The Association of American Universities (AAU) and the Council on Governmental Relations (COGR), representing leading research universities and institutes, submitted a joint response opposing a petition received by the USDA requesting the development of specific "ethologically appropriate" standards for the care of nonhuman primates in research facilities. The petition seeks amendments to existing Animal Welfare Act (AWA) regulations to mandate more explicit environmental requirements based on natural primate behaviors. AAU and COGR argue that current regulations, which require institutions to promote the psychological well-being of primates in line with professional standards and under veterinary supervision, are both effective and sufficient. They cite recent data indicating robust social housing practices and emphasize the continuous improvements already made by the research community.
Both organizations contend that the proposed changes are unnecessary, lack evidentiary support, and would impose undue burdens on research facilities without improving animal welfare outcomes. They further maintain that existing standards are uniformly applicable across research, exhibition, and dealer environments, and that oversight by attending veterinarians and institutional committees is sufficient to ensure compliance and animal well-being. AAU and COGR caution that the suggested regulatory changes could impede vital primate research and are motivated more by anti-research advocacy than by scientific or welfare considerations. Consequently, they strongly recommend that the USDA reject the petition and refrain from initiating related rulemaking.