Statements By The New Guinea Singing Dog Club of America Board and supported by their membership
TO: USDA/APHIS
March 1st 2023
First we would like to thank USDA/APHIS for their hard work in protecting the public, handlers, keepers, and the welfare of animals within their purview. We are writing to you today regarding the proposed “USDA Plan to Strengthen Regulations for Handling Wild and Exotic Animals for Exhibition; Environmental Enrichment Requirements” as well as the regulation and classification status of New Guinea Singing Dogs within the USDA as a whole.
In April 2016 an APHIS Animal Care Tech Note was published changing the “Classification of the Dingo and New Guinea Singing Dog” from "dogs" to "exotic animals" and would regulate them under Subpart F as "other animals" with the inclusion of examples; “coyote or African Wild Dog”. The Tech Note stipulates that “in 2003, the dog was reclassified from Canis familiaris to Canis lupus familiaris, and the Dingo and New Guinea Singing Dog became classified as Canis lupus dingo.” Of the cited sources for this statement, the International Commission on Zoological Nomenclature Bulletin (2003) does not specifically say that dingoes or New Guinea singing dogs are not domestic dogs. To quote Jackson and colleagues (2020):
“Opinion 2027 (Case 3010) (ICZN, 2003) – This publication reviewed 17 specific scientific names based on wild species that are pre-dated by, or contemporary with, those based on domestic animals. This publication lists the Grey Wolf (Canis lupus Linnaeus, 1758) and its domestic derivative the Dog (Canis familiaris Linnaeus, 1758). It also explicitly places the name Dingo in brackets after the name Dog to provide a clear indication that the Dingo was considered to be a Dog. In addition, the Opinion confirmed that Linnaeus’ binomial, e.g. Canis familiaris, should be retained for the 17 domestic animals and their wild-living (sensu Darwin 1859) derivatives as a matter of nomenclatural procedure. This arrangement was reiterated by Gentry (2004)”.
The citation for Wilson and Reeder’s Mammal Species of the World does not mention New Guinea Singing Dogs specifically but references Canis lupus dingo only from (Meyer, 1793) and still includes that they are “domestic dogs”. Within the synonyms of this classification can be found the only references associated with New Guinea singing dogs, specifically papuensis (Ramsay, 1879) and hallstromi (Troughton, 1957) all significantly out of date references. A thorough review of the current literature on dingoes and New Guinea Singing Dogs shows that their classification is still hotly debated and Canis lupus dingo is not “The currently most accepted taxonomic classification for both the Dingo and the New Guinea Singing Dog”.
It is our recommendation through demonstration of the current scientific literature that New Guinea Singing Dog be reclassified as Canis familiaris or Canis lupus familiaris, and continue to fall in the regulatory definition and standards for “dog”. The New Guinea Singing dog is not native to Papua New Guinea but is instead an ancient breed of dog introduced to the island nation approximately 3000-5000 thousand years ago likely through seafaring (Cramb, J. 2022, Greig, K. et al. 2018, Savolainen, P., et al. 2004). Current genetic evidence places New Guinea Singing Dogs as appearing after the genetic point where dogs were considered domesticated (Perri, A. 2021, Savolainen, P. et al. 2004), approximately 20,000+ years ago (Perri, A. 2021). They do not extend from a diversion point before this point of domestication. Therefore they are a domesticated animal, regardless of living in a wild state. It is also not unique for domesticated animals to live in a “wild state” as is seen with the domestic horse, domestic pigeon and domestic camel, and many other domesticated species. The New Guinea singing dogs’ proximity to humans both in villages (Dwyer, P., & Minnegal, M. 2021a, Dwyer, P., & Minnegal, M. 2021b, Dwyer, P., & Minnegal, M. 2016) and in a free-living state (McIntyre, et al. 2019) in Papua New Guinea do not change the genetic status of the New Guinea Singing Dog as a domestic dog. Numerous researchers and academics classify New Guinea Singing Dogs as domestic dogs (Dwyer, P., & Minnegal, M. 2021a, Dwyer, P., & Minnegal, M. 2021b, Dwyer, P., & Minnegal, M. 2016, National Institutes of Health. 2020, Jackson et al. 2017), and recently as 2019 the IUCN designated New Guinea Singing Dogs as “feral domestic dogs” (Alvares et al. 2019).
The majority of New Guinea Singing Dogs living in the United States today, live as companion animals (Koler-Matznick, J. 2016, Sumridge et al. 2021). Under the current classification, the welfare of the majority of New Guinea Singing Dogs is negatively impacted. As domestic dogs, they require the same husbandry care, medical care, enrichment, and socialization as other domestic dog breeds (American Veterinary Society of Animal Behavior. 2014, Serpell, J. 2017). The current classification for New Guinea Singing Dog prevents some of these dogs from receiving this essential care through individual restrictions on “exotic or wild animals”. This has prevented essential medical care, training, and socialization, critical for a domestic dog to thrive.
When allowed to live as domestic dogs in the United States, New Guinea Singing Dogs are found to live identical lives to dogs of other primitive and ancient origins such as Shiba Inus and Basenjis. A study published in 2021 found that New Guinea Singing Dogs are less aggressive to humans and dogs than other dog breeds (Sumridge, et al. 2021). This study also found that they are also as trainable as other dog breeds included in the study including competing in dog sports, and participating in activities including as therapy dogs. New Guinea Singing Dogs still earn the AKC Canine Good Citizen certificate and were previously shown in conformation in the United Kennel Club in the 1990s. They are still showable in the American Rare Breed Association today. The restrictions placed upon New Guinea Singing Dogs via their current USDA classification as well as the proposed Category 2 are unnecessary and would further restrict essential activities and lives where they thrive.
It is an unnecessary waste of important resources to regulate New Guinea Singing Dogs as exotic animals as they are domestic dogs and create no additional concerns for public safety and animal welfare. The continued classification and categorization as an exotic canine negatively impacts their welfare and ability to thrive as domestic dogs. We appreciate your request for public comment. Our team and researchers are available to assist the USDA/APHIS in the matter if they see fit.
Sincerely,
The New Guinea Singing Dog Club of America
Works Cited:
Alvares, F., Bogdanowicz, W., Campbell, L., Godinho, R., Hatlauf, J., Yadvendradev, J., Kitchener, A., Koepfli, K.-P., Krofel, M., Senn, H., Sillero-Zubiri, C., Viranta, S., & Werhahn, G. (2019). Old World Canis spp. With taxonomic ambiguity: Workshop conclusions and recommendations. Y CIBIO-InBIO and the IUCN SSC Canid Specialist Group.
American Veterinary Society of Animal Behavior. (2014). AVSAB Position Statement on Puppy Socialization. American Veterinary Society of Animal Behavior. https://avsab.org/wp-content/uploads/2018/03/Puppy_Socialization_Position_Statement_Download_-_10-3-14.pdf
Cramb, J. (2022). The Dogs of Remote Oceania: An archaeological and ethnohistorical view of domestic dog introduction and loss in the South Pacific. Archaeology in Oceania, 57(1), 28–38. https://doi.org/10.1002/arco.5252
Dwyer, P., & Minnegal, M. (2021a). The provenance of diagnostic specimens of the ‘New Guinea Singing Dog.’ Memoirs of the Queensland Museum - Nature, 63, 27–39. https://doi.org/10.17082/j.2204-1478.63.2021.2021-01
Dwyer, P. D., & Minnegal, M. (2021b). Relationship between wild-living and village-living dogs in New Guinea. Proceedings of the National Academy of Sciences, 118(12), e2020432118. https://doi.org/10.1073/pnas.2020432118
Dwyer, P. D., & Minnegal, M. (2016). Wild dogs and village dogs in New Guinea: Were they different?Australian Mammalogy, 38(1), 1–11. https://doi.org/10.1071/AM15011
Greig, K., Gosling, A., Collins, C. J., Boocock, J., McDonald, K., Addison, D. J., Allen, M. S., David, B., Gibbs, M., Higham, C. F. W., Liu, F., McNiven, I. J., O’Connor, S., Tsang, C. H., Walter, R., & Matisoo-Smith, E. (2018). Complex history of dog (Canis familiaris) origins and translocations in the Pacific revealed by ancient mitogenomes. Scientific Reports, 8(1), 9130. https://doi.org/10.1038/s41598-018-27363-8
Jackson, S. M., Fleming, P. J. S., Eldridge, M. D. B., Archer, M., Ingleby, S., Johnson, R. N., & Helgen, K. M. (2021). Taxonomy of the Dingo: It’s an ancient dog. Australian Zoologist, 41(3),
347–357. https://doi.org/10.7882/AZ.2020.049
Jackson, S. M., Groves, C. P., Fleming, P. J. S., Aplin, K. P., Eldridge, M. D. B., Gonzalez, A., & Helgen, K. M. (2017). The Wayward Dog: Is the Australian native dog or Dingo a distinct species? Zootaxa, 4317(2), 201. https://doi.org/10.11646/zootaxa.4317.2.1
Koler-Matznick, J. (2016). Why the New Guinea singing dog should be considered a companion animal and not subject to regulations as an exotic animal.
McIntyre, J. K., Wolf, L. L., Sacks, B. N., Koibur, J., & Brisbin, I. L. (2019). A population of free-living highland wild dogs in Indonesian Papua. Australian Mammalogy, 42(2), 160–166. https://doi.org/10.1071/AM18039
National Institutes of Health. (2020). Scientists use genomics to discover an ancient dog species that may teach us about human vocalization: The finding marks a new effort in conserving an ancient dog breed, with potential to inform human vocalization processes. National Institutes of Health. https://www.nih.gov/news-events/news-releases/scientists-use-genomics-discover-ancient-dog-species-may-teach-us-about-human-vocalization
Perri, A. R., Feuerborn, T. R., Frantz, L. A. F., Larson, G., Malhi, R. S., Meltzer, D. J., & Witt, K. E. (2021). Dog domestication and the dual dispersal of people and dogs into the Americas. Proceedings of the National Academy of Sciences, 118(6), e2010083118. https://doi.org/10.1073/pnas.2010083118
Savolainen, P., Leitner, T., Wilton, A. N., Matisoo-Smith, E., & Lundeberg, J. (2004). A detailed picture of the origin of the Australian dingo, obtained from the study of mitochondrial DNA. Proceedings of the National Academy of Sciences, 101(33), 12387–12390. https://doi.org/10.1073/pnas.0401814101
Serpell, J. (Ed.). (2017). The domestic dog. Cambridge University Press.
Sumridge, M. H., Suchak, M., & Hoffman, C. L. (2021). Owner-Reported Attachment and Behavior Characteristics of New Guinea Singing Dogs Living as Companion Animals. Anthrozoös, 1–18. https://doi.org/10.1080/08927936.2021.1898218
Public comment talking points:
New Guinea Singing Dogs are a domestic village dog and feral domestic dog. Significant evidence is available throughout the academic literature.
These dogs primarily live as companion animals in the United States and have been found to be less aggressive than other breeds of domestic dogs.
The welfare of New Guinea Singing Dog is negatively impacted by “exotic” and “wild” animal classifications and would be further negatively impacted by being moved into Category 2.
Please reconsider the classification of New Guinea Singing Dogs under the purview of the USDA/APHIS or only place them into Category 3.