September 29, 2026 
VIA ELECTRONIC SUBMISSION 
The Honorable Brooke L. Rollins
Secretary
U.S. Department of Agriculture
1400 Independence Avenue, SW
Washington, DC 20250
 
RE: SEPTEMBER 21, 2026, ANIMAL WELFARE STRIKE FORCE ANNOUNCEMENTS  
 
Dear Secretary Rollins: 
 
On behalf of the National Animal Interest Alliance (“NAIA”), a broad-based animal welfare organization founded in 1991 to provide balanced and fact-based answers to complex and often controversial issues regarding animals, thank you for considering our comments in response to the above-referenced recent announcements. NAIA’s membership is diverse but is composed of members with hands-on daily direct interaction and experience with animals. It includes pet enthusiasts and breeders, rescuers, sportsmen, pet businesses, conservationists, farmers, scientists, and veterinarians. We followed your September 21 press conference with Secretary Kennedy and related announcements closely, and we would like to begin our comments with where we see significant alignment.

First, dog fighting is a felony and is unquestionably reprehensible. As Judge Pirro rightly described it, it can be a gateway offense entangled with drug trafficking, firearms, and other criminal activity. We support that enforcement work without reservation. Likewise, we support the stated mandate of the new Animal Protection Bureau to shut down illegal dog import routes, root out illegally operating commercial breeders, and stop inappropriate regulatory evasion. Our members and supporters are, by definition, the people who did apply for the license, and who do maintain the records. Every enforcement action against an operator who evades that system is an action that protects the people who do not. When federal agencies distinguish between the licensed and those who should be licensed, it is defending the integrity of its own regulatory program, and our members benefit directly.

We would offer one piece of context on scale. APHIS Animal Care’s own reporting has consistently found the licensed population to be overwhelmingly compliant. In its Fiscal Year 2023 report, approximately 96 percent of licensees and registrants were found in substantial compliance across more than 10,500 site inspections covering over 1.4 million animals. Over the same period, the number of licensed breeders and dealers has fallen by more than seventy-five percent from its peak in the 1980s. The enforcement problem the Department has identified is real, but it is concentrated almost entirely outside the licensed population, and it has grown as that population has shrunk. Policies that raise the cost of being licensed accelerate the movement to an unregulated status the Animal Protection Bureau now exists to reverse. As such, this is why we write today. The constituencies with the most direct operational stake in these initiatives, and with data to contribute to them, were not represented at the roundtable that preceded the announcements.

Respectfully, we ask that you consider our requests for more engagement. To our knowledge, the September 21 roundtable convened rescue organizations, advocates, and enforcement officials, but not individuals representing licensed research institutions, licensed breeders, brokers, or other licensees and registrants that the USDA regulates and inspects. These entities deserve representation. We do not seek to displace anyone. We are asking that the Department hear from the people who will be inspected under the forthcoming rule before it is written rather than only after it is proposed. Our members can speak to what inspection inconsistency looks like, where recordkeeping requirements produce useful data, and which husbandry and veterinary practices reflect standards of care rather than genuine animal welfare concerns. That information is available from no other source, and it will make the resulting rule productive and defensible.

You noted the Department’s intention to bring tens of thousands of currently unlicensed breeders under federal oversight. As explained in more detail below, we support reaching operators who evade licensure. We do note, however, that USDA’s existing exemptions for small residential breeders and for brick-and-mortar retail pet stores reflect deliberate congressional design rather than oversight, and that the D.C. Circuit sustained the Department’s judgment on precisely this question in Doris Day Animal League v. Veneman, 315 F.3d 297 (D.C. Cir. 2003), where the court credited USDA’s consideration of the potential invasions of privacy attending inspection of private residences. We urge that these protections continue.

This exemption protects the hobby breeder community that public policy should actively encourage. Responsible hobby breeders commonly spend decades with a single breed, health test their breeding stock, screen prospective homes, and remain available to take a dog back years after it was placed. Their work preserves sound health, stable temperament, working ability, and the genetic diversity on which every future generation of purpose-bred dogs depends. These breeders are not commercial kennels merely because they breed, and they are among the most transparent and knowledgeable sources from which a family can obtain a dog. When unnecessary regulatory restrictions have been imposed on hobby breeders at the state and local level, the predictable result has not been improved welfare, but fewer quality sources, with buyers steered toward internet sellers and scam-filled markets where meaningful oversight is nearly nonexistent. We urge the Department to keep that dynamic firmly in view as it considers next steps.

Similarly, we urge the Strike Force to bring to the unregulated side of the dog market the same attention it is directing toward licensed facilities, because that is where the volume now moves. NAIA has documented that more than a million dogs are imported into this country annually, with hundreds of thousands more moving across state lines, much of it under the banner of humane relocation. High‑volume rescues face no meaningful oversight yet place the vast majority of dogs with new families each year. The sourcing of these animals is too often hidden. Imported dogs are typically required to have Certificates of Veterinary Inspection, yet in many cases it is extremely difficult to establish how many dogs enter a given state, from whom, or from which facilities, and the process is rife with fraud. Certificates are falsified, and dogs from substandard foreign and domestic breeding operations are laundered and placed with families as kill shelter rescues, puppy mill rescues, and owner surrenders. This is exactly the trafficking the Strike Force and federal attention should address. We must be sure that new actions do not unnecessarily restrict the regulated markets further, but apply uniform animal welfare and consumer protections to all third-party sellers.

Next, we note with appreciation Secretary Kennedy’s statement that FDA’s direct final rule implementing the FDA Modernization Act does not ban animal studies or change FDA’s evidentiary standards, and his further clarification that the Department is not banning animal testing. We take those statements as authoritative and welcome them. We support the development and validation of New Approach Methodologies and are actively engaged in that work. The substantial investment now being made in validating these methods, including the NIH office changes and announcements on September 21, recognizes that validation of NAMs is an ongoing process that is not close to complete. Policy and enforcement must follow validation, not come before it.

Moreover, in September 2025, the National Animal Interest Alliance submitted a comment to the Department of Justice in response to its Request for Information on state laws adversely affecting interstate commerce (Docket No. OAG182, 90 Fed. Reg. 39427), documenting how the patchwork of state and local animal commerce restrictions burdens interstate trade and asking that federal preemption initiatives be explored. That record is already before the Department of Justice. The recent announcements strengthen support for our request. The principal justification offered for state and local overreach has always been that federal enforcement is inadequate. The actions of the USDA and your partner agencies over the last two years, and more so from the September 21st announcements, demonstrate this statement is false. We ask that USDA take up this question with the Department of Justice through the Strike Force and consider whether guidance, rulemaking, or a legislative recommendation would appropriately affirm the Animal Welfare Act’s uniform national standards.

In summary, NAIA recognizes that the Department has taken on this work in earnest, and we do not mistake vigorous enforcement against criminal conduct for hostility toward lawful, licensed, regulated activity. Our request is simply that the Department hear from the regulated community on an ongoing basis. We have much to offer. We would welcome the opportunity to meet at your convenience.

Sincerely, 
Patti Strand, President
National Animal Interest Alliance (NAIA) 
 
cc: 
 
The Honorable Robert F. Kennedy Jr., Secretary of Health and Human Services 
The Honorable Bernadette Juarez, Deputy Administrator, Animal Care for the Animal and Plant Health Inspection Service (APHIS), US Department of Agriculture