Who Are the USDA Class C Exhibitors?

November 2, 2017 - Rachel Garner

The group of entities in the United States that hold United States Department of Agriculture (USDA) animal exhibition licenses (Class C) are a far more diverse group of individuals and businesses than most even within animal exhibition-related industries realize. The number of Class C licensees is often conflated with the number of zoos in the United States, a mistake that appears to stem from a National Geographic article from 2003. If legislative and regulatory changes are promulgated on an incomplete understanding of the wide range of animal exhibition-related businesses that exist in the country today, this seemingly minor error could have far-reaching consequences. As no easily accessible information about the distribution of business types of USDA Class C licensees appeared to be extant as of 2017, it seemed pertinent to pull the most recent USDA Animal and Plant Health Inspection Service (APHIS) records and break them down. 

Who Needs a Class C License?

USDA requires "individuals and businesses who exhibit [warmblooded] animals to the public for compensation (e.g., prizes, stipends, products, or publicity that directly benefits that person’s business, including donations)," or that are "on display, [performing] for the public, or are used in educational presentations," to be licensed as exhibitors. Individuals or businesses who "exhibit only farm animals in agricultural events" do not require a license; "animal preserves, or sanctuaries that maintain exotic or wild animals, are also exempt from regulation provided they do not exhibit or use the animals for promotional purposes, including fundraising, or sell animals"; as are "exhibitors showing only coldblooded animals, such as fish and reptiles." (USDA APHIS Animal Exhibitor Fact Sheet)

Methodology

The project to quantify the different types of businesses with Class C licenses was completed using two sets of data: one set of license information collected in December 2015 from the ACIS search tool, and the second set exported in August 2017 from a list of all current licensees uploaded to the USDA APHIS website. As of the 2017 data, there were 2416 active Class C licenses. Exhibitors categorized as active for the purposes of this work were cross-referenced between both sets of data in a master list - businesses that showed as active in 2015 but not in 2017 were not counted.

Licensees were classified in two different ways: by their main purpose, and by why they maintained an exhibition license. Business purpose was a binary category: did the business exist primarily for the purpose of exhibiting animals, or for another reason? (An "unknown" category was also created for licensees who were not businesses or had no information publicly available that would allow for categorization.) 21 distinct categories were created for the reasons a licensee maintained their Class C license - each category is itself broad and could be further subdivided for a future study. (An "unknown" category was also created for licensees whose reason for having a license could not be determined.) The categories were defined as such: 

• Agribusiness: A working animal-based farm with a public exhibition component

• Alternate Mission Nonprofit: A nonprofit organization for which animal-related causes are not the primary mission but for which animal exhibition is a component

• Amusement Park: An amusement park that includes an animal exhibition component

• Animal Shelter: A domestic animal shelter with a small resident collection

• Attraction: An entity that exists for entertainment and tourism purposes but has an animal exhibition component

• Breeder: A business that exists for the purpose of animal breeding that also maintains an exhibition license

• Camp/Resort: A vacation- or camp-style facility whose guest activities require them to maintain an exhibition license

• Conservation Breeder: A business that breeds animals specifically for conservation programs that maintains an exhibition license for commercial support of the program

• Educational Institution: A university or other place of learning with an animal collection for the purposes of student teaching and/or research, that also maintains an exhibition license to make it available to the public

• Entertainment/Outreach (animal-reliant): A business that facilitates animal-based entertainment, education, or outreach programs held away from where the animals reside (e.g., birthday parties with animal presentations)

• Entertainment/Outreach (not animal-reliant): A business that does not exist for the purposes of animal exhibition that maintains an exhibition permit in order to include animals in their programming (e.g., magicians)

• Museum: A permanent education facility that includes an on-site animal collection for exhibition and education programs

• Nature Center: A facility specifically dedicated to educating the public about local ecosystems and wildlife that includes an on-site animal collection

• Rescue/Rehabilitation: A wildlife rescue and rehabilitation facility that offers tours and on-site education programs with unreleasable animals

• Production Work: A company that uses their animal collection in the pursuit of artistic projects (e.g., movies, theater, photography)

• Park: A non-business area set aside for recreation with an on-site animal component

• Petting Zoo: A facility that allows the public to interact directly with domestic, farm, and small exotic animals on-site

• Retail Services: A business where animal exhibition is a supporting factor of primary business objectives (e.g., steak house, pet supply store, bed-and-breakfast)

• Sanctuary (exhibiting): A nonprofit business that provides a stationary collection of rescue animals with a permanent home and maintains an exhibition license to allow the public to visit the site

• Sanctuary (non-exhibiting): A nonprofit business that provides a stationary collection of rescue animals with a permanent home and maintains an exhibition license in order to allow for commercial support of the facility

• Zoological Facility: A business that maintains a stationary collection of exotic animals for the primary purpose of public exhibition

For example, a working farm would be classified as "not existing for animal exhibition" and maintaining their Class C license for their "agribusiness tour;" a domestic animal circus would be classified as "existing for the purpose of animal exhibition" and maintaining their Class C license for the touring circus. 

Findings

As the purpose of this project was to provide a representative overview of the distribution of Class C licensees, the breakdown of types of exhibitors below is presented in approximate percentages. The specific number of entities under USDA regulation is constantly in flux, so these percentages are not static - it is to be expected that Class C licensee numbers obtained from USDA for future projects will fit the same pattern but have slightly different numerical results. 

Primary Business Purpose of Class C Licensees:

Businesses that existed for the purpose of animal exhibition were the largest group (48.6%) of Class C license holders, and businesses that existed for non-exhibition primary purposes were the majority of the rest of the license holders (38.6%). A small fraction (12%) of the licensees - generally those who had the license in the name of an individual, rather than a business - did not have enough information available from which to discern a primary purpose. 

Distribution of Businesses with Class C Licenses:

317 (13%) of the 2416 Class C licenses did not have enough business information online to allow for classification (these were mainly licenses held in the name of an individual, rather than a business entity). The remaining 2099 USDA licensees were categorized into 21 distinct categories of businesses types. Five of these categories made up a majority of the extant Class C licensees, and eight categories each comprised less than 1% of the total licensees. The rest of the categories each represented between 1% and 4% of the total active licenses. 

While it is a common misconception that all animal exhibitors who hold a Class C license are zoos, it turns out that as of August 2017 zoological facilities comprise less than a fifth (19%) of the 2416 entities with active Class C licenses. Together with businesses that do off-site entertainment and outreach programs and agribusinesses, these three categories represent slightly under half (47%) of all animal exhibitors in the country. While the other categories of entities maintaining Class C licenses are each a much smaller fraction of the total active licenses, an understanding of the diversity these distinct types of businesses represent is necessary for anyone involved in the legislative or regulatory aspects of animal exhibition in the United States. 

Read More Articles from Why Animals Do The Thing:

RACHEL GARNER

Rachel is an educator and animal science writer. With prior professional experience in zookeeping, visitor education, shelter behavior management, and more, she works to translate pertinent field-specific knowledge into comprehensive explanations about current animal related topics.