Comment Letter

FINAL_COGR_AAU_Comments_Reporting Requirements_USDA_August 2015

The Association of American Universities (AAU) and the Council on Governmental Relations (COGR), representing major research universities and affiliated institutes, submitted joint comments to the USDA regarding a petition from the National Anti-Vivisection Society (NAVS). This petition requested amendments to the Animal Welfare Act reporting regulations, specifically to require research facilities to provide more detailed information about the number and specific uses of animals in research, testing, and education, with such data to be published by APHIS in its annual report.

AAU and COGR strongly opposed the petition, aligning their position with that of the National Association for Biomedical Research (NABR). They argued that the requested changes exceed USDA’s statutory authority, would increase administrative burdens and costs for research institutions, and could subject researchers to increased targeting by special interest groups. The associations contended that the additional information would not enhance animal welfare, as current oversight processes and reporting requirements are sufficient to ensure humane treatment of animals in research. They maintained that further reporting would not serve the public interest but rather hinder research by discouraging essential animal studies, ultimately impeding scientific progress. The letter concluded by recommending that USDA take no action on the petition, emphasizing that existing regulations already provide necessary safeguards and that the proposed changes are part of a broader pattern by advocacy groups aiming to restrict or terminate animal research.