Giving you one more chance: USDA-APHIS says speak now or hold the pieces

(Beth Clifton photo collage)

Feds want your input on Animal Welfare Act enforcement & much, much more; comment period extended another 30 days

WASHINGTON D.C.––”In response to requests, stakeholders will have an additional 30 days to share their thoughts on the United States Department of Agriculture’s (USDA) Animal & Plant Health Inspection Service (APHIS) strategic plan to guide the agency’s work over the next five years,” USDA-APHIS spokesperson Sharla M. Jennings on June 30, 2022 emailed to interested parties and media at the crack of dawn.

The USDA Animal & Plant Health Inspection Service is the government agency responsible for enforcing the U.S. federal Animal Welfare Act. The Animal Welfare Act regulates the care and housing of animals in laboratories, the exhibition industry including zoos, circuses, and sanctuaries open to the public.

The USDA Animal & Plant Health Inspection Service also enforces the Horse Protection Act, governing inspection of show horses.

USDA Wildlife Services, the federal exterminating agency, is also part of the USDA Animal & Plant Health Inspection Service.

(Beth Clifton collage)

Deadline is July 31, 2022

“Comments must be received by July 31, 2022,” Jennings said. “APHIS appreciates insights from all stakeholders. We expect to finalize and publish the new strategic plan this fall and will post it on the APHIS website.”

“The strategic plan framework,” Jennings explained, “is a summarized version of the draft plan and provides highlights including the mission and vision statements, core values, strategic goals and objectives, and trends or signals of change we expect to influence the agency’s work in the future.

“Specifically, ” Jennings said, “we are seeking insight on the following questions:

Are your interests represented in the plan?
Are there opportunities for APHIS to partner with others to achieve the goals and objectives?
Are there other trends for which the agency should be preparing?
Are there additional items APHIS should consider for the plan?

“To review the strategic plan framework and provide your insights,” Jennings finished, “please visit:

https://www.regulations.gov/docket/APHIS-2022-0035

For further details, please see below.

To see the comments ANIMALS 24-7 submitted on June 4, 2022, when the comment period first opened, please go to USDA-APHIS wants your 2¢ on animal-related federal law enforcement––NOW!!!, and scroll to the subhead “This is the ANIMALS 24-7 two cents’ worth.”

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(Beth Clifton collage)

“Come on, animal advocates, let’s move fast! Your big chance has come at last! Want a chance to have your say? Tell it to the USDA!”

WASHINGTON D.C.––The USDA Animal & Plant Health Inspection Service [APHIS] is, until the end of July 2022, offering the public a unique chance to kibbitz on an “APHIS Strategic Plan Framework” meant to guide the agency for the next five years.

APHIS is the agency which, among other duties, enforces the Animal Welfare Act and the Horse Protection Act. This includes inspecting laboratories, horse shows, zoos, and other animal exhibition facilities.

APHIS is also the agency housing Wildlife Services, the government exterminating company, whose duties focus on killing animals for the benefit of farmers, ranchers, and other public agencies, and on keeping birds out of aircraft engines.

(Beth Clifton collage)

Read all about it!

ANIMALS 24-7 has already submitted an extensive comment on the “APHIS Strategic Plan Framework,” appended, and urges all U.S. readers and U.S.-based animal advocacy organizations to add their own two cents’ worth. The opportunity to have a direct say in broad-reaching animal-related public policy is rarely as accessible.

But read the “APHIS Strategic Plan Framework” first, available as a download here: https://www.regulations.gov/document/APHIS-2022-0035-0001

Many early commenters have expressed opinions that go beyond the scope of the “APHIS Strategic Plan Framework,” and would require Congress to amend the legislation that APHIS exists to implement. What the “APHIS Strategic Plan Framework” is about is what APHIS can do by itself.

(Beth Clifton photo)

Mission statement & core values

The “APHIS Strategic Plan Framework” includes some provisions of possible benefit to animals, including a mention of preparing for a possible role in overseeing animal welfare in agriculture, not yet provided for in law, but anticipated on the distant political horizon.

The “APHIS Strategic Plan Framework” takes note of “the rise of globalization, advances in technology, climate change, and evolving production practices.”

It begins with “a new mission statement and vision statement, core values, and strategic goals and objectives.”

The new mission statement is simply, “Protecting the health, welfare, and value of our nation’s plants, animals, and natural resources.

The vision statement essentially restates the same concept.

The “core values” include no mention of animals.

Tom Regan in childhood. (See Tom Regan, 78, made the case for animal rights.)
(Beth Clifton collage)

APHIS is hiring

The substance of the “APHIS Strategic Plan Framework” comes under “Strategic Goals and Objectives.”

Rebuilding the depleted APHIS staff is Goal 1. APHIS has not been fully staffed in 30 years, and the experienced staff still at APHIS is rapidly aging out.

“Of the estimated 2.2 million federal employees,” the “APHIS Strategic Plan Framework” says, “43% are age 50 or older. For APHIS, the percentage of employees in this age bracket is even higher, at 46%. Over the next five years, APHIS will focus on recruiting new talent to ensure the agency’s institutional knowledge is maintained as older workers leave the workforce.”

Note to younger animal advocates with useful skills: APHIS is hiring in practically all departments. But leave your slogan t-shirts home and be aware that enforcing the rules requires working within them.

(Beth Clifton collage)

Zoonotic disease control offers huge chance to reduce animal suffering

APHIS Goal 2 is to “Deliver science‐based solutions that reduce the impacts of zoonotic and emerging diseases and ecosystem changes.

“Seventy‐five percent of emerging infectious diseases found in humans are zoonotic, meaning they impact the health of both humans and animals,” the “APHIS Strategic Plan Framework” stipulates.

“There has been a surge of outbreak cases by these diseases over the past two decades,” the “APHIS Strategic Plan Framework” acknowledges. “Early detection and response to zoonotic and emerging diseases is essential in limiting or preventing human outbreaks.

“APHIS will strengthen its ability to prevent, detect, report, and respond to emerging and zoonotic diseases,” the “APHIS Strategic Plan Framework” pledges.

Few if any government jobs offer more opportunity to reduce animal suffering than zoonotic disease control and prevention.

(Beth Clifton collage)

Opportunities supervising labs & agribusiness

APHIS Goal 3 is to “Protect agriculture from plant and animal diseases and pests,” under which heading the “APHIS Strategic Plan Framework” promises to “continue to ensure the safety, purity, and effectiveness of veterinary biologics and provide oversight of genetically engineered organisms,” including “to investigate alleged violations of agency‐administered laws and issue enforcement actions.”

APHIS Goal 4, to “Maintain and expand the safe trade of agricultural products,” includes helping to build “regulatory capacity in developing countries to facilitate trade and develop future markets,” a job likely to focus on animal welfare, albeit in connection with raising animals for slaughter.

(Beth Clifton photo)

Wildlife Services

APHIS Goal 5 is the operating mandate of Wildlife Services: to “Manage wildlife damage and threats to agriculture, natural resources, property, and people.”

Absent an act of Congress, APHIS does not have the authority to kill Wildlife Services, even if it institutionally wanted to. But APHIS policies and priorities can be rearranged to de-emphasize killing wildlife, in favor of non-lethal solutions, more research and development of wildlife birth control (an area in which APHIS has already done more than all other government agencies combined), and continued distribution of “millions of oral rabies vaccination baits,” along with collecting and testing “samples from wild animals to reduce rabies in wildlife and prevent disease spread to people, livestock, and pets.”

This would be samples from animals either found dead under suspicious circumstances or euthanized after exhibiting rabies symptoms.

Mississippi lawyer Clant Seay may have done more to enforce the Horse Protection Act in recent years than USDA-APHIS has in decades.. (Billygoboy Facebook photo)

Animal Welfare Act & Horse Protection Act

APHIS Goal 6, to “Promote the welfare of animals,” involves enforcing the Animal Welfare Act and Horse Protection Act, and providing “national leadership on the safety and well‐being of pets and other animals in disasters.”

Under this heading, the “APHIS Strategic Plan Framework” notes that “APHIS has initiated a process to amend the AWA regulations and develop standards for birds to ensure their humane care and treatment,” to “apply to birds not bred for use in research; all birds bred for research are exempt from regulation under the Animal Welfare Act.

“With the new regulations expected to be finalized in the first half of fiscal year 2023,” the “APHIS Strategic Plan Framework” projects, “APHIS will need to prepare for the implementation of the regulations.”

(See USDA proposes to cover birds under the Animal Welfare Act––sort of.)

Clant Seay’s motto is “We the people.”
(BillyGoBoy photo)

“The public is more interested in wildlife & livestock welfare than ever before”

This section “APHIS Strategic Plan Framework” concludes with a mention that, “While it is unclear how animal welfare legislation and consumer behavior will evolve over time, the agency should prepare for the possibility of increased regulatory responsibility of farm animals.”

The concluding portion of the “APHIS Strategic Plan Framework” adds that “Public perceptions around animal welfare and wildlife in society are evolving. APHIS’ activities directly impacting animals are being scrutinized. The public is more interested in wildlife and livestock welfare than ever before.”

Beth & Merritt Clifton

Submit your comments at: https://www.regulations.gov/commenton/APHIS-2022-0035-0001.

And again, too see the comments ANIMALS 24-7 submitted on June 4, 2022, when the comment period first opened, please go to USDA-APHIS wants your 2¢ on animal-related federal law enforcement––NOW!!!, and scroll to the subhead “This is the ANIMALS 24-7 two cents’ worth.”