                   INTERNET MEDIA

                             Ian Charles Calderon, Chair

          716 (Lara) - As Amended May 5, 2015

          SENATE VOTE:  29-7

          SUBJECT:  Animal cruelty: elephants.

          SUMMARY:  Would make it a misdemeanor for any person who houses,  
          possesses, or is in direct contact with an elephant to use  
          specified devices designed to inflict pain for the purpose of  
          training or controlling the behavior of an elephant.  
          Specifically, this bill:  

          1)Declares that on or after January 1, 2018, it shall be a  
            misdemeanor for any person who houses, possesses, or is in  
            direct contact with an elephant to use a bullhook, ankus,  
            baseball bat, axe handle, pitchfork, or similar device  
            designed to inflict pain for the purpose of training or  
            controlling the behavior of an elephant. 

          2)Provides that prohibited behavior includes brandishing,  
            exhibiting, or displaying any of the devices, listed above, in  
            the presence of an elephant.


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          EXISTING LAW:   

          1)Declares that it is a misdemeanor for any owner or manager of  
            an elephant to engage in abusive behavior toward the elephant,  
            including the discipline of the elephant by any of the  
            following  methods:  

             a)   Deprivation of food, water, or rest. (Pen. Code,   
               596.5, subd. (a).)

             b)   Use of electricity. (Pen. Code,  596.5, subd. (b).)

             c)   Physical punishment resulting in damage, scarring, or  
               breakage of skin. (Pen. Code,  596.5, subd. (c).)

             d)   Insertion of any instrument into any bodily orifice.  
               (Pen. Code,  596.5, subd. (d).)

             e)   Use of martingales. (Pen. Code,  596.5, subd. (e).)

             f)   Use of block and tackle. (Pen. Code,  596.5, subd.  

          2)Provides that the actions of a person who maliciously and  


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            intentionally maims, mutilates, tortures, or wounds a living  
            animal, or maliciously and intentionally kills an animal as a  
            criminal offense. (Pen. Code,  597.)

          3)Specifies when a person overdrives, overloads, drives when  
            overloaded, overworks, tortures, torments, deprives of  
            necessary sustenance, drink, or shelter, cruelly beats,  
            mutilates, or cruelly kills any animal, or causes or procures  
            any animal to be so overdriven, overloaded, driven when  
            overloaded, overworked, tortured, tormented, deprived of  
            necessary sustenance, drink, shelter, or to be cruelly beaten,  
            mutilated, or cruelly killed; and whoever, having the charge  
            or custody of any animal, either as owner or otherwise,  
            subjects any animal to needless suffering, or inflicts  
            unnecessary cruelty upon the animal, or in any manner abuses  
            any animal, or fails to provide the animal with proper food,  
            drink, or shelter or protection from the weather, or who  
            drives, rides, or otherwise uses the animal when unfit for  
            labor as a criminal offense. (Pen. Code,  597, subd. (b).)

          4)Requires punishment as a felony by imprisonment pursuant to  
            subdivision (h) of Section 1170, or by a fine of not more than  
            twenty thousand dollars ($20,000), or by both that fine and  
            imprisonment, or alternatively, as a misdemeanor by  
            imprisonment in a county jail for not more than one year, or  
            by a fine of not more than twenty thousand dollars ($20,000),  
            or by both that fine and imprisonment for violations of Penal  
            Code section 597 (animal cruelty). (Pen. Code,  597, subd.  

          5)Requires that if a defendant is granted probation for a  
            conviction of animal cruelty, the court shall order the  
            defendant to pay for, and successfully complete, counseling,  
            as determined by the court, designed to evaluate and treat  
            behavior or conduct disorders. If the court finds that the  


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            defendant is financially unable to pay for that counseling,  
            the court may develop a sliding fee schedule based upon the  
            defendant's ability to pay. The counseling shall be in  
            addition to any other terms and conditions of probation,  
            including any term of imprisonment and any fine. If the court  
            does not order custody as a condition of probation for a  
            conviction under this section, the court shall specify on the  
            court record the reason or reasons for not ordering custody.  
            This does not apply to cases involving police dogs or horses  
            as described in Section 600. (Pen. Code,  597, subd. (h).)
          FISCAL EFFECT:  Unknown


          1)Author's statement of need for legislation: According to the  
            author, "SB 716 simply codifies industry standards for  
            elephant management by prohibiting the use of bullhooks, bats,  
            and pitchforks to discipline an elephant. A bullhook is  
            typically embedded into most sensitive areas of an elephant,  
            which involves areas around the ears, mouth, and back of the  
            legs. The use of this instrument also puts handlers at severe  
            risk, should an elephant decide to rebel against the trainer.  
            Since 1990, there have been at least 16 human deaths, and 135  
            injuries in the U.S. have been attributed to elephants. Simply  
            put, it is time for the State to prohibit this inhumane  


             a)   Existing state and federal law prohibits animal abuse,  
               and provides specific protections for elephants. As  
               mentioned in the "Existing Law" section above, California  
               law makes abuse of an animal a crime punishable under the  
               Penal Code. Further specific protections exist for  
               elephants, including (Pen. Code,  596.5, subd. (a).) which  
               provides, "It shall be a misdemeanor for any owner or  
               manager of an elephant to engage in abusive behavior toward  


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               the elephant, . . ." Id. The statute goes on to list  
               specific conduct which is included under "abusive  
               behavior," but does not limit the definition of abusive  
               behavior towards an elephant in any way. A "bull hook" or  
               "guide" used by an owner or manager to engage in abusive  
               behavior toward the elephant is already a crime under  
               existing law. Enforcement of these laws is done at the  
               local level by the local Animal Control Officer and local  
               law enforcement.

               In addition, federal law provides, under the Animal Welfare  
               Act (AWA), that zoos, circuses, transporters, roadside  
               menageries and exhibitors of elephants must be licensed and  
               participate in record-keeping and marking requirements.  
               Additional protections exist governing their care,  
               handling, and transport. The AWA gives power to the  
               Secretary of Agriculture and the United States Department  
               of Agriculture, whose power is further delegated to the  
               Animal Plant and Health Inspection Service (APHIS) to  
               administer and enforce the AWA's requirements. APHIS  
               enforces the Act through conducting inspections and  
               instituting rules and regulations for facilities. APHIS is  
               required to conduct yearly inspections and investigate  
               facilities whenever a complaint is filed.

               Unlike California law, the AWA does not prohibit any  
               particular instruments in the handling of elephants or  
               other warm blooded animals.

             b)   Two models for handling elephants: protected contact and  
               free contact. There are two models for elephant trainers  
               and caretakers to interact with elephants:  "protective  
               contact" and "free contact." In the protective contact  
               model, the trainer or caretaker only interacts with  
               elephants through a barrier or fence. In free contact the  
               trainer/caretaker shares a physical space with the  
               elephant. According to some experts, the bullhook/guide is  
               necessary for free contact training or management. Without  
               use of the "bull hook" or "guide," free contact is not a  


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               viable model for interacting with elephants. In order to  
               have a live performance involving an elephant, for  
               instance, free contact is necessary. A live performance  
               with elephants typically occurs in a circus, but can also  
               include use of elephants in films, events like county  
               fairs, or attractions such as theme parks and safari  
               experience parks.  

                  It should be noted that while California zoos accredited  
               by the Association of Zoos and Aquariums (AZA), along with  
               many other facilities housing elephants no longer use  
               bullhooks, the American Veterinary Medicine Association  
               (AVMA) policy does not prohibit the use of  
               guides/bullhooks, and many facilities nationwide have  
               contacted the committee to state that they incorporate  
               guides into their protected contact protocol.

                AVMA policy prohibits the use of guides in a manner which  
               inflicts harm on an elephant, but allows use of the guide  
               as a husbandry tool for elephant management.
               "The AVMA condemns the use of guides to puncture, lacerate,  
               strike or inflict harm upon an elephant. Elephant guides  
               are husbandry tools that consist of a shaft capped by one  
               straight and one curved end. The ends are blunt and  
               tapered, and are used to touch parts of the elephant's body  
               as a cue to elicit specific actions or behaviors, with the  
               handler exerting very little pressure. The ends should  
               contact, but should not tear or penetrate the skin."  
               (Elephant Guides and Tethers, AVMA.)  

               "Guides and tethers are used for training elephants in some  
               elephant management systems, and appropriate training is  
               important for facilitating veterinary care. However, guides  
               and tethers should only be used in a manner consistent with  
               the promotion of optimum welfare of the elephant. Personnel  
               using these devices should be trained adequately, as well  
               as introduced to alternative management systems." (Elephant  


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               Guides and Tethers, AVMA.)  

             c)   Elephants in the California entertainment and tourism  
               industries:  Impacted entities are two businesses where the  
               public interacts directly with elephants. As mentioned  
               above, all zoos and major sanctuaries in California have  
               moved to protected contact and have ceased use of the guide  
               tool. There are two remaining commercial organizations -  
               which have 10 elephants between them - that have direct  
               contact with elephants as their business model. Both claim  
               they need to use guide tools in order to provide their  
               services. The first is Have Trunk Will Travel, who provides  
               elephants for work in films, television, commercials,  
               traditional Indian weddings, as well as offering elephant  
               rides at fairs and theme parks. They are the exclusive  
               providers of elephants to the film industry and have worked  
               on projects such as George of the Jungle and Water for  
               Elephants. Their research and development of elephant  
               handling and medical care techniques are recognized  

               The second affected business is the Monterey Zoo, which  
               offers a safari style bed and breakfast experience, public  
               meet and greets with exotic animals and educational  
               experience and research facilities all inside an expansive  
               property outside of Salinas California. There are over 100  
               exotic animals onsite, with five elephants among them.  
               Education, public interaction with exotic animals and  
               research are all supported through a related non-profit as  
               well as the proceeds from their ranch. The facility's  
               animals are also stars of stage and screen, with their  
               lions and bears, parrots, squirrels, yaks and more  
               appearing in numerous television shows, commercials and  
               films. The Monterey Zoo is currently undergoing a $10  
               million dollar renovation and expansion of their facility. 

               The committee also heard from The American Humane  


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               Association, the film industry expert veterinary officers  
               who grant films with the "No Animal Was Harmed"  
               certification for films, who also use the guide tool in  
               their work with elephants.

               Conversely, PAWS wildlife sanctuary offers tours of their  
               facility with up-close-but-no-touch encounters with  
               elephants, known as "Seeing the elephant" tours. Visitors  
               are able to observe the elephant's habitat, special  
               handling techniques for bull elephants, and observe  
               positive reinforcement training to deal with medical  
               problems and foot care. Education and conservation are  
               combined with overnight options and vegetarian lunches.  
               These tours would not be impacted by passage of SB 716.

          3)Arguments in support: 

             a)   Use of the "guide" or "bull hook" is de facto  
               abuse. According to the sponsor, a "bullhook is a  
               steel-pointed rod resembling a fireplace poker that is  
               used to prod, hook, and strike elephants in order to  
               dominate and control them during training, performing,  
               and handling. The sharp tip and hook are applied with  
               varying degrees of pressure to sensitive spots on an  
               elephant's body, causing the elephant to recoil from  
               the source of pain. The handle is used as a club,  
               inflicting substantial pain by striking areas where  
               little tissue separates skin and bone. . . . Elephant  
               calves are forcibly separated from their mothers  
               (females elephants naturally remain with their mothers  
               for life) and taught to associate the bullhook with  
               pain and fear. While the elephant is typically  
               restrained, handlers repeatedly administer sharp jabs  
               and hooks with the bullhook, and strike sensitive  
               parts of their bodies with the handle or metal hook.  
               Thereafter, the elephant responds to the bullhook out  
               of fear of pain (moving away from the device) and will  
               be expected to perform a behavior on cue or suffer the  
               painful consequences. . . ."   


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               The president and co-founder of PAWS, which is a  
               co-sponsor of this bill, states in part, "Based on  
               firsthand observations, I have concluded that there is  
               no way to humanely use a bullhook - a weapon  
               resembling a fireplace poker, with a sharp metal point  
               and hook at the end - to train and manage elephants.  
               By its very design, the bullhook is meant to inflict  
               pain and instill fear. I have spent time around many  
               circuses and personally seen handlers forcefully hook,  
               jab and strike elephants with bullhooks on sensitive  
               parts of their bodies before and during performances,  
               and as a matter of routine handling. It was very  
               obvious by the elephants' responses that they both  
               anticipated and experienced pain."

             b)   The professional community of elephant handlers is  
               moving away from direct human contact with elephants, and  
               thus the instrument should be banned from use as outmoded. 
               The East Bay Zoological Society, which owns the Oakland  
               Zoo, supports this bill, explaining in part that it has  
               used the management style called "Protected Contact"  
               described in Comment 2 above since 1991. "The elephants and  
               staff do not share the same physical space, and the  
               elephants also have a choice of whether or not to  
               participate in training sessions. This management style  
               ensures not only the safety and care of our elephants, but  
               also our staff. According to the Humane Society of the  
               United States, "California zoos accredited by the  
               Association of Zoos and Aquariums (AZA) no longer use  
               bullhooks, nor does the Performing Animal Welfare Society's  
               sanctuary which is home to numerous rescued elephants. The  
               AZA now also urges all its member zoos to switch to a safer  
               and more humane elephant training system that does not  
               utilize the bullhook." (Emphasis in original).

          4)Arguments in opposition: 

             a)   Existing law is sufficiently protective of elephants.  


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               Numerous letters to the committee contain similar language  
               and content to the effect of the following: In addition to  
               state laws against animal abuse, and specific laws  
               protecting elephants, there are existing federal  
               regulations that strictly govern elephant care under the  
               Animal Welfare Act, that are overseen and revised  
               frequently by the U.S. Department of Agriculture, animal  
               and Plant Health Inspection Service (USDA/APHIS).  
               USDA/APHIS utilizes trained veterinary professionals who  
               are instructed specifically in animal/elephant care and  
               welfare to conduct regular inspections of all license  
               exhibitors of elephants (and other animals)."

             b)   The "guide" is a humane and irreplaceable aspect of  
               elephant handling in direct contact with humans, which many  
               vets and zoo keepers still need to use, in addition to use  
               with performing animals. According to the Elephant Managers  
               Association (EMA), who oppose this measure, "All animal  
               species are vastly different in their husbandry needs and  
               each species requires specialized equipment to ensure  
               proper care. Tools such as the elephant guide (or  
               bullhooks) are safe and productive components of elephant  
               care and training. Elephant tools are not intended to  
               injure or harm the animal and are proven and humane  
               husbandry tools that are widely utilized by knowledgeable  
               and experienced elephant care professionals in a variety of  
               settings. They also add an increased degree of safety for  
               the trainer, the animal, and the public."

               Additionally, they add, "The American Veterinary Medical  
               Association (AVMA) has gone on record supporting the use of  
               professional tools, including the guide, to manage  
               elephants." In particular, The EMA states, "All animal  
               species are able to be trained using "operant  
               conditioning."  This is a type of learning in which the  
               probability of a behavior recurring is increased or  
               decreased by the consequences that follow. This teaching  
               process includes both positive and negative reinforcement.  
               Operant conditioning is used in all forms of elephant care,  


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               and the process of training animals responsibly utilizes a  
               variety of science-based techniques which are critical to  
               providing proper welfare and husbandry. Utilizing an  
               elephant guide and employing positive reinforcement are  
               often part of the same overall operant conditioning  
               system." They relay a concern with reliance solely upon  
               protected contact, which depends upon the animal's choice  
               to cooperate, especially with baby elephants that are not  
               yet conditioned to approach their medical treatment area,  
               which is when elephants don't feel well; they won't come  
               into medical pens for treatment. Sadly, this has resulted  
               in more than one baby elephant's death from a treatable  
               condition, an EMA representative asserts.

             c)   Economic hardship: lost tourism and entertainment  
               dollars. The Western Fairs Association, states in  
               opposition, "Our organization has been monitoring  
               proposed legislation regarding guides for several  
               years. Groups including the Elephant Manager's  
               Association, the Zoological Association of America,  
               the Association of Zoos and Aquariums, the  
               International Elephant Foundation Elephant Husbandry  
               Resource Guide, and the American Veterinary Medical  
               Association all recognize the guide as a husbandry  
               tool to aid in caring of elephants and have policies  
               in place for its use. ?We see the efforts to ban the  
               guide -- effectively shutting down elephant exhibits  
               and rides at fairs -- as the beginning of a slippery  
               slope that has serious implications for all fairs." 
               The Salinas Valley Chamber of Commerce adds in  
               opposition, "The Monterey Zoo is an important tourist  
               attraction in our area and elephants are the flagship  
               of their new facility. Should the proposed legislation  
               in SB 716 be enacted, it would create severe barriers  
               to the success of this responsible 501(3) non-profit  
               organization that provides so much to our community."
             d)   Request for amendments: assignment of responsible  
               oversight agency to existing California Fish and Wildlife  
               Committee on "restricted species held by exhibitors," and  


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               one year extension of delayed implementation. Concern has  
               been raised that if SB 716 were to become law and use of  
               the bullhook/ankus is outlawed; there is not sufficient  
               guidance in the measure to direct development of an  
                                                                          alternative tool and approve adoption for use. For  
               instance, if a tool is created that is similar in design,  
               but without barbs or points at the tips (imagine something  
               more like a cane than a fire poker), that implement would  
               seem to comply with the intention of the bill to be a tool  
               for "training or controlling the behavior of an elephant"  
               which is not "designed to inflict pain." Who will be the  
               agency authorized to make that determination? As mentioned  
               above, the enforcement of animal abuse laws falls upon the  
               local Animal Control and law enforcement; that disbursement  
               of authority would make uniform compliance and adoption of  
               accepted tools of husbandry difficult to achieve.

               In order to address this situation, the Monterey Zoo and  
               Have Trunk Will Travel urge the adoption of amendments to  
               refer the implementation and adoption of any new husbandry  
               tool to the Department of Fish and Wildlife. In support of  
               this concept, they share the following:

               "Specifics on animal husbandry and care as well as tools  
               used in animal care for species requiring permits in  
               California are regulated by section 671 of title 14 of the  
               California Code of Regulations. Section 671 of Title 14 of  
               the California Code of Regulations contains all of the  
               specifics on the care and housing of restricted species  
               held by licensed exhibitors, including husbandry tools. Per  
               Section 671, the California Fish and Wildlife Commission  
               has an appointed committee that is required to meet on a  
               scheduled basis to address such issues as addressed in SB  
               716, and submit recommendations to the Director of Fish and  
               Wildlife. After the Committee votes on such issues and  
               presents their report to the Director, he then may present  
               his recommendation to the Fish and Wildlife Commission,  
               where the law may be modified."


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               "The Director of Fish and Wildlife's Advisory Committee is  
               composed of representatives of Human Society of the United  
               States, PAWS, Monterey Zoo, Have Trunk Will Travel, UC  
               Davis, laboratories, education facilities, several other  
               animal rights representatives, and animal experts as well  
               as representatives from Fish and Game legal, enforcement  
               and licensing departments. This Committee needs to have the  
               opportunity to debate this issue and possibly come to  
               middle ground on an acceptable means of developing and  
               using the guide tool. The use of the guide tool (bullhook)  
               should go through this proper channel where individuals  
               with actual and specific professional experience with these  
               matters can apply both science and experience to their  

               In addition to the amendment to refer the enforcement and  
               oversight of the issue to Fish and Wildlife, Monterey Zoo  
               and Have Trunk Will Travel also request an extension of the  
               date of implementation, to January 1, 2020, in order to  
               allow sufficient time for the administrative process to  
               determine an acceptable husbandry tool, and the affected  
               entities proper time to retrain their staff and elephants  
               to its proper use.

          5)Committee comments:

             a)   Definitions: Is a "Guide" by any other name still covered  
               by SB 716? The opposing sides of this legislation use  
               differing terminology to refer to the same tool of elephant  
               husbandry, supporters often referring to "bull hooks" or  
               sometimes "ankus", while opponents refer to a "guide." As  
               defined in, Literature Review on the Welfare Implications of  
               Elephant Training, (April 2008), the guide is a shaft with a  
               tapered metal hook attached, and it sometimes has a blunt  
               metal point at the end. It is also sometime referred to as  
               the ankus, (bull)hook, or goad. The guide extends a  
               handler's reach so s/he may touch, push, or pull various  
               parts of the elephant's body. A guide is used in all free  


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               contact programs in the United States, and may also be used  
               in conjunction with protected contact.  

                This legislation prohibits the use of a bullhook, ankus,  
               baseball bat, axe handle, pitchfork, or similar device  
               designed to inflict pain? The bill does not include "guide"  
               in its list of prohibited husbandry devices. Many opponents  
               of this legislation believe that the use of a guide, when  
               done properly, is not painful to the animal. They further  
               argue that it is not intended to be painful, but rather  
               mimic the physical interplay of tugging and prodding common  
               in elephants. Additionally, earlier versions of this measure  
               contained reference to the word "guide", but it was amended  
               out. Therefore, there is some ambiguity as to whether use of  
               the "guide" would be prohibited by this bill. The author may  
               wish to clarify this by expressly including reference to  
               guides and adding a definition.

             b)   Conflict within scope of covered persons within PC 596.5  
               (a) and (b). This bill amends an existing section of the  
               Penal Code, 596.5 which contains prohibited devices and  
               abusive acts directed at elephants done by "any owner or  
               manager of an elephant" and as of January 1, 2018 the new  
               subsection (b) will prohibit use, including brandishing,  
               exhibiting, or displaying or enumerated additional  
               prohibited devices (bullhook, ankus, pitch fork, etc?), by  
               "any person who houses, possesses, or is in direct contact  
               with an elephant."  The committee wishes to point out that a  
               conflict in the scope exists between these two sections,  
               with the latter being substantially more broad than the  
               existing law (which will remain in force). The author may  
               wish to amend subsection (a) to also address abusive acts by  
               any person who houses, possesses, or is in direct contact  
               with an elephant, in order to provide consistency within the  
          6)Prior Legislation:  


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             a)   AB 777 (Levine), of 2007-2008, would have prohibited  
               specified   conduct in relation to housing, possessing,  
               contacting, or traveling with an elephant. AB 777 was held  
               in the Assembly Public Safety Committee

             b)   AB 3027 (Levine), of 2005-2006, would have prevented the  
               use an Ankus, bullhook, or similar device on an elephant.  
               Would have prevented the use of any chain that is used to  
               restrain an elephant, except if utilized for the shortest  
               amount of time necessary to provide actual medical  
               treatment. AB 3027 was held in the Assembly Appropriations  

             c)  AB 1000 (Horcher), of 1995-96, would have prohibited the  
               chaining of elephants in their permanent facility unless  
               the chaining was for training purposes limited to two hours  
               per a day or veterinary care. AB 1000 failed passage in the  
               Assembly Committee on Public Safety.




          Organizations (CA)


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          Active Environment
          American Society for the Prevention of the Cruelty to Animals
          Animal Film Festival
          Animal Legal Defense Fund
          City and County of San Francisco, Board of Supervisors
          City of Los Angeles
          City of Oakland
          Elephant Voices
          Global Sanctuary for Elephants
          Humane Society Veterinary Medical Association
          In Defense of Animals
          International Marine Mammal Project
          Laborer's International Union of North America, Local 777 & 792
          Last Chance for Animals
          Lions, Tigers and Bears
          March for Elephants
          Oakland Zoo
          Performing Animal Welfare Society
          Sacramento SPCA
          San Diego Humane Society
          San Francisco SPCA 
          Santa Clara County Activists for Animals
          Sierra Wildlife Coalition
          Society for the Prevention of Cruelty to Animals Los Angeles
          State Humane Association of California
          The Elephant Sanctuary
          The Fund for Animals
          The Global March for Elephants and Rhinos
          The League of Humane Voters, California Chapter
          The Marin Humane Society

          Organizations (Out of State)
          Action for Animals
          Best Friends Animal Society
          Detroit Zoological Society
          Elephant Trust
          Global Sanctuary for Elephants
          Humane Society Veterinary Medical Association
          The Elephant Sanctuary in Tennessee


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          The Humane Society of the United States
          Uganda Carnivore Program

          8 California residents

          12 Out of state individuals


          Organizations (CA)
          American Humane Association Hollywood
          Animal Actors of Hollywood
          California Fairs Alliance
          Circus Fans Association of America
          Face in the Crowd Casting
          Farm Bureau Monterey
          Gentle Jungle, Inc.
          Have Trunk Will Travel
          Los Angeles Foundation for the Circus Arts
          Monterey Zoo
          No Animals Were Harmed program
          Pacific Animal Productions
          Salinas Valley Chamber of Commerce
          Silver Screen Animal, Inc.
          Western Fairs Association
          Wild Wonders, Inc.
          Worldwide Movie Animals

          Organizations (Out of State)
          Asian Elephant Support
          Columbus Zoo and Aquarium (Jack Hanna)
          Feld Entertainment Inc.


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          International Elephant Foundation.Org
          National Animal Interest Alliance
          Outdoor Amusement Business Association
          United States Zoological Association
          Zoological Association of America

          75 California residents

          43 Out of state individuals

          Analysis Prepared by:Dana Mitchell / A.,E.,S.,T., & I.M. / (916)