Letter to the USDA regarding Animal Welfare Act enforcement related to licensing of dealers and exhibitors

SUMMARY

The Animal Law Committee wrote a letter to the United States Department of Agriculture urging it to exercise its jurisdiction to (1) decline to renew and to suspend or revoke the licenses of those exhibitors whose conduct and operations constitute repeated or serious violations of the Animal Welfare Act or demonstrate a pattern of violating the AWA by either repeat violations or a failure to cure cited violations of the AWA and (2) confiscate the involved animals and transfer them to accredited sanctuaries. The letter also recommended that the USDA adopt robust thresholds to determine when a particular license should not be renewed or should be suspended or revoked. The letter notes that while AWA regulations require applicants for license renewal to certify that they are in compliance, and will continue to comply, with the law, in practice the USDA’s review of applications for license renewals does not appear to implement substantive standards or include an inquiry into the compliance history of applicants.