The document is a formal comment letter submitted by the Council on Governmental Relations (COGR), an association representing nearly 200 U.S. research universities and related institutions, to the U.S. Department of Agriculture’s Animal and Plant Health Inspection Service (USDA APHIS) concerning a proposed rule on standards for birds not bred for use in research under the Animal Welfare Act (AWA). While COGR expresses support for establishing clear and humane standards for the care of such birds, it raises significant concerns about the blanket application of standards designed primarily for mammals in laboratory settings, arguing that birds—especially those used in research and teaching—require more flexible, species-specific regulations that recognize their diverse needs and the frequent use of naturalistic environments such as aviaries.
Throughout the letter, COGR provides detailed comments and recommendations on specific definitions and regulatory provisions, emphasizing areas where clarification or adjustments are needed to reduce administrative burdens and ensure practical compliance. Key areas include refining definitions related to bird breeding intent, dealer and exhibitor status, and the classification of exotic birds, as well as advocating for sufficient implementation timelines and more nuanced operational standards for field studies and record-keeping, especially to avoid unnecessary stress or disruption to birds. The organization also calls for harmonization between overlapping federal and state regulations, increased guidance and training from USDA APHIS, and responsive support for the regulated community. COGR concludes by reiterating its commitment to animal welfare and regulatory efficacy, while highlighting the importance of flexibility and clarity in rules affecting research institutions’ use of birds not bred specifically for research purposes.
