USDA is seeking public comments about their Rule Promulgation to Amend the Animal Welfare Act (AWA) to include birds not bred for use in Research.
Below are examples of appropriate comments from aviculture experts to oppose USDA's Proposed Rule.
Please use the comments below as a guide and manage these suggested comments to make them your own and respond directly at the USDA portal by May 25, 2022 (link below)
Background and General Information:
While the USDA/APHIS does have experience with birds and other animals raised for food and other other products, USDA/APHIS has no experience with avian species (birds) in an avicultural setting, where aviculture is the breeding, raising, and keeping of birds..
This addition to the Animal Welfare Act (AWA) will create a huge amount of conflict and divisiveness between animal owners and APHIS staff.
The incredibly diverse spectrum of 10,000 species of birds puts APHIS at a disadvantage, making uniform standards that would apply to all impossible. Each species has different breeding, nesting, feeding requirements, where specific needs for various species must be addressed and individuals within species may have specific requirements depending on age, gender, reproductive status and health, and general standards may not be possible to apply to all.
Knowing these facts, one must question this Rule Promulgation as it will put all domestically owned birds at great risk.
With regard to the term "stakeholder:"
A.1. Definition of stakeholder: someone with a STAKE in the matter.
A.2. Who are the primary stakeholders here?
a. Aviculturists who are keeping and breeding birds.
b. Zoos who are keeping and breeding birds.
A.3. Who are the secondary stakeholders here?
a. Owners of pet birds.
b. Avian veterinarians.
c. Companies that produce food and equipment related to birds.
d. Transporters of birds, supplies, food, equipment, etc.
A.4. Who are the tertiary stakeholders here?
a. Members of the general public
b. Members of Animal rights organizations are individuals who do not own birds, do not support aviculture, have no knowledge of the practices of aviculturists, but want to TELL bird breeders how to care for their birds. These individuals should have NO INPUT INTO ANY FEDERAL REGULATIONS BECAUSE THEY ARE NOT ACTUAL STAKEHOLDERS. THEIR GOAL IS TO DESTROY AVICULTURE IN THE U.S., BASICALLY TO REMOVE BIRDS FROM HUMAN CONTACT.
Comment Examples for you to use as a guide in submitting our opposition comments in the USDA Comment Portal by May 25th, 2022