From: National Avian Welfare Alliance (NAWA)
Re: USDA Proposed Regulations: Animal Welfare; Regulations and Standards for Birds, Rats, and Mice
"As a result of a lawsuit by an Animal Rights organization, the USDA is now forced to regulate birds under the Animal Welfare Act (AWA), but the USDA has no prior experience at regulating birds under the AWA. To facilitate a coordinated effort at developing appropriate recommendations from the perspective of the avicultural community, the National Avian Welfare Alliance (NAWA) was formed with representatives from a broad cross-section of bird specialty groups including, bird trainers and avian veterinarians, as well as organizations for keepers of racing pigeons, waterfowl and pheasants, finches, softbills, and parrots. NAWA has completed most of these recommended regulations and is preparing to submit them to the USDA.
At the 2004 AFA Convention, USDA representatives indicated that in order for our side to be heard, we needed to get our members to make comments regarding the impact that AWA regulations would have on those of us involved in keeping and breeding birds. They urged each of us to get all of our members to respond.
The participants in NAWA would like to urge you to make comments to the USDA to provide them with information on the impact of covering birds under the AWA. These comments can be made by the internet or letters to the USDA. The original comment period has been extended and Comments must be submitted by
November 1, 2004. If we do not make these comments, the comments of the Animals Rights Activist side will be taken into consideration rather than ours. It is possible that all or most of us may be exempted from these regulations, if we get enough comments into the USDA showing the negative impact that AWA regulations would have on us.
NAWA has identified several key issues of concern. When making your comments, please emphasize some of these points:
The largest majority of us are Hobbyists for which bird breeding is not a money- making venture. Many facilities are lucky just to cover expenses and any added expenses under the AWA would force them out of raising birds.
Any inspections will have a detrimental effect on your ability to propagate any rare or endangered species because many rare or endangered species may kill their mates or abandon their nests while being inspected by a stranger.
The inspections are done in normal business hours and that most of us hold normal jobs that take us away at those times, so we would not be able to be present at the times we would be inspected or show our records to the inspectors.
The quantity of paperwork that is required under current AWA regulations (besides the paperwork you already may do for Fish and Wildlife and State Departments) is not possible for most bird keepers to maintain. It would require you to hire someone to keep up with the records alone. This represents and unreasonable burden on most and would force many to sell their birds due to the financial expense of hiring a bookkeeper.
The additional cost of keeping the birds to the current USDA requirements would be so costly that we could not afford to keep the birds we now have.
When people quit raising birds, the effect will be felt throughout our nation. The ripple effect of this taking place could cost the U.S. economy many hundreds of million of dollars and thousands of jobs as a result of greatly reduced demand for the wide variety of bird foods and bird-related equipment.
As the supply of domestic bred birds is decreased, the demand for smuggled birds will increase resulting in greater risk of the introduction of avian diseases such as Exotic Newcastles Disease and Avian Influenza.
Please take the time to make comments to the USDA and hopefully keep us from having AWA regulations put in place. If you have any questions, please do not hesitate to contact NAWA at: comments@nawabirds.org . Comments should be sent directly to the USDA per the following information.
Information you need to comment to the USDA:
The text form with the questions USDA is asking can be found on:
http://www.aphis.usda.gov/ppd/rad/webrepor.html Then click Animal Care
Then choose: Animal Welfare; Regulations and Standards for Birds, Rats, and Mice
Docket Number 98-106-4 Advance notice of proposed rulemaking and request for comments
9 CFR Parts 2 and 3 Published June 4, 2004 69 FR 31537
In order for the USDA to consider your written comments you
MUST submit them to the USDA by one of their approved methods:
By postal mail: Send your written letters as follows:
Postal Mail/Commercial Delivery: Please send four copies of your comment (an original and three copies) to: Docket No.98-106-4, Regulatory Analysis and Development, PPD, APHIS, Station
3C71, 4700 River Road Unit 118, Riverdale, MD 20737-1238. Please state that your comment refers to Docket No. 98-106-4.
By email:
Address your email comment to:
regulations@aphis.usda.gov.
Your comment must be contained in the body of your message; do not send attached files. Please include your name and address in your message and
``Docket No. 98-106-4'' on the subject line.
By commenting on the USDA comments website at:
http://frwebgate.access.gpo.gov/cgi-bin/leaving.cgi?from=leavingFR.html&log=linklog&to=http://comments.aphis.usda.gov.
According to the USDA, this webform is designed to allow commenters to associate each of their comments with the issues identified in the advance notice, and to allow APHIS to more easily analyze the comments
received regarding each issue.
(BUT please note that this website is not reliable, may take a long time to load, and is often unavailable. Do not rely on the website as your only method of commenting to the USDA).
Reading Room: You may read any comments that we receive on Docket No. 98-106-4 in our reading room. The reading room is located in room 1141 of the USDA South Building, 14th Street and Independence Avenue, SW., Washington, DC. Normal reading room hours are 8 am. to 4:30 p.m., Monday through Friday, except holidays. To be sure someone is there to help you, please call (202) 690-2817 before coming.
Other Information: You may view APHIS documents published in the Federal Register and related information, including the names of groups and individuals who have commented on APHIS dockets, on the Internet at
http://www.aphis.usda.gov/ppd/rad/webrepor.html .
Press Release:
http://www.aphis.usda.gov/lpa/news/2004/06/ac_birdratmice.html If you have any questions regarding bird regulation under the AWA, please contact NAWA at comments@nawabirds.org "
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