WSPA Canada’s audit of Ontario zoos is getting a lot of attention, but a closer look needs to be paid to the details. Overall, the idea of the audit — evaluating the captive care of animals in several private zoos in Ontario — is a good idea, and their observations are worth noting, but it’s important not to give the report more significance than it deserves.

The report only covers 13 private zoos, plus three CAZA-accredited zoos, and it only looks at a few mammalian species (primates, ungulates, wolves, bears, and great cats); it’s by no means comprehensive. The standards by which the zoos were evaluated were not external, but set by WSPA Canada, and were exacting enough that even the Toronto Zoo’s grizzly bear exhibit failed. (There’s a difference between failing an easy exam and failing a hard one: the number of outright failures is augmented by the marginal cases.) And they’re by no means disinterested evaluators. WSPA Canada is an animal rights group, and they do have an agenda: it’s a part of their campaign against roadside zoos.

Among their recommendations (pages 71-72 of the PDF, 9.2 MB) is the regulation of exotic animal ownership in Ontario — whether privately or in a zoo. They want standards, inspections, and formal training: fine for zoos, problematic for private citizens (more on that in a moment). But from my quick glance at the report, I can’t see how that conclusion follows from their observations, especially since their study was limited to medium-sized to large mammals in zoos, rather than all exotics in all captive scenarios. I think there’s a missing step, there.

As a reptile keeper, my concern is that their understanding of exotic animal ownership is based on large mammals, but that they would apply those mammal-based norms, willy-nilly, to all exotics, including birds, reptiles and fish, regardless of difficulty of care. It’s one thing to argue that tiger or kangaroo ownership should be regulated, quite another to say that every time you buy a cichlid, cockatiel, crested gecko or corn snake, you have to ask the provincial government’s permission, get formal accreditation, and meet professional standards of care.

Regulating zoos is by no means a bad idea, but it’s important to focus on outcomes rather than processes. Regulatory regimes are a pain in the ass to conform to; if they’re largely unenforced (think government understaffing), they’ll be ignored. (Lack of enforcement of wildife conservation laws, applicable to native species, was one issue of concern in the report.) The ostensible point is to improve the care of captive animals in zoos; I’m largely indifferent to how that’s done, whether through moral suasion via public attention, self-regulation through professionalization, or regulation.

But regulatory regimes, being, as I said, a pain in the ass to conform to, also have the benefit of discouraging participation in the regulated activity, if they’re onerous enough: not only would several zoos be shut down (not necessarily a bad thing), but the wind would be knocked out of the exotic animal hobby, particularly if the regulations apply to private individuals. I wonder if that’s exactly what WSPA Canada has in mind: to stop, rather than to improve.