Over the past twelve years, Six Flags Great Adventure in Jackson has imported dozens of animals, from antelopes to tigers to zebras, sometimes through donation and sometimes through outright purchase, to support its popular safari.

But at least nine of those imports may have been illegal, according to federal communications and records, because the park operated without a valid Captive Bred Wildlife (CBW) permit.

A CBW permit is required for the interstate trade of exotic animals listed as endangered or threatened in the wild, and born in captivity in the United States, according to David Favre, who teaches animal law at Michigan State University. The permit, issued by the U.S. Fish and Wildlife Service under the Endangered Species Act, allows the park to specifically buy and sell African elephants, Siberian tigers and red lechwes, a type of antelope known for their long, spiraled horns, as long as the trade is done for the survival of the species.

Yet there appears to be a gaping hole in the park’s permit history: Federal records show no evidence of any CBW permit on file since 2007. The last permit on file for Six Flags expired in 2007, according to separate state records.

In a statement, the park denied violating any laws or regulations. Still, the park declined to provide a copy of its most recent CBW permit to NJ Advance Media.

“We are and have always been in full compliance with all federal laws and regulations as outlined by the U.S. Department of the Interior, U.S. Fish and Wildlife Service," said Kristin Fitzgerald, a spokeswoman for Six Flags Great Adventure. "Our CBW permit is up for renewal and the required paperwork has been submitted and is under review.”

Six Flags Great Adventure does maintain 14 other permits required to keep exotic animals at the park, including an animal exhibitor license from the U.S. Department of Agriculture and a zoological holding permit from the New Jersey Division of Fish and Wildlife, according to the park. (Though other Six Flags parks around the country exhibit animals, each maintains its own set of permits.)

Fitzgerald added that Six Flags Great Adventure was never told by the USFWS the permit was missing.

“We have supplied reports to the [USFWS] annually, as per the requirement for CBW holders,” Fitzgerald said. “We have never received written or verbal communication from the [USFWS] to indicate anything less than our full compliance with all federal laws and regulations.”

However, the USFWS disputed this characterization of the permitting process, saying that it is the permit holder’s responsibility to remain in compliance.

“Without a proper permit or authorization, it is illegal to take, transport, possess, or sell these species across state lines," said a USFWS spokesperson. "It is up to the permittee to ensure that they have the proper documents in place and are engaging in lawful activities at all times.”

The missing permit became an issue after the park submitted a renewal application for a CBW permit in March 2018. That renewal application is still pending, according to the U.S. Fish and Wildlife Service.

In an email from May 2018 obtained through a public records request by NJ Advance Media, USFWS official Michael Moore wrote that he believed the park has not had a valid permit at least since 2007. In the email Moore went to recommend that the park’s animal purchases be referred to law enforcement for investigation. Moore also expressed concern over animal welfare at Six Flags Great Adventure.

Six Flags did not respond to questions sent to them by NJ Advance Media about the animal welfare concerns raised by Moore.

Another USFWS official, Permit Biologist Kara Dziwulski, told Six Flags Great Adventure in a June 2018 email the park is "not authorized to conduct any activities (e.g. interstate commerce) requiring this permit until a new one has been established.”

Fitzgerald said Six Flags has refrained from all activities that require the CBW permit since starting the renewal process.

Calls and emails to Moore and Dziwulski seeking additional comment were not returned.

Since 2007, the park imported one Siberian tiger and eight red lechwes, according to reports filed by Six Flags with USFWS. These imports are what spurred Moore to recommend in his email that the USFWS permitting office notify law enforcement for possible violations of the federal Endangered Species Act.

During this period, Six Flags also imported an African elephant named Joyce, the subject of an NJ Advance Media special report published in June. However, Joyce’s import would not appear to be a violation, said Favre, since the CBW permit specifically relates to domestic-born animals. (Joyce was born in Africa in the early 1980s, and arrived at Six Flags Great Adventure in 2010.)

A violation of the Endangered Species Act could carry a maximum civil penalty of $49,467, according to an interim rule published by the USFWS in 2016. Each violation could also result in criminal penalties up to $50,000 and one year of prison time.

Both Six Flags and the USFWS declined to say whether the park is currently under investigation.

The animal rights group People for the Ethical Treatment of Animals (PETA) began ringing the alarm about the park’s permit in December, when the group called for a federal investigation of the amusement park.

“The Endangered Species Act exists to protect endangered animals from commercial exploitation, not to facilitate it,” Rachel Mathews, PETA’s Deputy Director of Captive Animal Law Enforcement, said at the time. “PETA is calling on the authorities to throw Six Flags’ permit request in the trash and investigate the park...."

In December, Six Flag Great Adventure disputed PETA’s assessment of its records, and stood by its animal treatment practices.

“Six Flags Great Adventure has been dedicated to animal preservation and education for more than 40 years, and our team of experienced caretakers is passionate about the health and wellbeing of our animals," Fitzgerald said in December. "We provide a safe and healthy environment for various animals that previously had received questionable care. Our goal is always to provide safe and healthy homes for animals in need whenever possible.”

At the heart of PETA’s complaints are transactions between Six Flags and facilities that have dubious animal treatment histories, including a facility in Ohio slammed for inhumane living conditions after a federal inspection; the Catoctin Wildlife Preserve and Zoo in Maryland, which has racked up dozens of USDA violations since 2006, according to the Humane Society; and a North Carolina facility that recently settled a federal complaint for $20,000, according to the Charlotte Observer.

In the email, Moore also said he was concerned about the number of deaths involving tigers and red lechwes at Six Flags Great Adventure. That concern is shared by PETA, which alleges the death rate of the park’s red lechwes is “extremely high.” According to reports filed by Six Flags with federal and state agencies, 15 red lechwes have died at the park since 2009. Causes of death for those animals have ranged from “general organ failure” to “trauma,” according to the reports.

In December, Fitzgerald said the park’s red lechwe herd was “doing well.”

“The red lechwe herd came to us in the 1990s, and their life expectancy is 10 to 15 years,” Fitzgerald said. “We discontinued breeding this particular herd in the early 2000s. Several additional red lechwe were introduced many years later to ensure we maintained a healthy population without inbreeding.”

Beyond the red lechwe herd, reports filed by Six Flags with federal and state agencies show the park has had six Siberian tiger deaths since 2012, with the cause of death ranging from neoplasia to uterine rupture. The most recent death was a female Siberian tiger in January 2018. Six Flags did not respond to additional questions about the welfare of the Siberian tigers.

In September, a 45-year-old female African elephant named Gloria died of congestive heart failure at the park. Gloria was one of the park’s original elephants and had lived at Six Flags since 1974.

Six Flags is required to report all imports, exports, births and deaths of African elephants, Siberian tigers and red lechwes to the USFWS. In addition, the park must report all changes to its animal inventory on a quarterly basis to state authorities. Six Flags appears to have consistently filed all of these reports.

Read the full email from U.S. Fish and Wildlife Service official Michael Moore regarding Six Flags Great Adventure:

Michael Sol Warren may be reached at mwarren@njadvancemedia.com. Follow him on Twitter @MSolDub. Find NJ.com on Facebook.