Below is my letter to Assemblymember Gomez on behalf of The Rabies Challenge Fund.
February 13, 2013
Assemblymember Jimmy Gomez
P.O. Box 942849
Sacramento, CA 94249-0051
RE: AB 272 An Act to Amend Section 121690 of the Health and Safety Code Relating to Rabies
Greetings Assemblymember Gomez:
Assembly Bill AB 272 which you have introduced seeking to lower the age at which dogs must be vaccinated against rabies from 4 months to 3 months is ill-advised and scientifically unfounded. The bill seeks to address a problem in the canine community that does not exist, as the California Department of Public Health’s statistics in Reported Animal Rabies Data make abundantly clear: bats and other wildlife pose the major threat of rabies transmission to the public, not dogs under the age of 4 months.
Three cases of rabies in dogs since 2007 (no mention of them being dogs under 4 months of age), as opposed to 981 rabid bats and 147 rabid skunks for the same period, evidences the fact that the current law requiring puppies to be vaccinated against rabies by 4 months of age is effective at controlling rabies in California’s canine community and does not need to be changed.
Lowering the age at which puppies are required to have their first rabies shot from 4 months to 3 months would be counterproductive. Puppies are finishing up their other vaccinations (distemper, hepatitis, parvo) at 12 weeks (3 months) of age, and adding a rabies vaccine into the mix will not only increase the likelihood of adverse reactions, but also the probability that the vaccine components will interfere with each other and neutralize or negate the desired immunological response.
Contributing to the chance that rabies vaccination at 3 months may not be effective is the continued presence of maternal antibodies. According to the 2006 American Animal Hospital Association's Canine Vaccine Guidelines, the most common reason for vaccination failure is "the puppy has a sufficient amount of passively acquired maternal antibody (PAMA) to block the vaccine......"  They elaborate by reporting that at the ages of 14 to 16 weeks of age, "PAMA should be at a level that will not block active immunization in most puppies (>95%) when a reliable product is used." After the age of 16 weeks (4 months), the maternal antibodies are reduced to a level at which they should not reduce the rabies vaccine's effectiveness.
Vaccinating puppies at too young an age can be ineffective. The 2003 American Animal Hospital Association's (AAHA) Canine Vaccine Guidelines reports on Page 16 that: "When vaccinating an animal, the age of the animal, the animal's immune status, and interference by maternal antibodies in the development of immunity must be considered. Research has demonstrated that the presence of passively acquired maternal antibodies interferes with the immune response to many canine vaccines, including CPV, CDV, CAV-2 and rabies vaccines.” 
As it currently stands, the law requiring puppies to be vaccinated at 4 months of age is and has been effective at controlling rabies in California’s canine population. There is no epidemiological or scientific rationale for changing this law and prematurely exposing puppies to the potentially harmful, sometimes fatal, adverse side affects of the rabies vaccine prior to the age of 4 months.
On behalf of The Rabies Challenge Fund and the many concerned California pet owners who have requested our assistance, I strongly urge you to withdraw AB 272.
Kris L. Christine
THE RABIES CHALLENGE FUND
cc: Dr. W. Jean Dodds
Dr. Ronald Schultz
 American Animal Hospital Association Canine Vaccine Task Force. 2006 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, 28pp.
 American Animal Hospital Association Canine Vaccine Task Force. 2003 Canine Vaccine Guidelines, Recommendations, and Supporting Literature, 28pp.