Comment from Anonymous

Please consider the attached technical feasibility briefing from The Alliance for Cruelty Free Science (Linda Birr-Pixton) as supplemental material relevant to ongoing discussions regarding modernization of biomedical research and increased adoption of human-relevant New Approach Methodologies (NAMs). What makes this document particularly valuable is that it does not simply advocate for reducing animal use — it presents a detailed operational and infrastructure-based transition framework for how this could realistically be accomplished at scale. The briefing synthesizes existing technologies and policy concepts into a cohesive modernization strategy addressing many of the practical barriers that are frequently cited as obstacles to transition. The document discusses: • phased transition planning and implementation timelines • use of archived FAIR-compliant datasets to preserve historical scientific knowledge • integration of AI, computational modeling, organoids, and organs-on-chips • infrastructure conversion of animal facilities into NAM-centered research hubs • reviewer and workforce training initiatives • translational reliability and interspecies limitations • institutional and funding incentives that may unintentionally slow innovation • strategies to support researchers during modernization and retraining efforts Whether or not one agrees with every proposed timeline or recommendation, I believe this briefing provides a thoughtful and unusually comprehensive systems-level framework that warrants serious review and consideration within future scientific and regulatory modernization discussions. Thank you for your time and consideration.