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The following is a copy of a letter sent to the USDA
(United States Department of Agriculture) by members of the Wolf Dog Coalition prior to April, 1996 meeting.
December 18, 1995
Dr. Lonnie King
USDA, Whitten Bldg.
14th and Independence Avenue, SW.
Room 312, E.
Washington DC. 20250-3401
Dear Dr. King:
It is my understanding that rabies vaccines are approved for all domestic dogs of the scientific name "Canis Lupus Familiaris." According to the USDA Code of Federal Regulations Title 9 (CFR9), Section 113.209, rabies vaccines are tested and approved according to species. I am writing you today to ask that the current canine rabies vaccine be approved for wolves and wolf dogs (wolf hybrids) in accordance with USDA testing and regulatory procedures. Please take into consideration the following information: The Code of Federal Regulations (9 CFR chapter 1.1) "Animal Welfare" has defined a wolfxdog as domestic.
Changes occurred in the taxonomic classification of canines in the past ten years that bear looking into. Please have your staff research this matter in regard to the proper taxonomic classification for wolves and wolfxdog crosses. You will find that wolves, wolf dogs and dogs are now classified as Canis Lupus, dogs and wolf dogs are classified as Canis Lupus Familiaris, which means canine of wolf origin that is domesticated. This change has occurred after decades in which Canis Familiaris was listed as "probably conspecific" to Canis lupus. In light of the data available from biologists across the country as well as the "Mammal Species of the World: A Taxonomic and Geographic Reference, 1993" we are certain you will come to the conclusion that the wolf dog should be reclassified under the AWA and be subject to the standards under Subpart A rather than Subpart F. Mammal Species of the World is the presently accepted standard of mammal authorities, including the American Society of Mammalogists and the International Commission of Zoological Nomenclature and has been peer reviewed. It is also the authority upon which USDA has based it's decisions in the past. Many "exotic breeds" have been approved for the rabies vaccine despite the lack of specific testing and the fact that their lineage is unknown; the approval was based primarily on the "Mammal Species of the World" reference. Among these are the: New Guinea Singing Dog, Canaan Dog, Dingo and the Carolina Dog.
Please note: there are many supportive studies by such experts as Drs. Robert Wayne, L.David Mech, Raymond Pierotti, Terry Kreeger, Dmitry Belyaev, Ray Coppinger, Rodney Honeycutt, Morey, Wozencraft and many others. REAC has repeatedly clarified the wofxdog to be a dog. The taxonomic issue is clear, the wolf and wolfxdog should be included under the dog label, without the need for testing.
In our pursuit of the approval of the rabies vaccine for wolves and wolf dogs we have met and exchanged information with many other organizations that have pursued the same goals. They have been met with evasions and been put off as to a decision in this matter. We are requesting a definitive answer. Are rabies vaccines approved according to species as set out in your regulations? If so, there can be no question that the current canine vaccine is efficacious in wolves and wolfxdog crosses. If there is some little known clause of which we are unaware please apprise us; if not please let us know that the rabies vaccine is approved for wolves and wolfxdog crosses or supply a scientific and intelligent reason why the wolf and wolfxdog is denied approval for the current rabies vaccine and supply appropriate backup material for your stance.
Thank you for your consideration in this matter. Please feel free to call at any time if you require more information or clarification, evenings: [ telephone numbers ].
Copy of original signed letter is available upon request.
Contact The Wolf Dog Coalition ( firstname.lastname@example.org ).
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