Comment from Adeola , Emmanuel

I HAVE A VERY STRONG ARGUMENT AGAINST THESE PROPOSALS. **What the policy does:** Extends and revises APHIS's paperwork requirements for importing pet birds, performing birds, research birds, and bird carcasses into the US — all in the name of HPAI and Newcastle Disease prevention. 5,100 respondents, 6,334 annual burden hours, and an estimated 41 minutes per response. **7 core arguments against it:** 1. **Burden estimate is fiction** — APHIS claims 41 minutes per response, but a single bird import involves permit applications, vet certificates, quarantine arrangements, and post-arrival monitoring. Real burden is likely 5 to 5 to 10 higher. The total also jumped 250% from the 2023 version with no explanation. 2. **Form consolidation creates chaos** — Key forms (VS 16-3, 16 - 6A, 17-129, 16-28, 16-29) are being moved to different information collections, splitting a single import process across three separate systems. No transition plan provided. 3. **No electronic filing system** — In 2026, importers still use paper forms, mail, and fax. No online portal, no tracking system, no automated disease-status database. Violates the Paperwork Reduction Act. 4. **Research birds treated like commercial poultry** — Scientific institutions with biocontainment facilities and IACUC oversight face the same 30 DAY quarantine and reporting as bulk commercial shipments. Disrupts conservation breeding and research timelines. 5. **Pet bird owners abandoned** — US citizens returning with their pet birds face notarization requirements, forty quarantines, and 41-minute-per-response estimates that are detached from reality. No plain-language guidance exists. 6. **Bird carcass rules are ambiguous** — Hunters can't tell what counts as "processed." Scientific specimens are caught in commercial poultry rules. No published list of processing methods that eliminate disease risk. 7. **Inadequate public notice** — No direct outreach to avian veterinarians, bird breeders, researchers, hunters, or performing-arts handlers. These aren't categories of people who read the Federal Register. MY PERSONAL CONCERNS AS A RESEARCHER - **Pet bird owner** (traveling internationally with your bird) - **Researcher / scientist** (importing birds for study) - **Importer** (commercial bird or carcass imports) - **Hunter** (bringing game bird carcasses back from abroad) - **Performer / handler** (performing birds for entertainment)