# On behalf of all US dogs, I need your help!



## Yaddaluvpoodles (Mar 20, 2010)

Dear Poodle Forum Members,

There have been some brief threads regarding the USDA's proposed rule change. Yet people seemed to be lulled into complacency.

If this rule passes, it has far reaching and dire consequences. Please consider where you want to get your next poodle from and, even more importantlly, what options you want your children and grandchildren to have in the future. 

I am asking each one of you to please comment on the proposed rule on the USDA website. In addition, I am asking that each one of you reach out to 10 other people, family, friends, explain the impact that this will have on the future of our dogs in the USA.

I would like you to go to the USDA website and post your opposition to the proposed rule change:

Regulations.gov

Don't procrastinate. Do it NOW. Do it, for the love of our dogs.

PS, people not in the USA can comment also!

Darla


----------



## CT Girl (Nov 17, 2010)

Done. Thanks for posting this link.


----------



## Yaddaluvpoodles (Mar 20, 2010)

Two things:
First, Somehow the search option is giving me different numbers when I search. The first time was 161, then 2 and now.. 5600+ (yeah!). Even if the last number is correct, it's still a drop in the bucket.

I find myself with my chin on the floor, wondering how many people have truly considered what this regulation means, and that it's not just about breeder's/breeding. The fallout, ifpassed, will make an impact on nearly every dog born in the future in the USA as well as the lives of the people who own them.

Read here about the impact to disabled people:

Urgent: Your Help Is Needed! Guiding Golden

Again, I ask each of you, if you want to do something good today, please post your opposition to this proposed rule.

Thanks, Darla


----------



## LEUllman (Feb 1, 2010)

Please don't flame me -- I honestly want to understand.

The rule specifically exempts anyone with up to four breeding females from the new regulations. I'm pretty sure that would cover most if not all of the "good" breeders on this forum from whom I'd consider buying a pup.

Is four not enough? What would be the right number? What, exactly, is being objected to here? What additional amendments could/should be added to make things right?


----------



## Paragon (Feb 18, 2012)

LEUllman,

1)Have you thought about those of us that co-own dogs until testing is done, and a Championship attained? These dogs do not live in our homes, and are basically other people's dogs.

2)How about those of us that keep our girls and boys till they cross the rainbow bridge?... They can live quite awhile. 

3)We don't breed every heat, and the time before you have breeding it takes 2- 3 years before you start...

4)This will affect people who foster, volunteer for rescue, all dogs count. They do get sent across country at different times.

5)How about when someone who has had a pup before, what if you are at a dog show, and bring the pup, to ease travel time for the new owners. 

6) How many of us Ship our dogs? People with diverse pedigrees are harder to find all the time....

Any of these things put you under the radar for this new bill! Rescue organizations will have an awful time complying, as dogs are often shipped, to foster homes, by dog train... a ride by volunteers to the next volunteer, to get to the foster, or adoptive home! 

How can we properly socialize Service dogs if they must be kept on an imperveal suface(no carpet in the home), and kept away from all other dogs other than their mother!!!!


Take a read!!! Please support those of us who are trying to do the right thing for our breeds!

BTW LEUllman, I am not trying to be mean, I just want others reading this to understand what is at hand.

Paragon


----------



## CharismaticMillie (Jun 16, 2010)

LEUllman said:


> Please don't flame me -- I honestly want to understand.
> 
> The rule specifically exempts anyone with up to four breeding females from the new regulations. I'm pretty sure that would cover most if not all of the "good" breeders on this forum from whom I'd consider buying a pup.
> 
> Is four not enough? What would be the right number? What, exactly, is being objected to here? What additional amendments could/should be added to make things right?


"More than four intact females" includes co-ownerships/cases where the bitch lives in another home. Includes older, maturing puppies, and an intact bitch that might have been surrendered back to the breeder. 

Let's say a breeder has 1 intact bitch in her home. A second intact bitch is co-owned and living with the other owner. A recent litter produced 2 nice bitches, both are over 4 months now, and the breeder is waiting to decide which she will keep and which she will place. This breeder has her maximum 4 bitches. Unfortunately, she will no longer be able to sell any bitches on co-ownerships (will have to sell them outright!) or take back any pets that didn't work out, unless those pets are first spayed.

How is any reputable breeding program going to be able to maintain genetic diversity under these stipulations? To answer your question, 4 intact bitches is not enough for many reputable show/hobby breeders to continue to improve the breed and maintain genetic diversity.

Now, owning more than 4 intact bitches is only *one way* a breeder can end up having to either surrender breeding or sterilize/commercialize breeding. The other way is if at *any point* a buyer does not come to inspect the premises before buying a puppy.

I can almost guarantee that most of the "good" breeders you would consider buying from own, have owned, or will need to own at some point more than 4 intact bitches.


----------



## Yaddaluvpoodles (Mar 20, 2010)

LEUllman said:


> Please don't flame me -- I honestly want to understand.
> 
> No flaming is necessary! Questions are good. This proposed rule is one that slips in a bunch of stuff that looks really innocuous, but in fact is not.
> 
> ...


This proposed regulation is very dangerous. It jeopardizes the overall wellbeing of all dog breeds in the USA. While the insinuation is that it is for the health and welfare of dogs, what it does is forces most small hobby breeder's into quitting.. while at the same time, opening the doors to the large wholesale cage dog breeders who are already USDA regulated.

There is a lot of information circulating about this proposed rule change. I would encourage everyone who has questions not only to read the rule, but read the associated regulations. 


It is a modern day trojan horse and if it passes, our pet dogs, the quality of our pet dogs are in danger.

If this rule passes, it vanquishes most of the "good" breeder's.


----------



## Yaddaluvpoodles (Mar 20, 2010)

If anyone has questions about this, PLEASE, PLEASE ask!

It would be a whole lot better for people to ask now, then find out in a couple of years.. that there are no more good breeder's and the only dogs available are from mass breeding situations, kennel raised, but unsocialized with dogs other than their dam and littermates and possibly at higher risk of hip dysplasia due to the surfaces they were raised on.

For those who have an interest in service dogs, or believe that people should be able to acquire a service dog if they need one, please read this:

Urgent: Your Help Is Needed! Guiding Golden


----------



## Yaddaluvpoodles (Mar 20, 2010)

Another link that was just shared with me. Much better than I could write!

Washington Animal Watch: Why not just apply for a USDA license?


----------



## zyrcona (Jan 9, 2011)

Yaddaluvpoodles said:


> PS, people not in the USA can comment also!


If this is implemented, it will suck for people not in the USA also. If someone wants to import a dog from America for whatever reason, they will either have to go to America in person to get it and spend large amounts of money on flights and accommodation, or make do with a dog that has lived all its life in some kind of concrete-floored pig-sty and never interacted with an adult dog asides from its dam. Because of rabies import restrictions, most pups will be pushing four months by the time they have received the correct vaccines and paperwork for export. A four-month old who has never been inside a normal house nor seen an adult dog asides from its mother is going to be an emotional train-wreck. It's not good for dogs, it's not good for owners, and it's not good for diversity.


----------



## judyf (Aug 20, 2011)

Thanks, Yadda, for posting his thread. I submitted my comments a week or so ago. Although I do not breed, I understand the threat this misguided legislation poses to those of us who enjoy then purebred dog hobby.

I joined the fight against the AR groups over twenty years ago, first against those who would have regulated aviculture out of existence, then, after a period of burnout, against the threats to the pet trade in general. It never ends. Although I have vastly scaled back my activism, I won't quit the fight.

Thanks to all of you in the forefront of the fight. And thanks to all who provide support and encouragement from the sidelines. I wish I were able to do more.


----------



## Sookster (Apr 11, 2011)

For those who aren't sure what to say or where to start, this website was posted on a facebook group that I'm a member of: 

SUGGESTED COMMENTS FOR APHIS PROPOSED RULE


----------



## LEUllman (Feb 1, 2010)

Okay, thanks to this thread I've begun to get educated, and what I've learned disturbs me. I'm a firm believer in following the money, and after some quick internet research, I've yet to sniff out the money trail here. Here's what I want to know:


Who stands to gain from passage of these rules?
What organizations lobbied for this legislation? (Was the USHS involved?)
Who actually wrote the rules being proposed?
Who "advised" the rule-making committee?

Finally, how come I have not seen nor heard anything about this in the mainstream media or blogosphere? Never mind, foolish question.


----------



## roulette (Feb 18, 2011)

This is getting ridiculous! I sign at USDA, (I signed the AKC petition weeks ago, which now has over 48,000 sigs) and the USDA site will NOT allow the "submit" button to submit my comment! No wonder yaddaluv gets differing #s on the submissions. Also, just to note..shortly after I signed the AKC petition, I got audited by my state revenue cabinet. Probably not directly related, but I suspect another push-back on small breeders. When I called State Revenue and asked how my audit notice came about, the rep said "from internet ads". I have one ad on puppyfind, only 3 weeks old.. so I suspect they may be trolling elsewhere? Although I have pursued compliance with state sales tax remission in the past..never were any available cabinet employees able to give me clear paperwork to remit. Anxious to put this behind me, and surely don't mind remitting sales tax on pups sold in state..but it's beginning to feel like a general "squeeze" driven by who? Are there any links to what the AKC is doing for us? any feedback on the petition, anyone to report to us how this fight will play out in the long run? I feel voiceless in an overbearingly loud crowd of folks who have labeled all breeders as irresponsible. What else can we do? (esp since usda won't "let" me submit my comment)


----------



## SnorPuddel (Jul 8, 2010)

I submitted my comment and I got my confirmation as well !

*Thank you for submitting a comment on the following Proposed Rule:
Animal Welfare; Retail Pet Stores and Licensing Exemptions

Agency: APHIS
Document ID: APHIS-2011-0003-0001
Your Comment Tracking Number: 8107f0c8 *


----------



## annadee (May 15, 2012)

I won't lie, I'm kind of confused of exactly what this new law is proposing. Is there some stricter guidelines for breeders? I want to make a comment, but I don't fully understand what it's about.

Okay, I read over the proposed comments, and have a better understanding now. I guess I just needed it to be explained in simpler language. I signed now, I hope this law isn't passed!


----------



## annadee (May 15, 2012)

This issue is really starting to worry me, do you know what date is it that they would implement this rule? I really hope it doesn't pass, there are so many amazing breeders in the US. This is so not right. Not right at all.


----------



## Apres Argent (Aug 9, 2010)

Who stands to gain from passage of these rules?
What organizations lobbied for this legislation? (Was the USHS involved?)
Who actually wrote the rules being proposed?
Who "advised" the rule-making committee?

It is very interesting that about 2 years ago HSUS said they would place people within our Government agencies and they would begin promoting their agenda from within. A bit more than a year ago USDA hired a HSUS former attorney! 

Please also write your Senators and Congressmen, they do not have a clue about this rule change!


----------



## LEUllman (Feb 1, 2010)

Apres Argent said:


> Who stands to gain from passage of these rules?
> What organizations lobbied for this legislation? (Was the USHS involved?)
> Who actually wrote the rules being proposed?
> Who "advised" the rule-making committee?
> ...


Ah, things now become clearer. (For those of you who don't know about the HSUS, the youtube video is exactly correct about the goals of this radical "Animal Rights" -- not Animal Welfare, big difference -- organization.) As I suspected, there's big-money politics behind this. The best hope for defeating it is to get coverage in the mainstream media. Are there any organizations mobilized to defeat these rules?


----------



## roulette (Feb 18, 2011)

Here's a link to AKC resources and answers to this breeder regulating bill. 

USDA/APHIS Regulations Resource Page

Do what you can, write, call..a personal letter or call (or appt) can be much more effective than some of the suggested form letters. If less than 50,000 signatures on AKC petition, we will lose, I'm afraid. Please just take an hour out of your busy day, and do SOMEthing to help. HSUS is a huge opponent, having a huge majority of the public opinion, and tons of money. There are also cool flyers and banners available at akc website to post on your webpage, FB page, or print for bulletin boards or dog events (4-H, whatever) The deadline is July 16th.


----------



## Apres Argent (Aug 9, 2010)

HSUS came up with 60,000 letters in favor just 3 days after the proposed rule was put up for comment. There are several groups working but no luck getting the comment period extended. The information on the USDA site is misleading and in my opinion just as deceptive as the advertising HSUS does with showing poor pups. This is about ending pets and farms are next! 

We have an opportunity to speak out we need to do it now!


----------



## annadee (May 15, 2012)

Apres Argent said:


> HSUS came up with 60,000 letters in favor just 3 days after the proposed rule was put up for comment. There are several groups working but no luck getting the comment period extended. The information on the USDA site is misleading and in my opinion just as deceptive as the advertising HSUS does with showing poor pups. This is about ending pets and farms are next!
> 
> We have an opportunity to speak out we need to do it now!


Do you really think there's a big chance we'll lose?


----------



## Apres Argent (Aug 9, 2010)

Do you really think there's a big chance we'll lose?  

Yes I think there is a good chance this will pass as written! There have been very few comments to oppose. If you use a form letter it does not count, the AKC petition only counts as one opposing comment. HSUS has already turned in 60,000 letters at last count. 

People do not understand and it is written very deceptively. We really need people commenting more than once! I have been posting this everyday and get barely a comment.......
I have very diverse Poodles some with the only known hapotype but rather than keep my poodles and raise my pups as lab animals I will spay and quit. Many others especially older breeders are already making arrangements to let go of co-owned dogs, fix or stop breeding altogether. 

We may have a slim chance but only if people get off their rears and start passing and encouraging everyone to oppose this invasion into our homes and protect their right to own a home raised socialized animal.


----------



## annadee (May 15, 2012)

Apres Argent said:


> Do you really think there's a big chance we'll lose?
> 
> Yes I think there is a good chance this will pass as written! There have been very few comments to oppose. If you use a form letter it does not count, the AKC petition only counts as one opposing comment. HSUS has already turned in 60,000 letters at last count.
> 
> ...


I have commented again, and I will comment every day until the deadline. We should not give up!!! I think we have a very good chance, considering not only dog breeders are affected, but I've seen rabbit breeders, cat breeders, and bird breeders all against this and trying to get people to comment. We cannot give in!!! 

Is it possible to see published comments, and how many there are up to date? Also, why is the AKC making a petition when it's only worth one body?


----------



## Paragon (Feb 18, 2012)

Apres Argent,

Please don't spay, or neuter your kids! We need the diversity! The haplotypes need to be kept. So far we can still keep them in Canada. We have regulations here that are bad, but nothing to compare to the nasty stuff you are dealing with! I pray it doesn't come here.... If need be, I would help you get your kids up here.

Paragon


----------



## zyrcona (Jan 9, 2011)

Apres Argent said:


> HSUS came up with 60,000 letters in favor just 3 days after the proposed rule was put up for comment. There are several groups working but no luck getting the comment period extended. The information on the USDA site is misleading and in my opinion just as deceptive as the advertising HSUS does with showing poor pups. This is about ending pets and farms are next!
> 
> We have an opportunity to speak out we need to do it now!


Just a suggestion, but have you tried contacting animal welfare groups in the US? The only American animal welfare public figure I'm aware of is Temple Grandin, so I don't know who else you have or what to suggest.

In my country animal rights extremists do not seem to have such a stranglehold (there was a slew of awful terrorist acts committed by a small cell against laboratory workers and breeders of lab animals several years back, but not much since), and I think it's because opponents have been quick to draw attention to animal welfare instead. 'Freedom Food' is a big thing here and it's popular for meat to be advertised with information about where it came from and how it was reared, and farmers and slaughtermen are interviewed on television and radio and their work portrayed in a positive light. If what goes on in farms and abattoirs is seen to be taboo and never exposed or discussed and there are problems with animal welfare that aren't being addressed, it provides holes for the animal rights brigade to exploit and give an air of credibility to their extremist ideas. It's essentially giving them a licence to ride roughshod and recruit people who would otherwise be in favour of animal welfare.

I can't help wondering if, when it's considered acceptable to chop puppies' ears off for non-veterinary reasons, and the government is trying to enforce a restrictive licensing law on the breeders of pet animals, whether this is in fact a stealth tax designed to top up coffers running dangerously low in a recession while appeasing a perceived public concern and without resorting to the politically unfavourable action of overtly increasing taxes.


----------



## annadee (May 15, 2012)

zyrcona said:


> Just a suggestion, but have you tried contacting animal welfare groups in the US? The only American animal welfare public figure I'm aware of is Temple Grandin, so I don't know who else you have or what to suggest.
> 
> In my country animal rights extremists do not seem to have such a stranglehold (there was a slew of awful terrorist acts committed by a small cell against laboratory workers and breeders of lab animals several years back, but not much since), and I think it's because opponents have been quick to draw attention to animal welfare instead. 'Freedom Food' is a big thing here and it's popular for meat to be advertised with information about where it came from and how it was reared, and farmers and slaughtermen are interviewed on television and radio and their work portrayed in a positive light. If what goes on in farms and abattoirs is seen to be taboo and never exposed or discussed and there are problems with animal welfare that aren't being addressed, it provides holes for the animal rights brigade to exploit and give an air of credibility to their extremist ideas. It's essentially giving them a licence to ride roughshod and recruit people who would otherwise be in favour of animal welfare.
> 
> I can't help wondering if, when it's considered acceptable to chop puppies' ears off for non-veterinary reasons, and the government is trying to enforce a restrictive licensing law on the breeders of pet animals, whether this is in fact a stealth tax designed to top up coffers running dangerously low in a recession while appeasing a perceived public concern and without resorting to the politically unfavourable action of overtly increasing taxes.


That is a good point. Whatever the case may be, we have to try. I'm not an American, but I think it's a good idea for Americans to contact animal welfare groups. Hopefully someone thought of such an idea by now.


----------



## Yaddaluvpoodles (Mar 20, 2010)

annadee said:


> Do you really think there's a big chance we'll lose?



Yup. And if this rule goes through, the only options I see for people in the United States to get a puppy in the future will be these:

1) Import (don't know how long that will last, there are also proposed rules.. again.. making it tougher to ship pets)
2) From a puppy mill (if this proposed rule goes through it will eliminate the majority of responsible breeders, leaving only those who sell massive amounts of pups, enough to pay for all of the required shelters, and who don't have any concerns about cage/kennel raising pups in relative isolation from dogs other than littermates/siblings)
3)the next door neighbor who lets their unspayed bitch run the neighborhood and gives all the pups away at the earliest convience to whomever will take them and who knows little to nothing about puppy rearing.
4)from an animal shelter.. and I anticpate that many will close their doors, not due to a decrease in the number of animals who are in need of help, but if this rule passes, I anticipate seeing a whole lot of owners who end up with unsocialized commercially raised pups who simply don't adjust well to a family/home situation, problems with house breaking.. etc. Shelters and rescues can only do so much. Most responsible breeder's will take their pups back if something goes wrong. Commercial breeder's do not. Things are going to get really ugly for shelters if this goes through.

As for those people who need service dogs.. good luck with that.


----------



## Yaddaluvpoodles (Mar 20, 2010)

Paragon said:


> Apres Argent,
> 
> Please don't spay, or neuter your kids! We need the diversity! The haplotypes need to be kept. So far we can still keep them in Canada. We have regulations here that are bad, but nothing to compare to the nasty stuff you are dealing with! I pray it doesn't come here.... If need be, I would help you get your kids up here.
> 
> Paragon


Not Apres Argent, speaking for myself, 
It doesn't seem that the males are a problem, so from the male side of the pedigree, we are okay for a while.. and the boys can be collected and frozen (sperm). My poodles are my whole life. I live for them, because of them, everything I do is motivated by them. If this proposed rule does pass, I can only hope that there is enough time granted, so that pups with rare genetics can be placed outside of the USA for the sake of the breed (s). That is yet another valid point of why this rule is a problem. It has dire consequences as far as losing genetics in already inbred breeds.

I have heard from some breeder's who are simply planning on retiring, others who are looking for places to live outside of the USA. Someone asked me today "whatever happened to the land of the free and the home of the brave?" Someone else made a comment about the "American's being held hostage by animal rights terrorists". I've talked to many breeder's who are terrified, not because they are doing anything wrong. These are not mass producing commercial breeders, these are hobby breeder's who work full time, who do stuff with their dogs, their dogs are family members, but they breed a litter every year or two. They are terrified. That's wrong... we shouldn't have to be afraid because we live with/love our dogs. But that's just my unasked for 2 cents worth.


----------



## Yaddaluvpoodles (Mar 20, 2010)

zyrcona said:


> I can't help wondering if, when it's considered acceptable to chop puppies' ears off for non-veterinary reasons, and the government is trying to enforce a restrictive licensing law on the breeders of pet animals, whether this is in fact a stealth tax designed to top up coffers running dangerously low in a recession while appeasing a perceived public concern and without resorting to the politically unfavourable action of overtly increasing taxes.


This won't be topping off any coffers. I can't name a single poodle breeder who I am personally acquainted with who can a)afford to comply with the regulations and b) who would be willing to comply. Most consider the requirements for the conditions the dogs/pups are kept under as cruel and inhumane. This rule has nothing to do with protection the well being of the animals who fall under it and everything to do with control. Also, if you follow the money trail, well it will eliminate the huge bulk of the breeder's, leaving behind only the commercial breeders, who's priority is making a buck, not the well being of the dogs are the breed.


----------



## zyrcona (Jan 9, 2011)

Yaddaluvpoodles said:


> This won't be topping off any coffers.


Well, I still argue that it will be. By forcing out breeders who are operating as small businesses they are making a gap in the market that can only be filled by more factory farm breeders. They make money from licensing and enforcing these dog factories.

And of course this is anti-welfare, but I suspect a lot of people who are looking at the document with not much understanding or consideration are interpreting it to be about improving welfare. If you don't know what's involved in breeding, or what the inspectors of factory dog farms actually inspect for, it looks like a positive thing whereby people with a lot of bitches have to submit to more stringent laws. The majority of the public don't understand the precise implications so it's picking on an easy target and makes the government look good to most of its people.

It needs real animal welfare people to stand up and explain why it is bad for animal welfare. The important part is not the stuff written in the document, but the stuff written elsewhere about what the licensed facility it's proposing actually involves. In the rules for the inspections there is a lot of stuff about only allowing animals to be in contact with washable surfaces. This could be interpreted to mean that they are not allowed a bed or a blanket to lie on. The thought of a pregnant bitch having to sleep and give birth on a concrete floor is just horrific. :-(


----------



## zyrcona (Jan 9, 2011)

Here is a document relating to the actual licensed facility which the regulations refer to, so far as I can ascertain: http://www.aphis.usda.gov/animal_we... Consolidated Inspection Guide - Complete.pdf

This is one page of it that inspectors refer to specifically to dogs

CANINE CARE CHECKLIST
_____Daily observation of all dogs within kennel.
_____All dogs requiring veterinary care have been treated.
_____Veterinary records have been updated.
_____Outdated medications have been disposed of properly.
_____Attending veterinarian has made kennel inspection within 12 months.
_____All dogs have convenient access to feed and water.
_____All feed and water bowls have been cleaned and sanitized within last 2 
weeks.
_____All bags of feed and bedding are in tightly lidded containers.
_____All unopened bags of feed stored off of floor and away from walls.
_____All enclosures spot cleaned daily.
_____Areas behind and below enclosures have been cleaned as necessary.
_____All enclosures have been cleaned and sanitized within last 2 weeks. 
_____All surfaces in contact with the dogs are impervious to moisture.
_____Surfaces within enclosures are free of sharp points and edges.
_____Mesh floors of sufficient size to prevent feet from falling through.
_____Adequate floor space is provided for all dogs.
_____All dogs have a minimum of 6 inches headroom in enclosure.
_____Nursing bitches have additional space required for litter.
_____All dogs in outside kennels have necessary shelters.
_____All outside shelters have wind and rain breaks in place. 
_____All outside kennels have sufficient shade structures.
_____Temperature controlled areas are between 45-85 degrees F.
_____All animal areas within kennel are well ventilated.
_____Doors, flaps, gates, etc. are in good repair and operate properly.
_____All drains are functioning properly.
_____Pest control measures are in place as necessary.
_____Items not necessary for animal husbandry are not kept within kennel area.
_____Animal husbandry items are stored in proper areas within kennel.
_____All dogs and weaned puppies have an approved means of identification.
_____Records of dogs on hand have been updated and are accurate.

Some of these things (such as identification) are sensible, but most of them are completely inappropriate for dogs and the descriptions of pens and outside areas would be considered inhumane by most.

There are also other things mentioned: that you must have an 'exercise plan' for your dogs approved by your vet and that your vet must come to your 'facility' and inspect it once a year, and must also advise you on the humidity of your 'indoor housing'. Power cables are not allowed to be in reach of dogs, which would make it more or less impossible to keep dogs in the house if you were to fall under this legislation. It also suggests that you must have facilities to separate your dogs if one of them is infected with a contagious disease.

Probably more, but PDF has got stuck and will no longer load with scroll bar half way down.


----------



## annadee (May 15, 2012)

This is so frightening. You can bet that if this kind of thing happens in Canada, I will be importing dogs from Europe. There's no way in hell I'm buying from pet stores, ever, even if it means never owning a dog again. It's not right.


----------



## annadee (May 15, 2012)

Commented again today. We really need more AKC signatures!!!


----------



## PonkiPoodles (Feb 25, 2009)

The HSUS is fighting with the USDA on this one. I'm not sure how much the AKC will be able to do in preventing the passing on this.

According to the article on the HSUS page they claim that:



> Most recently, AKC has been lobbying breeders to oppose a proposed U.S. Department of Agriculture rule that would regulate Internet puppy sellers under the federal Animal Welfare Act. AKC's chair described the regulations as "onerous," even though the proposal includes *exemptions for breeders with fewer than five breeding female dogs as well as breeders who sell only to buyers they meet in person*.


Full article here: http://www.humanesociety.org/news/press_releases/2012/07/akc_puppy_mills_070912.htm

The aweful thing is that most people who read these articles are people who want to do good in the world but have no idea what goes on in the world of breeding dogs or showing dogs so of course they suck everything up like honey and make descisions based on what they are told instead of researching and finding out for themselves. 

These organizations are only interested in how much money they can make and when it comes to the true wellbeing of animals they'll point the finger and tell you how many animals are dying because you bought a puppy.


----------



## annadee (May 15, 2012)

Yes, they can't do much, but considering there are so many other animal groups fighting against this, I think that everyone combined can really show that there are a lot of knowledgeable people against this! Dog breeds are only one of the many animals affected. And wasn't it four female dogs, not five? Where did they get the five from?


----------



## Sookster (Apr 11, 2011)

Someone mentioned some banners that the AKC has, but I can't find them. If anyone knows where they are located and could point me to them, I would love to put them up on my website.


----------



## roulette (Feb 18, 2011)

American Kennel Club - AKC Government Relations Resources

Scroll down to Canine legislation resources, labeled Cuddle This, Where Have all the Dogs Gone, etc.


----------



## PonkiPoodles (Feb 25, 2009)

annadee said:


> Yes, they can't do much, but considering there are so many other animal groups fighting against this, I think that everyone combined can really show that there are a lot of knowledgeable people against this! Dog breeds are only one of the many animals affected. And wasn't it four female dogs, not five? Where did they get the five from?


Well it says _fewer_ than five. So my assumption is if you have five you are not included in the exemptions, thus four will be your limit.


----------



## annadee (May 15, 2012)

PonkiPoodles said:


> Well it says _fewer_ than five. So my assumption is if you have five you are not included in the exemptions, thus four will be your limit.


Ooo, right, didn't realize the fewer! Silly me.


----------



## annadee (May 15, 2012)

Well, the AKC signatures hit 54,000. That may not help, but it's still nice to see how many dog lovers are fighting against this new rule. When we all come together we can do great things. Hope it makes a difference.


----------



## Apres Argent (Aug 9, 2010)

I was browsing through the comments and came upon this one. If you ever thought that these people are not for real then this should make you a believer. We are fighting fanatics every bit as dangerous as the Taliban, if not worse.


Document Subtype: Public Comment
Status: Posted
Received Date: June 22 2012, at 12:00 AM Eastern Daylight Time
Date Posted: June 25 2012, at 12:00 AM Eastern Daylight Time
Comment Start Date: May 16 2012, at 12:00 AM Eastern Daylight Time
Comment Due Date: July 16 2012, at 11:59 PM Eastern Daylight Time
Tracking Number: 810609fb
First Name: Markie
Middle Name: Helene
Last Name: Patterson
City: London
Country: United Kingdom
State or Province: England
Organization Name: Let There Be Peace for These Companions

Comment:
The HSUS animal rights goals requires the end to all breeding of all animals. We are 2% of the population and our goals will be met. Go Sarah L. Conant 1. Abolish by law all animal research. 2. Outlaw the use of animals for cosmetic and product testing, classroom demonstration and in weapons development. 3. Vegetarian meals should be made available at all public institutions, including schools. 4. Eliminate all animal agriculture. 5. No herbicides, pesticides or other agricultural chemicals. Outlaw predator control. 6. Transfer enforcement of animal welfare legislation away from the Department of Agriculture. 7. Eliminate fur ranching and the use of furs. 8. Prohibit hunting, trapping and fishing. 9. End the international trade in wildlife goods. 10. Stop any further breeding of companion animals, including purebred dogs and cats. Spaying and neutering should be subsidized by state and municipal governments. Abolish commerce in animals for the pet trade. 11. End the use of animals in entertainment and sports. 12. Prohibit the Genetic Manipulation of Species(1). Make this rule change and we can fulfill our goals. It is better to be dead than suffer as a slave to humans.


----------



## zyrcona (Jan 9, 2011)

Apres Argent said:


> I was browsing through the comments and came upon this one. If you ever thought that these people are not for real then this should make you a believer. We are fighting fanatics every bit as dangerous as the Taliban, if not worse.


These people make my blood boil. All forms of terrorism/ activism or whatever other euphemism they call themselves are nothing more than different flavours of misanthropy. These people do not love animals, nor do they care about welfare; they simply hate people and the human race. That they worship some romantic unrealistic ideal of the environment and animals, which for some nonsensical reason they don't believe humans to be part of, is irrelevant.


----------



## Apres Argent (Aug 9, 2010)

It is very hard for people to believe! Because of your post I have been thinking, I do not think we have any agency that really protects the "welfare" of animals or for that matter people. Sure we have agency's that step in when things go very wrong but really nothing proactive.


----------



## LEUllman (Feb 1, 2010)

Apres Argent said:


> It is very hard for people to believe! Because of your post I have been thinking, I do not think we have any agency that really protects the "welfare" of animals or for that matter people. Sure we have agency's that step in when things go very wrong but really nothing proactive.


Sadly, it seems the pendulum has swung and we are now entering another phase in history where the real "golden rule" applies -- He who has the money, makes the rules. The HSUS has a LOT of money, and they smell blood here. Beau turns 3 on the 25th. I wonder where my next poodle will come from, a decade or so down the road?


----------



## annadee (May 15, 2012)

Apres Argent said:


> I was browsing through the comments and came upon this one. If you ever thought that these people are not for real then this should make you a believer. We are fighting fanatics every bit as dangerous as the Taliban, if not worse.
> 
> 
> Document Subtype: Public Comment
> ...


There is no way they can take that kind of comment as constructive criticism. This person sounds like a real whack job.


----------



## LEUllman (Feb 1, 2010)

HSUS = PETA in suits, with _very_ deep pockets. Both are "animal rights" organizations with radical agendas aimed at the "whack jobs," not "animal welfare" organizations like your local shelter. HSUS has raised huge sums by scamming people into believing they are supporting shelters and such. It's a disgrace.


----------



## zyrcona (Jan 9, 2011)

Apres Argent said:


> It is very hard for people to believe! Because of your post I have been thinking, I do not think we have any agency that really protects the "welfare" of animals or for that matter people. Sure we have agency's that step in when things go very wrong but really nothing proactive.


This organisation looks like one, and is American. Perhaps contact them and explain the issue, and try to raise awareness of them?:

AnimalScam | Animal Rights Is Not Animal Welfare

Temple Grandin (animal welfare in farming person, really practical, rational, humane individual):

Temple Grandin's Web Page

There is also an organisation in this country (don't know about others) called pro-test

Pro-Test: standing up for science

Animal welfare information for farmers:

Farm Animal Welfare Council

The people in the animal rights movements are deranged extremists and cannot be reasoned with. If you tried to talk to them about bottlenecks, genetic diversity, health testing, Volhard temperament tests, Wycliffe influence, dog breeds etc. they would reply that they were irrelevant and that the poodle breed, cows, sheep, all other breeds of all kinds of animals, and the humans who created them should be banned and go extinct as unnatural abominations.


----------



## roulette (Feb 18, 2011)

I call 'em "Teadoggers"..


----------



## papoodles (Jun 27, 2011)

*No luck submitting ...*

Yadda,
I am having the same problem.I am unable to submit my comments.I have tried it again and again. I will keep at it...


----------



## Apres Argent (Aug 9, 2010)

They attacked AKC yesterday and now this comes out! 

Humane Society Paying Big Money for Help in Closing Puppy Mills - KPTM FOX 42: Omaha News, Sports and Weather; kptm.com |


OMAHA (KPTM)-

The Humane Society of the United States reports that Iowa is one of the top 10 "puppy producing" states in the country, with many of those coming from puppy mills.

Breeders abuse their licensed right to breed by breeding too many dogs in unclean and abusive conditions.

The HSUS announced a new incentive that officials hope will encourage more people to keep an eye out for problem puppy mills: up to $5,000 for a tip that leads to an animal cruelty arrest and conviction.

Genae Stoops, co-owner of Hooves and Paws Rescue in Glenwood, IA said, "This is incredible, maybe we can shut down some of these puppy mills."


----------



## zyrcona (Jan 9, 2011)

Apres Argent said:


> up to $5,000 for a tip that leads to an animal cruelty arrest and conviction.


That doesn't sound right. :-( You should report someone who is mistreating animals for the welfare of the animals, not so you can buy a new 50-inch flatscreen television. This is just going to lead to a greed-fuelled network of Orwellian spies reporting that someone's dog has done a poo and they didn't clean it up immediately.

(Edit) also without meaning any disrespect to the public, often the public do not know enough about animal husbandry to understand the reason for something they are seeing. I once saw a man unload a sheep and a lamb from a trailer into a field. As the sheep started to walk away towards the other sheep in the field, the lamb ran back to the man and he kicked it to make it go after the sheep. The reason for this is that it is vital for the lamb's survival that it stays with its mother, and it needed to learn that the man was not some kind of safe refuge it could use instead. I have seen a decrepit old horse led calmly to a gate on a field by the woman who had bred it and cared for it all its life, so a slaughterman could shoot it in the head. From what I saw and my understanding of anatomy, I am convinced the horse died instantly and had no idea what was happening, but a great many people would only have seen an act of betrayal, and blood pouring out of the horse's head as it was hauled in an undignified manner onto a trailer, and would have considered it a work of inhumane barbarism. The general public cannot be counted on to have any legitimate understanding of what is involved in dog breeding.


----------



## papoodles (Jun 27, 2011)

*Success*

My comments finally went through- as did my husband's.
Apparently, I was too loquatious in voicing my outrage at the ramifications that this bill would visit on all the wonderful lbreeders.
All fixed


----------



## annadee (May 15, 2012)

Apres Argent said:


> They attacked AKC yesterday and now this comes out!
> 
> Humane Society Paying Big Money for Help in Closing Puppy Mills - KPTM FOX 42: Omaha News, Sports and Weather; kptm.com |
> 
> ...


Well, if their main goal was to shut down puppy mills, that'd be great. I'd think they're the best organization ever. But little do people realize that by them forcing hobby breeders to shut down will just mean more puppy mills...


----------



## annadee (May 15, 2012)

Commented again today. I'm so anxious to find out what they will decide.


----------



## Apres Argent (Aug 9, 2010)

HSUS is behind the USDA rule change, so all breeders will have to either be USDA licensed or have multiple visitors to their homes. They offer 5000.00 dollars for reports that lead to conviction. Don't you think this is just another means to the end? The goal of HSUS is no pets, no meat.......

I hope everyone is bringing these things and the actions of HSUS to the attention of all elected officials!


----------



## Poodlelvr (Mar 13, 2010)

I've posted. Hope it helped.


----------



## Sookster (Apr 11, 2011)

Dog Post Daily issued this article today. Sigh. 

U.S. Department of Agriculture Is Considering To Regulate More Dog Breeders and Sellers|DogPostDaily

What I don't think people understand is that it DOESN'T exclude hobby breeders, since most hobby breeders have more than 4 females.


----------



## annadee (May 15, 2012)

Sookster said:


> Dog Post Daily issued this article today. Sigh.
> 
> U.S. Department of Agriculture Is Considering To Regulate More Dog Breeders and Sellers|DogPostDaily
> 
> What I don't think people understand is that it DOESN'T exclude hobby breeders, since most hobby breeders have more than 4 females.


Yup. If the definition of 4 females was "four females that you currently breed" (and it'd be awesome if they gave a healthy age range, say from 2-6 years or something to ensure the female isn't too young or too old) rather then "any 4 females that you own which are breedable."

Seriously, if these people just asked responsible breeders and happy owners of what rules they'd suggest, I'm pretty sure they could come up with the best laws regarding how to stop puppy mills.


----------



## roulette (Feb 18, 2011)

I think it's a logistical boondoggle (get it? dog-gle?) to draw a line in the sand at # of breedable females..why not # of puppies produced, which would be a much more pinpointable method of excess?? Some breeds only have 1 or 2 pups per litter..so 4 females (bred yearly, say) could only produce 6-8 pups. And they're to be singled out as offensive, or requiring inspection and regulation? The whole thing is poorly written and not thought out at all-full of gray areas. The best I can hope for is that this proposal opens a dialog between breeders, and HS, and legislators that could result in a more a)enforceable, and b) legitimate proposal, or an agreement to channel animal welfare dollars to the animals truly in need. If it's just about money, really, small breeders don't have a voice..sad.


----------



## zyrcona (Jan 9, 2011)

In 2006, the slaughterhouses in the USA accepting equines (horses, ponies, donkeys, mules, etc.) were shut down due to public protest. As a consequence, unwanted equines are now abandoned to starve or transported large distances in highly stressful conditions to abattoirs in Mexico and Canada. The conditions in these abattoirs are often vastly inferior to the USA ones. It would have been far better for the welfare of the horses if it had been permitted to continue slaughtering them in the USA.

Fur farming was banned in the UK some time ago, and acts of vandalism and terrorism on the farms and fears of exotic species escaping into the environment have made it a risky business venture in most countries where it is still legal. As a result of this, the fur industry decamped to China where the animals are treated in truly appalling ways. If there is demand for a product, that demand will be met by someone, somehow. It would have been far better for the fur-bearing animals if high standards of welfare had instead been implemented and people who liked this kind of stuff had been encouraged to wear luxury furs from humanely reared animals.

People may mean well by passing these laws and putting up bans, but they do nothing to help animals. In trying to prevent something, they not only fail, but make the conditions for the animals worse.


----------



## Yaddaluvpoodles (Mar 20, 2010)

*Comment deadline has been extended.*

The USDA has decided to extend the time allowed for commenting for another 30 days.

https://s3.amazonaws.com/public-inspection.federalregister.gov/2012-17283.pdf


----------



## Sookster (Apr 11, 2011)

American Kennel Club - Highlights from the July 9-10, 2012 Meeting

Here's the AKC's announcement and comments on the extension. I've been spreading the word in any way possible and will continue to do so.


----------



## annadee (May 15, 2012)

Wooo, that's great!


----------



## Yaddaluvpoodles (Mar 20, 2010)

Can anyone access the comments for the USDA rule? I was not able to yesterday, nor so far today. It doesn't do a bit of good to extend the comment period if the comment site is down (well, can still write hard copies).

Anyone try? Site down? Is it just my computer?

Darla


----------



## annadee (May 15, 2012)

Yaddaluvpoodles said:


> Can anyone access the comments for the USDA rule? I was not able to yesterday, nor so far today. It doesn't do a bit of good to extend the comment period if the comment site is down (well, can still write hard copies).
> 
> Anyone try? Site down? Is it just my computer?
> 
> Darla


It's just taking mine awhile to load, but it works.


----------



## Yaddaluvpoodles (Mar 20, 2010)

annadee said:


> It's just taking mine awhile to load, but it works.


Hmmmm, mine loads very quickly to an "Oracle" site. I just tried out several links from different places, all get me the same results.

My computer has been checked and is clear of the DNS server changer. Anyone have any ideas what's going on?

Is anyone having similar problems?

Darla


----------



## Yaddaluvpoodles (Mar 20, 2010)

*Well worth a read!*

SUGGESTED COMMENTS FOR APHIS PROPOSED RULE

Darla


----------



## Leooonie (May 30, 2009)

I am in the UK. will I be able to make any impact on these regulations?


----------



## Yaddaluvpoodles (Mar 20, 2010)

Leooonie said:


> I am in the UK. will I be able to make any impact on these regulations?


By commenting and encouraging others to learn about the rule and comment as well.

It's not legislation, so it's not like voting. Anyone, anywhere can speak up and have input. 

Darla


----------



## annadee (May 15, 2012)

Commented again for like the 5th time now, I think. I hope it helps!


----------



## Yaddaluvpoodles (Mar 20, 2010)

I am able to access it from a different computer with no problems at all. I can't find anything wrong with my computer, however, it gets "hijacked" and won't go tothe regulations.gov page. I had taken a couple of days off of work specifically to focus on this issue and have lost much of that time... sad.

Every single comment helps. I just read a wonderful comment by a pet owner named Doloria Pap. Don't know who she is.. but she says things very well! Search the comments for it if you get a chance.

I also found an "Opposition" list. Disappointed, but not surprised, I do not see the Poodle Club of America anywhere on that list. 

APHIS PROPOSED RULE OPPOSITION LIST

Darla


----------



## annadee (May 15, 2012)

Yaddaluvpoodles said:


> I am able to access it from a different computer with no problems at all. I can't find anything wrong with my computer, however, it gets "hijacked" and won't go tothe regulations.gov page. I had taken a couple of days off of work specifically to focus on this issue and have lost much of that time... sad.
> 
> Every single comment helps. I just read a wonderful comment by a pet owner named Doloria Pap. Don't know who she is.. but she says things very well! Search the comments for it if you get a chance.
> 
> ...


Where can you see comments that other people posted?

Also, wow, that is a LONG list.


----------



## Yaddaluvpoodles (Mar 20, 2010)

annadee said:


> Where can you see comments that other people posted?


Go to this link:

Regulations.gov

Put this in the search bar:

APHIS-2011-0003


----------



## Yaddaluvpoodles (Mar 20, 2010)

If you do a search to see what is posted, when the results come up, you can search within those results.

I would encourage every pet owner here to take a peek and see whether or not their breeder has commented. If not, ask why not? 

There are a lot of things that make a good breeder. One of those things is standing up for the breed when it is in jeopardy.

There are a whole lot of breeder's who are too terrified of animal rights activists to comment.. or at least that's what they are telling me. That makes no sense at all.. kinda supports "ostrich thinking"-- if my head is buried in the sand and I can't see something, it's not there and it can't hurt me.

It's common knowledge who the breeder's are. That information is readily available. There is safety in numbers. The more who comment, the stronger we stand and the safer for future generations of our poodles. 

So, take a look, if your breeder's name isn't on their, please, contact them gently to make sure they are aware of this and then.. politely encourage them (remember, in many cases, they are already scared. Don't need to put pressure on from both sides!) to comment.

Darla


----------



## roulette (Feb 18, 2011)

Dangit! I just got a petition in my inbox sponsored by Change.org. The petition was written by a very young girl to "close the loophole that allows cruel puppymills". Doubtful she has even read or considered any of the proposal, but it came to me pumped full of bells and whistles to share on FB twitter, etc. Ya know what bugs me?? Almost anytime you speak with the owner of a rescued mixed breed dog (me included) , they always talk about "what" their dog is...Part this, and part that. Why the heck would they care if they don't respect the genetic consistency of a purebred. ARGH, this has been SO frustrating. Also, does my local Humane Society sponsored shelter receive anything from HSUS. I've volunteered there many times and donated plenty. Do I consider withdrawing my support if they support this bill?? Isn't it supposed to be about our mutual love of dogs? Do shelters understand how active most breeders are concerning dog rescue? I feel we are ALL being manipulated to the ends of HSUS and Wayne Pacelle..who has stated in no uncertain terms his end goal of No animals as pets. Very upsetting, I feel my hands are tied.


----------



## Apres Argent (Aug 9, 2010)

*The fox watching the hen house!*

Please continue to oppose the USDA rule change, we need everyone's help! 

Below is a comment copied from the USDA site. This is a group of Lawyers heavily involved in HSUS=PETA! This is the comment that was posted by them. Please post in your own words, canned comments will be ignored. 
Please cross post. 
Have no doubt the intention is no breeders if any animal. 
If you are wondering who ALDF is: Animal Legal Defense Fund. It is a group
of lawyers who support and endorse animal rights. A lot of them work for
HSUS/ASPCA OR donate man-hours for court cases to HSUS/ASPCA. They are an
extremely dangerous group of people who believe in their cause.

Read the whole comment here!
http://www.regulations.gov/contentS...09c3b3&disposition=attachment&contentType=pdf


A quote: 
Some
states have adopted such pet disclosure laws in recent years, specifically to provide
the customer with information to make an informed decision about their puppy
purchase. Such a disclosure regulation would add further teeth to APHIS’s
inspection regime at little or no cost to APHIS.
Private right of action provision with fee shifting provision. Creating a
private right of action for enforcement of the AWA would be another important and
significant step towards reducing the substantial number of breeders who the 2010
Audit determined flagrantly operate in violation of the AWA’s requirements.
Allowing private parties to bring causes of action to enforce the AWA would help
bolster the USDA’s own enforcement mechanisms. Thus, ALDF submits that the
USDA should formally request Congress to amend the AWA to provide such a
private right of action. The ALDF looks forward to the opportunity to work with
you to craft such proposed legislation that would facilitate your efforts to enforce the
AWA without further burdening the limited resources at your disposal for such
efforts.


----------



## Apres Argent (Aug 9, 2010)

*Aphis caught in losey’s legal lasso*

APHIS CAUGHT IN LOSEY’S LEGAL LASSO re: PROPOSED RULE

:aetsch:

Frank Losey throws a wide loop at USDA & APHIS, reining in the HSUS plan to hobble hobby and show breedersMr. Losey’s letter to APHIS (Animal and Plant Health Inspection Service), a branch of the USDA (United States Department Of Agriculture), is lengthy and legal. He is after all, an attorney who served as Director of Civil Law at the Pentagon and who is licensed to appear before the U.S. Supreme Court.



Read his appeal to APHIS. Frank Losey is fighting for our right to engage in the hobby of breeding WELLbred dogs. Only those who are in some way connected to or benefit from the commercial dog breeders, would in ANY way support ANY version of ANY legislation to regulate a hobby. Do not listen to anyone who tries to convince you that we should go along with this in order to have "input". It is NOT inevitable. It is outside of the regulatory scope of USDA-APHIS which should be spending its resources protecting our food supply. 



To "go along" with this is to be sucked into the "incremental” defeat which is in the political playbook used by HSUS and other animal “rights” groups.


----------



## roulette (Feb 18, 2011)

I saw Mr Losey's letter on another list this morning. My first thought was, "only 21 points?" It seems he is mostly addressing legal procedure being circumvented in the proposal. My second thought was, "at least it seems to give adequate grounds for legal appeal, if it does get rushed through". Any thought as to why he didn't address other various vague assumptions in the entire document? So glad to have this guy on our side! Thanks to ALL who have continued to pursue support through various lists and groups, together we are stronger, and the dogs are better off!


----------



## papoodles (Jun 27, 2011)

*It's me*

Thank you for the compliment, Darla!
Dolores Pap


----------



## Yaddaluvpoodles (Mar 20, 2010)

@PaPoodles <Grin>

I had no idea! I shoulda guessed anything that well written came from a poodle person!

Darla


----------



## Yaddaluvpoodles (Mar 20, 2010)

@everyone: for those wanting something to write about, several of us have said that pups wouldn't be allowed to have contact with dogs other than their moms/littermates. That is already an active part of the current regulation. It can be found in the Code of Federal Regulations 9 Section 3.6 

Pay close attention to this sentence. 

Here it is in context: (this sounds really ugly.. but this is how our homes will be considered)

puppies under 4 months of age may not be housed in the same primary enclosure with adult dogs, other than the dam or foster dam. 

As our homes would be considered primary enclosures, I don't know where people having a hot bitch (Darla lingo for a bitch in season) who they aren't planning on breeding will put said bitch. 

So.. here it is.. the CURRENT regulation which does apply to.. well those it applies to.

(2) Compatibility. All dogs housed in the same primary enclosure must be
compatible, as determined by observation. Not more than 12 adult nonconditioned
dogs may be housed in the same primary enclosure. Bitches in heat may not be
housed in the same primary enclosure with sexually mature males, except for
breeding. Except when maintained in breeding colonies, bitches with litters may
not be housed in the same primary enclosure with other adult dogs, and puppies
under 4 months of age may not be housed in the same primary enclosure with adult
dogs, other than the dam or foster dam. Dogs with a vicious or aggressive
disposition must be housed separately.

Here is where the above paragraph comes from:
http://www.aphis.usda.gov/animal_welfare/downloads/awr/awr.pdf


----------



## Apres Argent (Aug 9, 2010)

*Please comment even if you already have!*

Very Important!

We need more comments! The site link is at the end of this email.
Please read. NO WONDER EVERYONE I KNOW IS OUT OF SORTS!
Is this Russia or what!

This description of a conference call will give you an idea of what is going on with USDA.

Please take time to go to the site again AND make a comment!

Fw: Conference Call Report with USDA Re: APHIS Rule on 8-7-12

----- Forwarded Message -----


TX-RPOA E-News
>From RPOA Texas Outreach and
Responsible Pet Owners Alliance
Crossposting is encouraged.
August 8, 2012

Deadline for USDA Comments was extended to August 15, 2012. RPOA urges
everyone to request withdrawal of this massive overreach by the federal
government! Pets don't grow on trees and HSUS continues to push their
"Meatless and Petless" Agenda in the U.S.
.......................................................
By Terry Martin:
MY REPORT ON 8/6 CONFERENCE CALL WITH USDA RE: APHIS RULE
on Tuesday, August 7, 2012

As you all probably know I was on the conference call yesterday (8/6) with
the USDA and the Animal Agriculture Alliance. I was told there were 122
people on that call. There should have been hundreds, but won't go there.
It was conducted as a question and answer of course about the proposed APHIS
rule that we are fighting against. I have waited a day to report on it as I
am not sure exactly what I got from it. What I write here are my
impressions and if anyone else on the call has anything to add, please do.

For positives, it was at the least a chance to get a feel for where these
people are coming from. I did definitely get the impression that they are
very aware of what we are writing in comments, and also the impression they
are just a bit confused, uneasy. But I wouldn't get too overly satisfied
with that feeling - they have the POWER in the end. I would just say our
comments are not just being ignored. They reiterated some things I have
tried to get across about writing comments.

1 Form letters are only considered one time. Letters that simply state the
author is for or against the rule are not considered - they want reasons.

2 This is not a numbers game. It does not matter how many pros and cons
they get - it is the content of the letters that is being considered. They
said every letter is read (obviously by many people) and I believe the law
requires them to do that.

3 Since we were not allowed to comment but only ask questions about the rule
and the faq sheet they continually said, "put that in a comment on the
site".
They want to hear why the rule is a problem and why the rule is not going to
do good for animals and buyers.

Who was on the call? Some people never said anything and they did not take
any kind of formal roll call. Sheila someone was there from AKC but did not
ask questions that I remember. Frank Losey was there and asked quite a few
very good questions. Rob Hurd, Michael Glass, Alice Harrington were the
ones who asked questions who I know from facebook.

They began with asking for agriculture related questions since this was who
they were meeting with. There were quite a few questions about the
"domestic farm animals" wording in the rule, questions about
farmers/ranchers who raise a pet breed but also have livestock and will the
inspectors have problems with their livestock who are nearby if they are
inspecting the other part of their operation. I got the impression that
they did NOT get the answers they were looking for in any concrete
way...especially as to why they are included in this rule in the first place
when there are other parts of the USDA that cover livestock. They kept
referring to aimals for fur or food not being covered. I asked about
horses, ponies, donkeys - no answer.

I believe there were more dog people on there than anything else - at least
who spoke. Since this rule appears to be very much aimed toward us, that
was not surprising. The APHIS reps harped on the two things below and
were continually questioned about them - often with no answer other than
"write a comment".

1 The first was the "face to face" transaction that they have decided must
happen. If you have read the proposed rule and then the faq sheet, they
changed their tune between one and the other. In my opinion this is a BIG
one we should hit on in comments!

Originally in regard to what they call "internet sales" but would cover any
sale where the dog is shipped or delivered they say in their document, "As a
result, customers of these businesses are often unable to enter the
retailer's
place of business to observe the animals before taking it home. Thus APHIS
believes that they lack sufficient public oversight to ensure the humane
treatment and care of these animals."

In their recent fact sheet they changed this to say, "Pet animal retailers
who sell their animals to their customers in face to face transactions at a
location other than their own premises are subject to some degree of public
oversight and therefore are not the focus of this proposal and would not
need to obtain a license."

Whoa! First they want the buyer to oversee our premises and how the animals
are treated and now we can sell puppies in a WalMart parking lot (that exact
question was asked on the call) or from the back of a pickup at a flea
market? That is "some degree of public oversight"?

They had no answers that I can recollect on that one other than insisting
the face to face meeting allowed the owner to see the puppy.

2 The definition of "breeding female". I do have a bit of transcript on
that one:

Terry - breeding females - how determined?

Rushin - "We have an exemption for whole-sale, what we currently regulate,
the 3 breeding females. And the way that is done we look at is capacity to
breed. That is a fact by fact determination BY THE INSPECTOR- so we will
look at things as age, physical condition of the dog, and etc etc. So just
because a dog is not spade there still are ..garbled examples??.. where a
dog is not considered, is not part of the breeding females."

Alice - Where are those listed?

Rushin - THERE IS NO LIST. [emphasis added]

Alice - There is no list. So we still have no way of knowing what a breeding
dog is or isn't.

Rushin - As I've said before - definitely submit that as a comment.

WOW. The inspectors are going to decide whether or not a female is a
"breeding female". In other words we don't know until they descend on us
whether we comply with this rule or not. I would suggest bombarding them
with comments on this one and explaining just why YOU don't consider a
female a breeding female until she is at least two years old and throw a
reference to OFA in there.

The rules constantly refer to dogs sold as PETS. I know a lot of us have
questioned this. I specifically asked if stockdogs such as cattle dogs and
sheep dogs (in case they didn't know what a stockdog is) and livestock
guarding dogs would count under the rule. They immediately said no, they
would be exempt. BUT I understand in the AWA definitions these dogs are NOT
considered working dogs. Someone else brought up competition show dogs and
I mentioned agility dogs - they hedged all over the place on those
questions.

3 The number of four breeding females. Several people tried to ask them
about (and were told this was a comment, not a question) dogs being shown,
dogs in training, dogs kept back as possible breeding stock but needing
health checks, evaluation etc. They didn't want to even answer this one but
I would say this needs to be hit hard in comments.

They have three choices after this comment period. They could decide not to
do it at all. They could revise it. IF they reword it they then can send
it out for comment again OR just implement it. They were hit also on where
does APHIS get the authority to regulate commerce - someone smarter than me
might want to check that out too.

Last impression - they are hell bent on doing this but are in some way are
considering the comments - they extended the comment time 30 days, have done
the fact sheet even though it just confuses the issue more, and allowed this
conference call. This last nine days they need to be hit hard with
arguments against this bill to show it is not going to accomplish anything
toward the welfare of animals and will harm buyers more than it will help
them. If you have had a puppy shipped, now is the time to explain why you
bought a puppy you could not purchase with a face to face transaction and
why it worked for you. Hit them with the number of four females and why
many intact females are not being bred. Comment here and comment again:
Regulations.gov


----------



## LEUllman (Feb 1, 2010)

Just curious - President Obama's Portugese Water Dog, Bo, is from a small breeder, Julie Parker of Valkyrie Farms. If these regulations go into effect, how would her breeding programs be affected? Would the Obama's be able to replace Bo down the road?

Has anyone written Mr. Obama to tell him that a government agency, in cahoots with special interest groups, might very well be about to put the breeder of his family's beloved dog out of business?


----------



## papoodles (Jun 27, 2011)

*Re: Docket No. APHIS–2011–0003*

You can also email Sec. of Agriculture Tom Vilsack directly to voice
any objections you might have to this onerous bill.
[email protected]


Interesting bit of information : His wife is running for Congress, and has accepted a $1,000 donation from HSUS.
Really? Conflict for her husband??

On the FEC page for the Humane Society Legislative Fund PAC for distributions:
CHRISTIE VILSACK FOR IOWA
P.O. BOX 641
AMES, Iowa 50010
5/16/2012
Political Contribution 1000.00


----------



## ar22dp (Oct 19, 2011)

Hi!

Im a bit confused(im from Sweden and lack proper english skills to fully understand the proposal).

As i understand it, in the US you can buy a puppy in a pet store? and this new proposition will make it harder to do this, with more government controlls? leading to higher prices?


//Alexander


----------

