Written By: Dr. Jeannie Thomason – Jun• 07•12

Do You Think It Can’t Happen?

THINK AGAIN!
If we spay and neuter all dogs and ban all breeding, what do you think will happen???

When donating, Please be careful who you donate to. The HSUS and PETA are AGAINST pet ownership. Read the fine print before you contribute or donate.

Where will you get your next family companion? Please support responsible breeders and private resuce groups.

PLEASE JOIN OUR FIGHT!

What is APHIS? USDA – Animal and Plant Health Inspection Service

“APHIS serves to facilitate safe trade, regulate the import and export of plants (and now animals), and help exporters meet the entry requirements of other countries”.

What is APHIS proposing as a rule change that will effect ALL pet owners? http://www.aphis.usda.gov/publications/animal_welfare/2012/retail_pets_faq.pdf

WHAT CAN WE DO?

1) Comment

A 60-day comment period began May 16 when the regulations were published to the Federal Register. To send your comment, go to http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001 You may file more than one comment if you wish.

Be respectful, tell how this would affect you and your breeding program and ask that APHIS withdraw these regulations. They are intended, by the way, to bring large “internet sellers” under USDA inspection. Apparently, someone has convinced them that there are huge numbers of kennels that take orders over the internet and ship puppies out with no one EVER coming to the kennel to see the conditions. No studies have been done of how many large “internet kennels” there actually are. The government cites “complaints from consumers” as proof but cannot tell us how many complaints there have been. But these regulations will catch thousands of caring, ethical hobby breeders in the net and may well put an end to many breeding programs.

2) Send your comment to your senator and representative.

Find out who they are here: •http://www.house.gov/representatives/

•http://www.senate.gov/general/contact_information/senators_cfm.cfm

These are proposed regulations, not a law Congress has to vote on. But point out to your representatives that the impact on the country’s economy and even on APHIS’s budget is tremendous. This is over-regulation of the worst sort and will make pets much harder to find and expensive to buy.

Please Note: If it is enforced to the letter, rescue organizations will also be included.

3) Send a copy of your comment to AKC at doglaw@akc.org . They are hard at work to prevent these regulations from passing and need to hear from as many people as possible.

We need everyone’s help on this one. It is the most serious threat so far to the home breeding of dogs.

If you have been wondering what to say in your comment to the APHIS rule change, read this. Although comments don’t have to be this long, this one is a good example of “telling your story” to make your points.

THIS WAS POSTED AS AN ATTACHMENT WHICH IS WHY IT IS LONGER THEN 2000 WORDS/SPACES.

I am strongly opposed to the newly proposed rules in APHIS 2011-0003-0001.

I am not a breeder of dogs but my livelihood depends upon those who are. I am a K9 handler who trains and handles dogs that detect survivors (live-find); and dogs that detect deceased persons. I volunteer my time to saving other people’s lives and bringing closure to families who are looking for loved ones, police officers who are trying to solve the most heinous of crimes and the dogs that provide the noses and incredible drive to do this work.

The proposed changes in APHIS-2011-0003-0001 will absolutely negatively impact all who rely upon my work – from the breeders to the dogs, to the families relying upon the information these dogs can provide. And I am representative of hundreds of other people who likely have no idea this public comment period is taking place.

This will not be the short, concise bullet pointed comment that is “recommended” by those in the know. This is a HUGE topic, it impacts thousands of everyday people, if not more, and it is a topic about which most of us are passionate. None of us support the concept of “puppy mills” nor activities nor people who do not have the welfare of animals in mind – but “welfare” has become a subjective term. In order to police those who should be halted in their practises and punished APHIS is not enforcing sensible laws that have been on the books for decades, but is rather infringing upon the freedoms of law abiding citizens by creating requirements for USDA licensure that are expensive and unnecessary for vast majority of people involved in the world of dogs – but who would be swept up in the net that is being cast by politically oriented, animal rights groups, their money, their agenda, their lobbyists and their hatred. This is NOT the business of the government – or more specifically the USDA and APHIS.

Allow me to share my story to give you some insight into how the propsed changes will impact the most unsuspecting of citizens:

The process of finding the right young, healthy prospective k9 partner is expensive and time consuming – but not all dogs are able to do this work. I work with German Shepherds and Belgian Malinois, exclusively for their incredible working ability. In the past 2 years alone I have evaluated 7 different dogs all of whom were moved onto a different line of work, or an appropriate pet home based on how they developed physically and mentally over time and their enjoyment of the work. “evaluating” a working dog cannot be done in a day nor accomplished by an interview process. During an evaluation process each of these dogs were provided with outstanding vet care for both screening of possible disease, as well as treatment of active disease, nutrition, exposure and training in the world, kindness, and respect. While each of these dogs were going through the process, I also had my currently working K9 partners to care for and work – and given that my dogs are intact far longer than 4 months of age, I would have needed to have a USDA license and all that is required of it.

Over 15 years I have rescued dogs from breed rescue organizations, spent months rehabbing the prospective working candidate, provided veterinary care, food, training, love, companionship, and an outlet for their physical and mental energy – only to find after 6 months, or in one case 2 years – that the work that I do is not the right work for the dog, and it is not FAIR to ask the dog to do work that causes stress or mental of physical discomfort. Those dogs needed homes that were suited to their needs – thus requiring more o f my time, effort, and money. Corresponding with people across the country to network and find a new home or job for a very special dog was conducted by phone, email, list serves.

According to the new APHIS regulations, I would now be required to be USDA licensed to engage in an activity that on the face of it and in the reality of it is for the betterment of mankind and dogs, alike.

Ikos would never have become my first working partner because his breeder had one litter a year, advertised online and was located in the Midwest – she couldn’t have afforded to become compliant with USDA licensure regulations for a facility. Ikos would not have gone onto save lives if these proposed regulations had been in place in 1997. Xeros would never have been able to come to me by plane after being carefully selected for my needs by a trusted breeder who was so tiny and obscure there was no way he could be in business if required to become USDA licensed. Enzo and I would never have been able to become the best of partners in work and life because he came from another country through a middleman. Dogs who were given up by their owners never would have been able to enter the national pipeline of devoted German Shepherd lovers to be moved across country by volunteers, evaluated by trainers, “sold” in order to cover vet bills and some fuel expenses. None of the people involved in the volunteer, rescue, re-home world could possibly afford to become USDA licensed. They do what they from their hearts – not based on their wallets. Indeed if the wallet had anything to do with the criteria for working dogs- I venture to say there would be very few.

Small breeders who meticulously maintain diverse genetics, and disease- free lines and who are devoted to the health and workability of these breeds would not be able to afford to become USDA licensed. What would happen to them? What would happen to all of us?

For the purposes of their health and temperament my working partners remain intact far longer than 4 months of age. They are not “breeding” dogs. A person who is responsible and educated will not alter a large breed, agile, athletic dog until they are 14-22 months of age at the youngest. All of these dogs would be considered “breeding dogs” under the new rules. Atleast it is up for interpretation. But by whom?

At any given time I may have 5 dogs at my house – my dogs, colleagues who visit to train, dogs who ,I myself, have committed to trying to nurture and re-home because they were mismatched the first time around. Does this make me a breeder?

Under the new proposed rules I would be a target for just doing what I do already – but when I took in “Mrs. G’s” 3 dogs when she died unexpectedly leaving her family in turmoil – I would have been in violation of Federal law for being a good neighbor and compassionate caretaker of animals.

As a handler who works exclusively with specific purebred dogs for my own purposes, the very notion that the small breeder who is meticulous in their work, genetic lines, research into specific breedings to try and regain what we have lost in the German Shepherd Dog from decades of horrendous breeding practices – these people will be put out of business because most of them will not be able to become USDA licensed due to cost, alone. This is a truly devastating notion. The ability to have a working specimen and be regulated by a government authority that does not understand how we breed-survey dogs, what a Schutzhund trial is really about, how long we must wait before even determining if a dog is suitable for breeding due to medical screening that we must perform (hips, elbows – can only be surveyed at 2 years of age as one example) – and by staying true to the science, medicine and best practises of raising these dogs people will be penalized by having to become USDA licensed… it doesn’t make sense.

APHIS has regulations in place already and historically enforcement has been haphazard and lax. I say this from my own experience working as a research biologist for 15 years and working with APHIS regularly, and now being a co-owner of a veterinary practise. By only utilizing “data” that does not represent the vast majority of citizens involved in the care, rescue, screening, careful breeding of dogs – poor decisions will be made. Don’t we owe it to the process, to the people, and to the animals to make good decisions?

The “data” that has been publicized doesn’t represent the origins of the 230 certified dogs that Department of Homeland Security utilizes for Urban Search and Rescue work when our nation is in crisis, for example. The data doesn’t represent the cost, time, money nor devotion to specific breeds, nor dogs in-general, who are exceptional in nature and require a nationwide network of individuals to help them find their right place in the world. The animal rights groups have a budget and an agenda, they have lobbyists and they are bullies. In addition to pets they would leave all working dogs (police, search, fire rescue, medical alert, therapy, assistance to name just a few) with no place to begin (reputable breeders; no place to go to transition (trainers, brokers); no place to be rescued (foster homes; breed rescue groups) and most likely only a place to end (euthanasia) without the onerous costs and regulations of the USDA being adopted by small breeders and others throughout the country. In any economy the finances required to comply with USDA licensure would be a mountain for individuals to climb. In this economy – it will be an impossibility for most.

What are the consequences? Dogs being dumped, euthanized, spayed or neutered in order to avoid financial burden. Loss of genetics. Loss of a certain kind of freedom that perhaps our citizens have taken for granted. And no impact on large commercial breeding operations who can afford to jump through the hoops, but are then forced to breed and sell in volume to make their bottom line. Which will lead to incredible loss for those of us who devote our “free time” to raising, training, handling, rescuing, and working DOGS; as well as all of those who are served by these dogs.

APHIS should start by properly enforcing the rules that have been on the books for 3 decades, generate more and better representative data with which to inform proposed change– and provide a more transparent and publicized period for public review and comment on proposed change.

Conduct a survey of households – Im sure it would be shocking to find out how many households have more than 4 dogs – are they all breeders? Would they have to become USDA licensed if they rescue and re-home other dogs, or have a litter of puppies for whatever reason they choose. Why is APHIS proposing to take away the freedom of responsible dog owners, enthusiasts, breeders, handlers – rather than enforcing regulations that are already on the books?

Politics has seeped into every crevice of our society – the health, welfare, and future of dogs and other species, and the people whose livelihoods depend upon them will all be impacted by the changes that APHIS adopts.

How will the proposed guidelines be enforced if they are subjective in nature and subject to interpretation?

How does one define a “breeding female”? Is it simply a female that has not been spayed? In any case the the age of 4 months is arbitrary.

I have a 12 week old puppy now – I will have NO idea how this dog is going to develop, whether or not he can work, never mind whether he is worthy of breeding until he is 2 years of age atleast. I already pay a “fine” in essence when I license my dogs each year. But it’s a small price to pay to do what we know is best for the dog. But maybe that silence and acceptance of the animal right’s agenda by so many of us is what has paved the way for the proposed sweeping changes and undue burdens that will be placed on citizens.

Under the proposed changes the fact that I currently have an intact female dog who is 18 months old and on her way to becoming certified; which will allow my currently certified 8 year old intact search dog to retire; along with my 6 year old intact certified detection dog; and my 5 year old intact female who was rescued simply because she deserved a better life – and my 12 week old puppy… well, that makes ME a target. It puts me in the crosshairs. Whether this is the intention of the proposed changes or not – this is the impact of how they are written.

APHIS has an absolute responsibility to do a better job than what is proposed.

The general public has the responsibility and ability to assist – but the discussion has to be broader and not let by animal “rights” groups.

Thank you for considering my comments.

Tara Wolcott

Chapel Hill, NC

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