October 29, 2004

To the Officers and Directors of the
American Federation of Aviculture

Re: AFA Comments on the Proposed Rulemaking under the Animal Welfare Act to Include Birds

Dear Friends,

I am pleased to inform you that the attached letter has been filed with the USDA as AFA’s official comments under the Notice of Proposed Rulemaking for the inclusion of birds under the Animal Welfare Act. 

Upon advice of Gary Lilienthal, our General Counsel, we have kept the enclosed in the strictest of confidence.  As our counsel, Gary considered confidentiality to be critical for the comments to have a maximum chance of success.  I have reviewed these comments as they evolved over the past several weeks, and believe that they have an excellent chance of having a positive effect for aviculture on the promulgation of regulations for inclusion of birds under the Animal Welfare Act. 

I believe that these comments will be well received by USDA and should give USDA the ability to eliminate one of the major concerns of aviculture with the implementation of the AWA to birds, that of, on-site inspection.  I trust that you will be as pleased as I am at the substance of AFA’s comments.   

Very truly yours,

Benny J. Gallaway, President