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The American Kennel Club (AKC) recognizes the invaluable contributions to both human and veterinary medical knowledge and practices that have resulted from medical research on animal subjects, including dogs.  Animal research has led to innumerable health advances that have saved or improved millions of human and animal lives.

View AKC’s position statement on The Use of Dogs In Research.

The National Association for Biomedical Research (NABR), which works to safeguard the future of biomedical research and supports the humane care and treatment of animals used in research, recently filed a complaint with the U.S. Department of Transportation regarding practices of some airlines that have refused to transport some species of animals for research purposes, but have agreed to transport the same species for other purposes, including as pets and for zoos or conservation efforts.

The AKC shares concerns that some airlines are arbitrarily limiting the legal transportation of animals, with staff making “moral” judgments as to which animals and owners may benefit from air transportation and which may not.  If allowed to continue, this practice could negatively impact the ability of scientists and researchers to perform their important work.

Concerned dog owners are encouraged to contact the U.S. Department of Transportation and request it evaluate the NABR’s recent complaint.  You are welcome to use the Draft Comment language below.  Comments to the U.S. Department of Transportation may be submitted by going to https://www.regulations.gov/document?D=DOT-OST-2018-0124-0001 and selecting “Comment Now!” near the top right corner of the page.

For more information, contact AKC Government Relations at doglaw@akc.org.

 

Draft Comment:

[DATE]

Secretary Elaine Chao
United State Department of Transportation
1200 New Jersey Avenue, S.E.
Washington, DC 20590
Attn:  Blane A. Workie, Assistant General Counsel for Aviation Enforcement Proceedings

Re: Submission in NABR v. United Airlines et al. – Docket No. DOT-OST-2018-0124

Dear Madam Secretary:

I am submitting this letter to provide the Department of Transportation (DOT) with information that may be relevant to its evaluation of the above referenced complaint, which alleges that various airlines refuse to carry animals for critical biomedical research, but carry them for other purposes.

Researchers must rely on live-animal research to safely develop treatments for both people and animals alike. Access to live-animal subjects is required in order to conduct this critical work. At the same time, current laws and regulations mandate this kind of research before life-saving medicines and treatments may be approved for use in humans. 

According to the complaint, many airlines refuse to transport animals for these vital scientific discoveries, although they will transport the same animals for non-research purposes, such as for zoos or as pets.  I believe that as long as the government requires this research, it should also enforce its laws in a way that does not undermine these essential research requirements. This arbitrary delineation by the airlines – which we understand has no transportation related purpose – threatens the progress of key research, research which could reduce or even eradicate diseases. 

I respectfully urge the DOT to investigate the complaint filed by NABR and to require all airlines to eliminate policies which discriminate against animal carriage and instead base carriage solely on the fact that the purpose of the transportation of animals is for legal, legitimate, necessary and essential life-saving biomedical research.  We respectfully request that DOT take these actions to ensure the continued progress of essential medical research.

Sincerely,

[Name]

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