Submitted Electronically via eRulemaking Portal

Dear Fish and Wildlife Service, Thank you for reviewing the status of chimpanzees under the Endangered Species Act. I care about all chimpanzees, and support your proposal to list both wild and captive chimpanzees as endangered. As the FWS moves forward on this issue, I would like to re-iterate some important points. Despite being listed as endangered in 1990, wild chimp populations are still at risk of extinction. Due to habitat loss and poaching, chimp numbers have dropped 65% over the past three decades. This is exacerbated by the pet, entertainment, and biomedical research industries, which exploit chimpanzees living in captivity. The FWS's current 'split-listing' of chimpanzees has done little to protect those in the wild, making a change in how these animals are categorized necessary. However, I am concerned that the FWS has indicated that biomedical testing on chimpanzees may continue through a permit system that liberally interprets the requirement for conservation benefits. The National Institutes of Health, Institute of Medicine, and many scientists have stated that chimpanzees are not needed to study human health and disease, and, therefore, no acceptable justification can be made to receive a permit to be exempt from the ESA. Laboratories requesting a permit should NOT be allowed to 'trade' donations to conservation in exchange for biomedical research that is harmful to individual chimps. All chimps need and deserve protection, so I support the FWS's proposal to list both wild and captive chimpanzees as endangered. But I do ask the FWS to refuse any permit requests that involve using chimpanzees in research. Not only is this research flawed and of questionable validity, it is simply wrong. Using these sensitive and intelligent animals for this purpose is nothing short of a holocaust. Thank you for attention to this important issue, and for your help to protect chimpanzees!