Oppose the CDC Dog Import Rule!

I oppose the CDC's proposed rule entitled, "Control of Communicable Disease; Foreign Quarantine: Importation of Dogs and Cats."

Dear Ashley C. Altenburger, J.D,

I am writing the Center of Disease Control and Prevention to voice my concern over the agency's proposed rule entitled, "Control of Communicable Disease; Foreign Quarantine: Importation of Dogs and Cats."

Many animal protection organizations, including the Humane Society of the United States and Humane Society International, respond to cruelty and disasters at the request of local communities across the world, and I believe that we should safeguard the capacity of such organizations to transport unowned dogs safely out of these disaster areas and into the United States for adoption. While I support the intention behind this action—it is critical to protect animals and families in the United States from rabies—the proposed rule poses significant burdens on rescue organizations and people traveling with their pets.

The proposed rule goes far beyond the temporary dog import rule by imposing import requirements on all dogs imported into the United States, regardless of country of origin. The proposed rule does not distinguish between personal and commercially imported dogs, requiring all dogs to be at least 6 months old, bare a microchip, and submit a CDC import form prior to travel. Extending these requirements to all dogs will greatly burden the CDC, and I want to express concern over the agency's ability to handle this dramatically increased regulatory volume.

Notably, the proposed rule asks all importers to prove a negative, that their dog has NOT been in a high-risk rabies country for six months before arriving in the U.S, without providing guidance on how an importer would do so. The severity of being denied admission, and required to return within 72 hours of arrival, is a grave burden for dogs and those trying to help them. Hinging this on a vague, and in many cases impossible, requirement means that many animals who otherwise would have been transported from countries with low or no rabies risk will not be able to be rescued and that even owners travelling with their own pets will be at risk of being denied entry if they don't provide the proper "proof."

I appreciate that the proposed rule advocates for airlines to provide safe housing for quarantined dogs and increased transparency around determining cause of death for dogs in their care. I thank the agency for its work, and respectfully request that the agency provide clear instructions for all importers on how to demonstrate that their dogs have not been in a high-risk rabies country for six months before arriving in the U.S. I also ask that the agency reconsider requiring CDC import submission forms for all imported dogs to avoid unnecessary regulatory delay and agency burden.

Thank you.