# Regulate Unlicensed Puppy Mills - Please Sign!



## NOLA Standards (Apr 11, 2010)

Pinky,

I do remember your story, it was the worst way for a puppy buyer to learn the do's and don'ts and how tos of finding a good breeder and the education horribly came at a cost of the life of your pup.

I followed your postings and grieved with you.

You know now, the solution to Puppy Mills is EDUCATION - not Legislation. 

The proposed legislation will most certainly DAMAGE small breeders who raise their pups in their homes, while allowing puppy factories to simply license and continue.

I've posted a photo for you and others to consider.

Again...Education...not Legislation.


Tabatha
NOLA Standards


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## ArreauStandardPoodle (Sep 1, 2009)

If this gets passed in the US, it will surely make it's way to Canada, then the rest of the world. This will force small breeders to discontinue what they love to do, and open the door for even more puppy mills. The USDA regulates "commercial breeders" (their language) now. Doing a terrific job, aren't they???


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## Pinky (Jul 21, 2010)

Education is most definitely the best way to stop puppy mills. The way I understood it, this is specifically for online breeders. While small breeders do usually have websites, they don't just let anyone buy their puppy directly off their site. Or at least they shouldn't. 

"The rule would require large-scale breeding facilities that sell puppies sight-unseen over the Internet, by phone, or by mail to be licensed and regularly inspected for basic humane care standards."

I don't see how that applies to honest breeders running their small business. Please enlighten me! I've sent this to a lot of people. I certainly don't want to cause problems for people that are actually doing the right thing, but any little bit to help shut down puppy mills is a step in the right direction!


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## NOLA Standards (Apr 11, 2010)

On the surface it probably has a knee jerk "feel good" tone.

It will cause breeders - most of the breeders you know from PF in fact - to have to industrialize their kennel - no longer sell from their home - if they sell a pup "site unseen".

The language used is internet. 

And it was smart...it works to affect many...

But what it MEANS is if you don't come to my house and get your pup, I must be licensed if I have more than 4 breeding females.

Now...breeding females is not defined. (And how it makes sense to group those with 4 intact females with those who have HUNDREDS is still a whole LOT confusing to me...but apparently not to our USDA)

And there are multiple instances where a breeding female has been defined as a 6 month old.

I would never - and I don't know anyone who would - breed a female at 6 months old. (I don't know of any lines that come into season at 6 months old) Yet a pup that I will title/show and after testing possibly use for my line would "count" under this legislation.

Ultimately, if I wanted to continue my NOLA line, I would be forced to industrialize. And that, for those of us who invest in our dogs, is not feasible.

Apres Argent has posted some very informative links in the Showing area here.

PLEASE PLEASE PLEASE educate yourself about this bill.

SUGGESTED COMMENTS FOR APHIS PROPOSED RULE is a great start.

Speak out and speak up or hobby breeders will be extinct. :crying:

Tabatha
NOLA Standards


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## PonkiPoodles (Feb 25, 2009)

ArreauStandardPoodle said:


> If this gets passed in the US, it will surely make it's way to Canada, then the rest of the world. This will force small breeders to discontinue what they love to do, and open the door for even more puppy mills. The USDA regulates "commercial breeders" (their language) now. Doing a terrific job, aren't they???


Sorry to say, but this legislation is going to pass... the USDA is walking hand in hand with the HSUS and Peta on this one. 



> https://secure.humanesociety.org/site/Advocacy?cmd=display&page=UserAction&id=5493


Slowly but surely they will get rid of small breeders and then breeders in general. They are focusing their efforts and campaigns towards urging people to adopt instead of buying puppies and spending millions on commercials and their 'shelter pet projects' that say animals are dying because of people breeding.


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## mom24doggies (Mar 28, 2011)

This makes me sick...I love mutts, (I have a couple myself) rescuing, etc. but a world without gorgeous, well-bred, purebred dogs? Doesn't sound attractive at all. Thank you for the education.


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## Pinky (Jul 21, 2010)

Thanks, Nola, I read that article. Very insightful! How misleading was the article I posted?! I totally thought it was a wonderful way to stop puppy mills. I don't know why they would want to stop the GOOD breeders when they are the only ones ensuring that puppies are healthy and go to good homes! Not treating them as stock the way puppy mills are. What they should do is make internet puppy brokers illegal. There is absolutely no reason why a breeder (well, one that actually cares about their puppies) would need some massive company to find their pups homes. Or trust them to for that matter. 

I still have high hopes for this lawsuit by the Humane Society. While Purebred Breeders isn't the only puppy broker out there, it is definitely the largest and maybe this will help people see that they should never buy a puppy that way!


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## momtymztu (Mar 27, 2012)

ArreauStandardPoodle said:


> If this gets passed in the US, it will surely make it's way to Canada, then the rest of the world. This will force small breeders to discontinue what they love to do, and open the door for even more puppy mills. The USDA regulates "commercial breeders" (their language) now. Doing a terrific job, aren't they???


So true Arreau...If they were doing their jobs now they wouldn't need additional regulations to crack down on puppymills...that's nothing but an excuse to gain more control over ALL breeders of ALL animals and gain public support by claiming to be going after the "bad guys". 

When I had my pet store several years ago I took the steps to get USDA licensed so that I could do educational programs in schools and also it allowed me to have ferrets in the store. (FYI...It is illegal to breed ferrets in Virginia, they must be purchased from another state and sterilized...so I guess by goverment standards "ferret mills" are the only acceptable place to obtain them.) Anyway, in three and a half years I was inspected exactly once by USDA...before my license was granted. Now, I treated everything in the store like my babies at home, which of course meant I made no money and had to close down...but USDA had no way to know that because they never bothered to check!! 

So, to my point, how many of these currently USDA licensed commercial breeders are they even checking up on??? Probably not too many unless there are complants! I guess since they aren't doing anything to take care of the current problems, it makes great sense for them to create a few more issues for the people who actually do care about their animals.

Okay...off my soapbox, back to enjoying all of your beautiful poodles!!! (and not so patiently waiting for one of my own)


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## Pinky (Jul 21, 2010)

mom24doggies, your pups are BEYOND adorable! Omg just so cute!

ArreauStandardPoodle, your poodle is just too gorgeous! How is she doing?


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## NOLA Standards (Apr 11, 2010)

Oh...those that Rescue and Shelter will also be legislated.


And many have supported what seems to be legislation to - as the thread says - regulate unlicensed puppy mills.

(Not picking on you here, Pinky. Instead, Thank You, for getting me in gear and getting me to not only post here but to also go post on the USDA site AND sign the AKC petition).

I copied these links and info from Apres Argent's post in Showing.

Again, PLEASE motivate. Just click on the link and sign or post a comment. There are fact sheets you can read through.

(The HSUS has a fact sheet too. And the letter sounds really good. It does, however, NEGLECT to educate the public that they will be affecting breeders who have 4 breeding dogs and doing nothing to inhibit those who have 100s!!! :afraid




*The Humane Society of the United States Delivers More Than 60,000 Letters in Support of Proposed Rule to Regulate Internet Puppy Mills : The Humane Society of the United States*

*In comparing we have 37,000 people who signed the AKC petition and just 1800 comments on the USDA comments page. *


Join With the AKC to Protect Responsible Small Breeders - http://www.gopetition.com/petitions...ct-responsible-small-breeders/signatures.html


Urge Congress: Take Action to Support American Pet Breeders | The Cavalry Group

http://the-cavalry-group.rallycongr...-to-support-cavalry-group-mission/?src=widget


Only 1500 comments there and you can bet a good number of them are for the rule change.


Information here: USDA NOTICE OF RULEMAKING MAY 2012 - REGULATION OF RETAIL PET SELLERS
http://the-cavalry-group.rallycongr...-to-support-cavalry-group-mission/?src=widget


Comment suggestions here: SUGGESTED COMMENTS FOR APHIS PROPOSED RULE
http://saova.org/APHIS_comments.html



Tabatha
NOLA Standards


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## Pinky (Jul 21, 2010)

No offense taken, Nola! I'm just glad you were able to provide more info on the reality of the situation. In a perfect world, puppy mills wouldn't exist. Unfortunately that is not the case  It just breaks my heart that these monsters can get away with this!


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## lrkellly (Jan 6, 2012)

I don't agree that education is the only solution, there ought to be legislation with teeth to persecute puppy mill operators. It sounds like the legislation proposed is too broad, and will paradoxically create a situation where dogs will be treated worse than before - commercial operations for pets, disgusting. There should be no large-scale pet breeding industry.

If I was the AKC, instead of merely creating a petition to protest the proposed law, I would propose more effective legislation to protect small breeders but that persecutes puppy mills, and prevents the industrialization of the pet breeding industry.

They must have lawyers? If not, there must be some way for small breeders to organize and raise funds to have a lawyer draw up legislation that is not 'one size fits all'?... just a thought.


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## Carley's Mom (Oct 30, 2011)

The mills will be stopped only when they have no buyers. Educate everyone you know about where and how to get a dog. It starts with one person at a time.


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## lrkellly (Jan 6, 2012)

Carley's Mom said:


> The mills will be stopped only when they have no buyers. Educate everyone you know about where and how to get a dog. It starts with one person at a time.


I have to respectfully disagree with you on this... think about successful social movements throughout history - most need legislation, in addition to, education to be effective. A few glaring examples include segregation and child labour. Legislation was needed to end these practices, although many people were educated to view them as wrong. Changing the legislation required education first, but education alone would not have been enough to stop these practices.

The other problem is that puppy mill operators are expert tricksters who are able to fool people who might think they are doing the right thing and buying their puppies from a legitimate breeder. Unless legislation exists to throw them out of business for tricking people, this behaviour will continue. That being said, I still think people will buy from puppy mills if it is convenient and cost effective, especially if the puppy mills make it easy for people to feel ok about doing so.

Education is of course key, but those who are educated need to try to change the laws. That is what is going on now, except those who are trying to change the laws seem to be those who work in or support humane society shelters and they don't realize the inadvertent harm their legislation will cause. Obviously, though, you can see where they are coming from - they are educated in that they see the harms of puppy mills every day.

Education alone will not change the world, especially when there is money to be made or saved.


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## Ladywolfe (Jan 11, 2012)

I am confused. Please understand that I will never claim to be highly knowledgeable about small breeding programs.

But, can't small breeders avoid any threats of fines or even being classified under this legislation by continuing to house their breeding females in other homes, as many now do? They can retain three breeding females, correct? Would shared ownerships with additional females living elsewhere, or those that are sold with a breeding contract intact avoid this all?

And, irkelly, to paraphrase what you have said, it also is the case that puppy mill operators are expert tricksters who are able to fool people who might think they are doing the right thing and buying their puppies from a legitimate *rescue*.


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## PonkiPoodles (Feb 25, 2009)

So I was wondering... a friend of mine has 13 dogs (probably 11 of which are female)... she's not breeding any of them but none of them are spayed or neutered. She's not a breeder and never has been, but she did once have an accidental litter. How are they going to distinguish between people who are breeders and those who aren't!?! If I own 4 unaltered bitches does that automatically make me a "breeder"? And does this even influence back yard breeders at all? 
What scares me is when I think what might be next on the agenda... a legislation forcing us to spay and neuter our pets?


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## NOLA Standards (Apr 11, 2010)

Ok guys...

We are posting and discussing here....

But how many have gone to the websites and signed the petition?

Please please please do more than read the thread!

Click on the link above and stand up against this legisltation! :cheers2:

Lord, but I do sound like a cheerleader (or a used car salesman!).

It's just that we do not have the funds that HSUS or PETA have - and we never will - they are money making machines. (If you have never, you should go to HUMANEWATCH.ORG)

So what we can do we must do.

Now....


:cheers2: Go sign those petitions!


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## ArreauStandardPoodle (Sep 1, 2009)

AGREED!!! If everyone does not get involved, this will end up a nightmare that will affect everyone for a LONG time!!!


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## mom24doggies (Mar 28, 2011)

I signed the gopetition one, are there any others I can sign? I also posted it to my Facebook, and I will send it to as many people as I can.


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## peppersb (Jun 5, 2011)

lrkellly said:


> Education alone will not change the world, especially when there is money to be made or saved.


I totally agree with lrkelly. Education alone is not going to be enough to stop puppy mills. 

A neighbor of mine bought a puppy over the Internet a few years ago (a purebred dog, but not a poodle). She liked what she saw on the web site and liked what she heard when she spoke to the breeder on the phone. She is the kind of person who would never dream of buying from a pet store. When her dog was still very young, he was diagnosed with a progressive neurological disease. They spent thousands of dollars on vet bills and watched their dog decline to the point where he was having seizures daily (often several in one day). They finally had him euthanized when he was only three years old. My neighbor called the breeder to let them know about the health problem. The breeder had absolutely no interest in hearing about the health issue. That is when neighbor began to suspect that she had bought from a puppy mill. She was devastated. In a day and age when anyone can put up a web site and anyone can sound nice on the phone, I just don't think that education is enough.

As I understand it, puppy mills who sell to pet stores are regulated, but puppy mills who sell over the Internet are not. This legislation is designed to make sure that either the public (by coming to actually see the dogs) or the USDA are inspecting the breeders. Breeders with up to 4 intact females are exempt (this legislation increases that limit from 3 to 4), and the rule applies only to breeders who sell to people who do not come to see their dogs. 

I have not studied the specific wording of this legislation, and there may well be things about it that should be done differently, but I certainly think we need legistation in this area. Internet sales are the pet stores of the future (or of the present), and they need to be regulated IMO.


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## ArreauStandardPoodle (Sep 1, 2009)

peppersb...I never thought we would disagree, but here is my opinion. Because the world is a smaller place now with access to the internet, truth be told, most small breeders like myself sell most of their puppies to places far from home. Most of my puppies are shipped to the US or far reaches of Canada, with plans for several babies in the future going to Europe. Not many of these people can afford the time or the money to come here to check us out. It is up to prospective buyers to check references and do due diligence in knowing what they are being presented with is the truth. People are welcome to contact my vast list of references, and are also welcome, when I have a litter of puppies in my home, to Skype me any time to see the pups, have a tour of the house, see that conditions are clean, etc. It would be hard to lie in real time. This type of regulation is going to make is VERY difficult if not impossible for someone like me.


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## roulette (Feb 18, 2011)

Here is a link to a blog shared today on another forum. Seems to put the issues more into laymen/pet owners terms. Trust me, pups raised in responsible breeders' homes are MUCH better off than those raised under the USDA recommended conditions..socially, mentally, emotionally raised as pets from the moment they emerge from the embryonic sac. The discrimination in terms should be responsible breeder vs irresponsible breeders. Purchase contracts are essential to the welfare of the pup and the buyer, as is a before/after purchase vet visit. When purchasing/adopting a pet..please examine closely the contract supplied, which should outline guarantees of health and procedures in the worst case scenario of disability or death from genetic causes. Unfortunately, there are very unscrupulous breeders AND adopters out there..folks, do your research , esp before spending alot of money on a pup, or homing a pup with an unknown person...in essence, do what is BEST for the puppy. Anyway, here is the link..enjoy:

Why the Proposed APHIS Licensing Changes Will Screw Small Hobby Breeders and the People Who Buy Puppies from Them


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## ArreauStandardPoodle (Sep 1, 2009)

Thank you Roulette! Awesome link!


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## judyf (Aug 20, 2011)

Although I do not breed, I am thankful to those breeders who have in the past, and will hopefully in the future, provide me with purebred dogs and other animals. I realize the devastating effects this regulation will have on them, and am pleased to see the members of this forum step up and educate others on this matter.

We are faced with an uphill fight, as HSUS and other AR groups are well funded and highly organized. The fact that Sarah L. Conant, APHIS' chief enforcer, is a former HSUS attorney, makes our job all that much harder.


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## papoodles (Jun 27, 2011)

*I signed!*

Thank you, Nola.
Not only did I sign, but I also notified my Congressional representatives and senators that I strongly disagreed with this bill.

Outrageous intrusion..I am steaming mad.


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## Apres Argent (Aug 9, 2010)

*Part 1*

Permission Given to Forward

Lots of questions are flying out there about what the new rules are really about. I hope the following will help to clarify what is happening.

1. The definition of a retail pet store is being changed. This will require any animal sold as a pet (regardless of age; adoptions qualify as a sale) to allow the new owner an opportunity to inspect the premises. It does not matter how many animals you have OR if they are spayed/neutered. Every sale must have the purchaser on the property at least one time inspecting the premises and the animal to be purchased, prior to purchase.

a. The definition of a retail pet store (taken from the proposal from APHIS): ‘‘Retail pet stores’’ are not required to obtain a license under the AWA or comply with the AWA regulations and standards. Currently, anyone selling, at retail, the following animals for use as pets are considered retail pet stores: Dogs, cats, rabbits, guinea pigs, hamsters, gerbils, rats, mice, gophers, chinchilla, domestic ferrets, domestic farm animals, birds, and cold-blooded species.

b. The reasoning behind the rule (taken from the proposal from APHIS): Because the current definition of retail pet store includes all retail outlets, with the limited exceptions discussed above, retailers selling animals by any means, including remote sales conducted over the Internet or by mail, telephone, or any other means where the customers do not physically enter a physical premises, qualify as retail pet stores and are exempt from the licensing requirements, even if they lack the public oversight provided by customers entering their place of business.

Without that public oversight or licensing and inspections by APHIS, there is no assurance that animals sold at retail for use as pets are monitored for their health and humane treatment nationwide.

c. Buyers will be required to (taken from the proposal from APHIS): physically enter his or her [seller] place of business or residence in order to personally observe the animals available for sale prior to purchase and/or to take custody of the animals after purchase.

2. These are exemptions to the definition of a “retail pet store”:
a. If you have 4 or less intact females (inclusive of all species listed above), sell only those animals born and raised on your place – you don’t have to have people come to your property to pick up the animal.

i. There are several ways to come up with the count for the females:
1. All females on your premises
2. All females within your household
3. All females owned in concert with another

b. Sell breeding, hunting or security animals as they are not considered pets by APHIS

3. If you don’t meet the definition of “retail pet store” from 1 Or you don’t meet an exemption on 2, then you will have to be USDA licensed and inspected by APHIS to sell to the public.

Rescues (whether in private homes or kennels) will have to be inspected and licensed by APHIS unless every time they sell an animal, the new owner comes onto the premises where the animal is originating from at the initiation of purchase, just prior to purchase, to inspect the premises before purchasing the animal (definition of a retail pet store). They can’t qualify under the exemptions because the “rescue” animals are not born and raised on their property, nor are they being sold as breeding, hunting or security animals.

Shelters will meet the definition of the “retail pet store” as the purchaser will be on their property prior to each sale and will be able to inspect the premises. If an animal were to be shipped without the end purchaser inspecting the premises, they would automatically lose their definition of a “retail pet store” and have to USDA licensed and inspected by APHIS.

Breeders can be exempted from being USDA licensed and inspected IF they meet ONE of the following:

1. Definition of a “retail pet store” (see 1 above).

2. All the following have to be met:
a. Have less than 4 intact animal species listed in 1 above, 
b. all animals sold are born and raised on their property

3. Sell only animals for breeding, hunting or security.

If at any time a breeder who was exempted by the number of intact females, go over that number, they would have to comply with either the definition of a “retail pet store” or be inspected and licensed by APHIS.

If at any time a breeder who was exempted by selling only animals for breeding, hunting or security, sold an animal as a pet, they would have to comply with either the definition of a “retail pet store” or be inspected and licensed by APHIS.


People who sell reptiles to the public as pets are included in this rule (see cold-blooded species in 1a of definition of “retail pet store”).
Farmers who sell any farm animal as a pet are included in this rule (see domestic farm animal in 1a of definition of “retail pet store”.
.
This has nothing to do with numbers unless you are trying to qualify for an exemption.

CathyM 

Stop APHIS from taking away the right of small breeders from selling to the public quality pets. 
Veiw the proposed rules at:
Regulations.gov
Comment at:
Regulations.gov 
Sign the AKC petition to stop the APHIS rules and regulations: AKC Petition Site <http://www.gopetition.com/petitions/join-with-the-akc-to-protect-responsible-small-breeders.html>


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## Apres Argent (Aug 9, 2010)

*Part 2*

Permission Given to Forward



We have until July 16 to make comments at the APHIS site. To comment on the proposal visit the Federal eRulemaking Portal at <http://www.regulations.gov/#!submitComment;D=APHIS-2011-0003-0001> Regulations.gov 
(and keep in mind that you will only have 20 minutes to complete the page, so have what you want to say ready). I would suggest that you write up what you want to say on another program and then copy and paste it to the portal.

Mail comments to: Docket No. APHIS-2011-0003, Regulatory Analysis and Development PPD APHIS, Station 3A-03.8, 4700 River Road Unit 118, Riverdale MD 20737-1238.

Contact and let your Senator and Representative know what is happening.

To find your Congressman or Congresswoman:
<http://www.house.gov/> The United States House of Representatives · House.gov
<http://www.senate.gov/> U.S. Senate

A good form letter to begin with can be found here: The Cavalry Group 

Contact information for USDA Secretary Vilsack: U.S. Department of Agriculture, 1400 Independence Ave SW, Washington DC 20250. Information Hotline: 202-720-2791. You can also email the USDA directly and address it to Secretary Vilsack: U.S. Department of Agriculture <http://www.usda.gov/wps/portal/usda/usdahome?edeployment_action=changenav&navid=FEEDBACK_FORM> &navid=FEEDBACK_FORM 



You can visit the following sites for suggestions about what to write:

v American Kennel Club American Kennel Club - Contact AKC 

v The Cavalry Group The Cavalry Group 

v National Animal Interest Alliance http://www.naiaonline.org/​articles/article/​the-usda-proposed-rule-and-you 

v Pet Industry Joint Avisory Council (PIJAC) http://capwiz.com/pijac/​issues/alert/​?alertid=61421501 <http://capwiz.com/pijac/?issues/alert/??alertid=61421501&queueid=%5Bca?pwiz%3Aqueue_id%5D> &queueid=%5Bca​pwiz%3Aqueue_id%5D 

v Scottish Terrier Club of America Scottish Terrier Club of America <http://www.stca.biz/?index.php?option=com_content&vi?ew=article&id=1188%3Ausdaaphis?-breeder-licensing-rules-chang?es-comments-and-information&ca?tid=337%3Alegislative-news&Ite?mid=227> &vi​ew=article&id=1188%3Ausdaaphis​-breeder-licensing-rules-chang​es-comments-and-information&ca​tid=337%3Alegislative-news&Ite​mid=227 

v Sportsman's And Animal Owners' Voting Alliance (SAOVA)http://saovanews.blogspot.com/​2012/06/​call-to-action-comments-needed.​html 

v SAOVA's Suggested Comments http://saova.org/​APHIS_comments.html 

v Texas Outreach and Responsible Pet Owners Alliance http://​www.rpoatexasoutreach.org/​Action_Alerts/​E-NewsMsg-USDA_APHISproposedreg​s2012.pdf 

v United Kennel Club http://www.ukcdogs.com/​WebSite.nsf/WebPages/​ComDogRtsJuly12 

v Virginia Federation of Dog Clubs http://​www.virginiafederation.org/​will-it-affect-you

CathyM 

Stop APHIS from taking away the right of small breeders from selling to the public quality pets. 
Veiw the proposed rules at:
Regulations.gov
Comment at:
Regulations.gov 
Sign the AKC petition to stop the APHIS rules and regulations: AKC Petition Site <http://www.gopetition.com/petitions/join-with-the-akc-to-protect-responsible-small-breeders.html>


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## Apres Argent (Aug 9, 2010)

*From: The United States Working Dog Foundation (USWDF)**

Important Notice on APHIS Proposed Rule Change. NEW Fact Sheet Forthcoming.
Permission to cross-post this message *in it's entirety *granted.---

On Thu, Jun 21, 2012 at 3:16 PM, Tina Perriguey <[email protected]>wrote:

> As some of you reading this know already, the United States Working Dog
> Foundation (USWDF) is a recognized Stakeholder with USDA/APHIS, and I was
> on the initial "Stakeholder conference call" announcing APHIS's proposed
> rule change rescinding the "retail pet store" exemption.
>
> Those who have heard the audio, or read the transcript of that call - know
> that I voiced strenuous objections to this proposed rule change
> (hereinafter referred to as "Rule.")
>
> The United States Working Dog Foundation opposes this Rule. We have worked
> hard to bring to the attention of USDA/APHIS decision-makers how and why
> this Rule is fundamentally flawed. From Day One, we have communicated
> clearly - in numerous phone conversations, conference calls, and emails -
> the wide variety of ways in which this Rule would "sweep up in the net" -
> our nation's most highly ethical, loving and responsible breeders,
> trainers, handlers, and owners of top-quality working dogs - AND pet dogs.
>
> We have - in detailed emails - described the esoteric world of the working
> dog - and how (despite the fact that this was not their intent) this Rule
> absolutely DOES target the best of the best in the working dog world. We
> have also laid out how and why this Rule would wipe out large numbers of
> the producers of the elite working dogs we need to protect, serve and
> defend America.
>
> It is our recommendation that this proposed Rule be withdrawn completely.
> Additionally, we have repeatedly stated the following to key public policy
> makers. If and when APHIS can demonstrate - with verifiable, measurable
> criteria - that there is a justification for this Rule - then TRUE subject
> matter expert Stakeholders must be involved in the rulemaking process from
> the very beginning.
>
> Additionally, we've shared with USDA/APHIS decision-makers our analysis of
> the APHIS Fact Sheet and the "Rule Summary" - and pointed out what we
> consider to be egregious omissions which - in our educated opinion - has
> resulted in a "60 Day Comment Period" so fundamentally flawed as to be
> worthless. How can Stakeholders and the American public comment on a
> federal agency regulatory change if they don't understand how it will
> affect them?
>
> To give APHIS credit where credit is due - I just received a phone call
> with some good news. It's not what we still recommend - which is that this
> Rule be withdrawn completely - but it is a move which we consider a good
> faith gesture (contingent upon the following being accompanied by an
> extension of the Comment Period).
>
> APHIS is re-writing their Fact Sheet on this Rule, and releasing a new
> version soon (hopefully by early next week at the latest) - which
> (according to what I've been told) will be a concerted effort to comply
> with transparency in the rulemaking process. In other words - APHIS has
> committed to an effort to be much more honest, and in-depth in their
> communication as to who will be affected by this Rule.
>
> I'm sure some of you are asking the logical question as you read this. The
> fact that they are acknowledging that the initial information presented was
> deficient means that the entire Comment Period up to now has been
> "lopsided" to say the least. Yes. I pointed this out, and stated that - at
> the very least - the 60 Day Comment Period absolutely MUST be extensively
> extended, pursuant to the release of the revised APHIS Fact Sheet.
>
> No guarantees of this were extended during the phone call, but we will
> continue to keep the pressure on - and it would be an utter sham for APHIS
> to release a new Fact Sheet "clarifying" critical facts on a proposed Rule
> which has enormous ramifications to our nation, without accompanying that
> release with an announcement that they are extending the Comment Period.
>
> Thanks to everyone in the Pet-Law Family for your dedication, and
> relentless work opposing this Mother of the Law of Unintended Consequences
> proposed APHIS Rule change.
>
> Your Friend in the Fight,
>
> *Tina Perriguey*
> *President, United States Working Dog Foundation (USWDF).*
> *America's K9 Bodyguard.*
> *
> *
> *The United States Working Dog Foundation (USWDF)*
> *is a research, education and policy institute*
> *which promotes and defends America's most cost-effective*
> *crime-fighting, terrorist-tracking, livestock-guarding,*
> *victim-rescuing, bomb-detecting, unconditional-love-providing heroes.*
> *www.uswdf.org*
> *(925) 899-8934*


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## Apres Argent (Aug 9, 2010)

*USDA and HSUS are working together*

Sorry for the lengthy posts but this is very important if you breed, plan to breed or simply would like to be able to purchase your next puppy from a QUALITY breeder who loves the breed and is not simply in "it" for the money! If this goes through most if not all small hobby and show/performance breeders will not continue to breed rather than move their dogs and raise their pups in a USDA kennel. This will also affect ALL rescues that charge a fee or ask for a donation. 
HSUS has collected 60,000 letters so far, we all have a chance to speak up and may not get another chance. Please go to the links above and comment on all! 


Several months ago The Dog Press did and article about USDA hiring an attorney who had been working with HSUS.


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## Apres Argent (Aug 9, 2010)

*And one more!*

New APHIS Rule Changes
The Start of the New APHIS Rule Changes?

The APHIS proposed rule changes of May 16, 2012 were brought on by:

1) A continuing struggle between animal rights groups (HSUS) & hobby dog breeders. In 2003, after a prolonged court battle, the Supreme Court would not hear a case that emphasized that the intent of the AWA (Animal Welfare Act) was to regulate wholesalers, not retail stores, and that APHIS was within their bounds to define home breeders as ‘retail stores.” The Animal Rights groups then introduced a series of bills in Congress to have those home breeders regulated, including the PUPS bill. 

2) A scathing USDA Office of the Inspector General (OIG) 2010 report on APHIS enforcement of the regulations of commercial dealers which increased inspections of commercial breeders, with emphasis on enforcement and monetary penalties rather than education & clarification of regulations.
The Result?

USDA/APHIS proposed rule changes that include retail breeders. Their rationale? Several hundred commercial breeders had found a ‘loophole” and were selling retail over the internet, rather than retaining their USDA license because of the increased enforcement and monetary penalties.
The Impact?

The results are these poorly constructed, over-reaching proposed rule changes.
Let's see if the proposed rule changes might affect you. . .

chart1

(Courtesy of the Virginia Federation of Dog Clubs & Breeders)

chart2

(Courtesy of the Tennessee Federation of Dog Clubs)
Additional Information about the APHIS Rule Changes

AKC Annoucement of APHIS Rule Changes

Summary of Proposed Rule Changes

Federal Register - Proposed Rules

Federal Register - Definition of Pet Store

APHIS Stakeholders Conference Call

APHIS Announcement

Cat Fanciers Announcement

NAIA Alert

SAOVA Alert

Retail Pet Sales Q&A from the USDA


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## roulette (Feb 18, 2011)

I believe I read today that the 60 day comment period had been extended due to protest (by maybe the Working Dog folks)? Still, time is wasting..don't put off any contacts over this bill. Call, write, and call again.. and thanks for doing so : )


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## Pinky (Jul 21, 2010)

lrkellly said:


> I don't agree that education is the only solution, there ought to be legislation with teeth to persecute puppy mill operators.


Exactly! While I do feel VERY strongly about educating the public about puppy mills and I do think it's the best way to put them out of business, I think legal repercussions for their actions is necessary! When I went through the ordeal with Charlie, someone on this forum worded it perfectly - "Puppy mills sell shattered dreams" and they do! At the end of the day we all have free will and choose to buy a puppy, whether knowing it came from a puppy mill or not, we chose to take on that responsibility and if the pup has issues due to coming from a puppy mill, then you do the best you can when in that situation. And then fight these monsters like hell. I will never stop fighting them for what they did to my poor Charlie, what they continue to do. These poor puppies and dogs that are being bred repeatedly have no choice, they have no voice. They are treating animals like trash for money. It's disgusting. I can't think of one person that would knowingly purchase from a puppy mill, and for that education is BEST. But do they just get to go out of business and go on to another shady way of making money? Absolutely not. They should be punished for their heartlessness and the pain they're inflicting on these animals.


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## Pinky (Jul 21, 2010)

ArreauStandardPoodle said:


> Because the world is a smaller place now with access to the internet, truth be told, most small breeders like myself sell most of their puppies to places far from home. Most of my puppies are shipped to the US or far reaches of Canada, with plans for several babies in the future going to Europe. Not many of these people can afford the time or the money to come here to check us out. It is up to prospective buyers to check references and do due diligence in knowing what they are being presented with is the truth. People are welcome to contact my vast list of references, and are also welcome, when I have a litter of puppies in my home, to Skype me any time to see the pups, have a tour of the house, see that conditions are clean, etc. It would be hard to lie in real time. This type of regulation is going to make is VERY difficult if not impossible for someone like me.


That's why I think maybe zoning in on online puppy brokers might be a better idea. Bc just as they can check your references and so on, you also get to know the buyer. I know you wouldn't just send your pups off to anyone the way that the puppy brokers do! This is literally the extent of their questions:

Breed:

Gender:

Name:

Address:

Phone:

As long as you have that, then they will find you a puppy and it is yours. When I got the dog I have now, the breeder wasn't just going to give me the puppy without knowing anything about me first. These online brokers do the exact opposite. Puppies aren't products, you can't just select a size and color and have it. A responsible breeder that sells online will provide everything that you do. Please don't think I am saying that breeders shouldn't be allowed to sell their pups online. I don't feel that way at all.


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## Ladywolfe (Jan 11, 2012)

Can anyone who has the full details tell me if breeders can avoid being affected by this legislation by...



> But, can't small breeders avoid any threats of fines or even being classified under this legislation by continuing to house their breeding females in other homes, as many now do? They can retain three breeding females, correct? Would shared ownerships with additional females living elsewhere, or those that are sold with a breeding contract intact avoid this all?


If this is the case, then wouldn't the only effect of this regulation upon reputable breeders be to limit them to how many females could live in their home....not cause them to have to change their facilities?

I am confused. And, if this is not going to effect reputable breeders, otherwise, would we really be at risk of losing diversity, etc?

I guess I am still confused.


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## outwest (May 1, 2011)

I did not read this whole thread but want to point to this blog that has some great points to consider with the proposed legislations. I don't think we should throw the baby out with the bathwater.  
Why the Proposed APHIS Licensing Changes Will Screw Small Hobby Breeders and the People Who Buy Puppies from Them 

I remember Charlies story well. It was incredibly sad and I am glad it helped to expose this issue. I only think we shouldn't go overboard regulating. Small breeders, who often produce the healthiest and best pets would be affected unfairly. That's my concern. They need to tweek the law a bit first. I think there is every good reason to get those puppies spread around the country. That increases diversity in all the areas, too.

I am not against the law in its entirety, but it needs to allow for dogs to be raised in the home because that is the very best place for them to be. It needs to allow for the puppies to interact with all different dogs for socialization. The law has problems, but I don't see why a person producing a litter couldn't be inspected and licensed, perhaps through their local spca, but the inspection needs to have common sense!


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## peppersb (Jun 5, 2011)

ArreauStandardPoodle said:


> peppersb...I never thought we would disagree, but here is my opinion. Because the world is a smaller place now with access to the internet, truth be told, most small breeders like myself sell most of their puppies to places far from home. Most of my puppies are shipped to the US or far reaches of Canada, with plans for several babies in the future going to Europe. Not many of these people can afford the time or the money to come here to check us out. It is up to prospective buyers to check references and do due diligence in knowing what they are being presented with is the truth. People are welcome to contact my vast list of references, and are also welcome, when I have a litter of puppies in my home, to Skype me any time to see the pups, have a tour of the house, see that conditions are clean, etc. It would be hard to lie in real time. This type of regulation is going to make is VERY difficult if not impossible for someone like me.


Arreau -- You are one of the best examples I know of a breeder who combines all the very best practices. You love your dogs, treat them like family members, select for heath, temperment, and conformation, do the health testing, and bring a wealth of experience and expertise to the whole process from selecting dogs for breeding to whelping to raising the pups to finding good homes and much much more. YOU are what is good about breeding. Laws should encourage people like you. We need more of people like you. 

I might be wrong about this. But my opinion (which certainly does not seem to be a very popular opinion) is (1) we need this kind of regulation to slow down the Internet puppy mill sales and (2) it is not going to significantly hurt breeders like you.

I won't take the time to elaborate on the need for regulating puppy mills who sell on the Internet. That seems to me to be an obvious need.

With regard to the second point (that this regulation will not hurt you), I wrote to the HSUS asking if this regulation would result in any additional costs for a breeder like you. I got this response:

"I think the important thing to remember here is that this rule provides oversight. It does not prevent breeders from continuing to breed. All it requires them to do (if they are not exempt) is get a USDA license (which only costs $75) and submit to an inspection. This particular breeder can still have puppies, keep more than 4 breeding females, and sell over the Internet, but she would be required to get a license and be inspected."

So, if a US breeder like you had only 4 intact females (which I think is what you have), the breeder would be exempt anyway. If she were to get a 5th female, then she'd have to get a $75 license and allow some inspector to come by and have a look. 

I worked for years in an industry that required licensing and I remember that every now and then someone would come by and take 10 minutes or so to walk through our office and write things on his clipboard. It was really not a big deal and we never got any negative feedback. I would think that an inspector would take a very quick look at your dogs, and would be assured that everything is just fine. 

I am very sorry if my opinions cause offense to you and others, especially you, Arreau! 

I am planning to be away for the weekend with no Internet access. Leaving tomorrow morning early. So I won't be able to pick up this thread until Monday. I am grateful that a variety of opinions can be expressed here.


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## ArreauStandardPoodle (Sep 1, 2009)

peppersb...you did not offend me at all! Thanks for your kind words.

I think we all need to go to the link provided earlier, which takes you to a Wind Hound page. She explains what all will be involved for breeders like me, if this regulations passes.

I have six intact girls, either as a full owner or co-owner, as well as an intact Whippet who will never be bred again. Does not matter. She is intact. So automatically, if I were American (and if this passes in the US, it is only a matter of time until something similar will be enacted here) I would not be exempt.

If it was as easy as paying a fee and being inspected, I would have no issue at all. BUT, according to the Wind Hound page, my puppies are NEVER, until after four months of age, to be in the presence of any canine other than their mother.

Every surface the animals come into contact with must be able to be FULLY saniitized...eliminates cuddling with a puppy on a bed, on a couch, on carpet....These are just a couple of examples of the power that will loom over breeders if this passes. I can almost guarantee, if we are forced to abide by all of this, the puppies we send to their new homes will not be the same as the puppies we are sending out now. Our puppies, if in my home, play with four dogs other than their Dam, and at Deb's they play with their Auntie and cousin. All of our puppies easily accept all other dogs. Will they if they can only be exposed to their Mother? I have no idea.

I would have to, as would one of my co-owners, lay out hundreds and hundreds of dollars to pour concrete, ashphalt or put paving stones everywhere the puppies will be, because grass cannot be sanitized. We would have to change our homes entirely so as not to allow the puppies to come into contact with any of the other dogs.

Seriously...the prospect of all of this will have tons of breeders throwing in the towel!


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## CharismaticMillie (Jun 16, 2010)

And when they come "take a look", what do they need to see in order for you to pass inspection? This needs to be clarified in the law. Will reputable hobby breeders need to make expensive housing upgrades for their dogs to appease USDA? Do we really want USDA governing "dog breeding" when they can hardly manage tasks at hand in a humane fashion? Do we really think this will stop puppy millers? 

At one time, a puppy mill law similar to this was proposed in my state and fought against for many of the same concerns shared. (Where did Missouri's 'puppy mill' debate go?) 

Back to the current bill...if this is intended to be for online puppy brokers, the law needs great revision so that it does not unintentionally force hobby/show breeders to abandon their love of raising healthy, well socialized pets.

Back to what Denise posted earlier...there are many terms that need clarification, in my mind.

What does 4 breeding females mean? If someone co-owns 2 bitches who live at other homes, has 2 breeding bitches in their own home, and has 2 puppy bitches (say one might end up being placed and one is hopefully going to stay as a show prospect), are they now in breach of the definition of "retail pet store" and need to be inspected? And as I said earlier, what will this inspection require?


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## outwest (May 1, 2011)

Yes, I see no issue with inspections and a small fee in order to breed. I do have an issue with the inspections. I bought a puppy once at 3/4 months old that had been raised on concrete. Yep, the puppy was healthy. Did I want a sterile puppy? NO! That puppy was afraid of grass! It took months to get it to poop on the grass instead of my lovely patio and would not do his duty on the grass his entire life if it was wet. 

The law has good intentions, but is severely flawed. To me, a well socialized puppy is right up there with a healthy puppy. We need to encourage people like Arreau. Otherwise we will all be buying patio pooping pups.


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## lrkellly (Jan 6, 2012)

This is all sooo bizarre! It seems like this legislation will only lead to the increased industrialization of pet breeding. Its so sad. Who wants to buy a puppy raised in a cage, on a slab of concrete ? 

It is really too bad that they are going about regulating puppy mills in this way, they should really be proposing legislation that makes industrial pet breeding illegal, period. Inspections of registered breeders would not be a bad idea either, as it could prevent abuse that occurs in some small breeding establishments (like backyard breeders...)

In any case, I am confused as to why the HSUS would want animals to be treated _less humanely _ than they are when raised in a loving home environment.

It sounds like the legislation needs a lot of work and a lot of exceptions need to be added (like having a litter of female puppies who will obviously be in-tact when they are born!). Perhaps, as well, the number of bitches allowed to home breeders needs to be increased. I wonder how they arrived at the number '4', and whether the number should have instead been based on square footage of one's home and acreage...

In the end, I hope as someone else mentioned, that the baby is not thrown out with the bathwater, and that effective legislation that banns the industrial production of pets is proposed and approved. Wishful thinking, I'm sure.


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## Ladywolfe (Jan 11, 2012)

Thank you for some of the clarification. I am with irkelly on this issue...don't want to see the baby out with the bath water, either.

I see that there is no clarification about ownership of breeding females located elsewhere? That basically answers the question.

It would seem that if this legislation were written being clearly non-applicable when these females were not all housed within the breeder's home; it would have no bearing on hobby breeders, and would be a moot point for them, individually. 

That still leaves a great deal of good accomplished regarding internet puppy mills.

I hate to say it, but sometimes I think that controls on registration would help just as much or more. Such as, not allowing a litter to be registered to a female who was too young. The records are there of dates, and it would discourage those who do it intentionally. If it was an accidental breeding, fine.......unplanned = no AKC/UKC registration, etc.


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## roulette (Feb 18, 2011)

AKC breeders are already required to comply with AKC inspections. If you suspect or have purchased a pup from a suspected "puppy-mill", please report it to the AKC. Point is, we have our own internal regulatory system in place, why pile the USDA on top of that? The expenses of rearing, testing, housing, and unpaid HOURS of research are all born by small breeders..not to mention vet, taxing, and licensing. This bill and inspection fees are unreasonable, not to mention unenforceable. There are animal abuse laws in place to suppress mass-production aspects of milling puppies, also puppy lemon laws, and scam/fraud laws to protect internet purchasers. The problem is that even those laws are difficult to enforce, why? Lack of personnel? Lack of funding? Geez, the USDA has never been able to even protect chickens or cattle from inhumane treatment, what makes anyone think this is any more than a slippery slope to what is basically, an extra "tax" on animal breeders. Throwing money at a problem does NOT solve it, enforcing present laws, and educating the general public will. I, personally, find this bill unacceptable... another load of misdirected rhetoric from folks who are anti-breeder. period.


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## roulette (Feb 18, 2011)

Sorry, meant to include this link:
American Kennel Club - Investigations and Inspections Department


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## ArreauStandardPoodle (Sep 1, 2009)

Ladywolfe said:


> Thank you for some of the clarification. I am with irkelly on this issue...don't want to see the baby out with the bath water, either.
> 
> I see that there is no clarification about ownership of breeding females located elsewhere? That basically answers the question.
> 
> ...


If one's name is on the registration of a bitch, and she is intact, regardless of where she lives or if you plan to breed her or not, she is part of the numbers which make you exempt or not exempt.


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## NOLA Standards (Apr 11, 2010)

PLEASE EDUCATE!



*Breeders who OWN 4 INTACT FEMALES (they could be 6 months old or 10 years old. One could be in CHINA and the rest could live at home but that EQUALS 4 OR MORE) WILL BE AFFECTED under this legislation.*

As Apres Argent noted:

_i. There are several ways to come up with the count for the females:
1. All females on your premises
2. All females within your household
3. All females owned in concert with another_


A piece of legislation...one that groups someone who owns 4 intact/breeding females with those who own 100s.... 

SMART

EFFECTIVE

and REALLY (ultimately) Concerned with improving breeding practices.

yeah.. right! _(in the event some did not get my sarcasm) _:alberteinstein:


There is NOT a baby in this particular bathwater legistlation.

PLEASE go to the links and speak out against this bill!

Do it now.

(easiest to go back one page and click on all the links AA posted for us!)


Tabatha
NOLA Standards


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## faerie (Mar 27, 2010)

i've signed the petition.


the path to helli s paved with good intentions. 

it sounds good if it does what it needs to do (legislate the bad guys), but in reality it will screw over the good guys. i'm battling a similar bill with my own business (i am a very small soap and body care manufacturer). ugh.


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## faerie (Mar 27, 2010)

is PETA lobbying for this?


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## LoveMyDogs (Jun 13, 2012)

ArreauStandardPoodle said:


> If this gets passed in the US, it will surely make it's way to Canada, then the rest of the world. This will force small breeders to discontinue what they love to do, and open the door for even more puppy mills. The USDA regulates "commercial breeders" (their language) now. Doing a terrific job, aren't they???


My Pepper came from a lady who owned a small home business called Poole's Poodles. Her name was Helen Poole and she bred a small number of poodles in her home. She was by no means a puppy mill. In fact, the way I found her was through a vet in Livingston, Texas who recommended her. He said she bred fine dogs and provided them excellent care.

I went out to visit her and she welcomed me into her home and showed me the facilities. I saw the cutest little pup in her home. I broke out crying because my darling Sophia of 12 years had just died 3 days earlier and I was really missing her. Helen decided to go ahead and sell me her little pup she was planning to keep. Pepper came from her last litter. She was not feeling her best and decided to quit "her hobby". 

To this day I get emails from her and send her pictures of Pepper. Of course when I was ready for my second little ball of love I called her for a recommendation. Helen directed me to Poodle Rescue Houston. That is where we got our little red headed boy Teddy. He is the poodle in my avatar. 

There will always be "bad" backyard breeders/puppy mills just like their are bad teachers, preachers, doctors, dentists...and every other kind of profession. A law won't stop the criminals. Yes, that is what I think bad breeders are....CRIMINALS of animal cruelty. 

It is a shame to see God's beautiful animals being abused for money. I agree with the rest of the people here. * Education is the key!* My darling Sophia came from a pet store. :ahhhhh: No rotten tomatoes please! * I didn't know any better* and my friends and family quickly clued me in! I never spend another penny again buying a dog that came from a puppy mill.


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## Apres Argent (Aug 9, 2010)

*Usda*



faerie said:


> is PETA lobbying for this?


Last year late fall The Dog Press did a story about HSUS former Attorney being hired by USDA!!!!??? 

This has not been well thought out nor is it funded. Something few think about is that this will stop kids doing 4H, rescues will also be affected because they charge a fee, agriculture and all farm and meat producers are next......

Everyone has a chance to voice opinions and concerns, I hope all are doing so before it is to late. The AKC petition will only count as one opinion no matter the number of signatures. Please make your comments to the USDA site also! 
APHIS - Washington Animal Watch 
Please ask friends and family to also comment, some attached pictures for posting elsewhere.......


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## faerie (Mar 27, 2010)

the same shizzle is happening in the cosmetics industry with a very well funded lobbiest organization trying to push through poorly thought out legislation which will screw over small businesses like mine. 

so i feel ya and hear ya and am trying to help pass the word on to help all ethical small breeders.


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## momtymztu (Mar 27, 2012)

NOLA Standards said:


> PLEASE EDUCATE!
> 
> 
> 
> ...



I just wanted to add one little side not here...and if I am reading the legislation incorrectly someone please correct me...

But, As I understand it the changes they are making effect various types of pet animals, not just dogs and cats...they include small mammals such as hamsters and rabbits, even reptiles. AND it is my understanding that the number of "breeding females" counts ALL females of ALL of those species COMBINED. So, under this amendment if you don't qualify as an exempt retail "pet store" (for instance, you at some point sell to someone via phone/internet and they can't come examine your facility themselves before the purchase) the USDA could count your 2 intact female dogs, your 1 intact female rabbit and your 1 intact female bearded dragon (can't say I've ever heard of a sterilized bearded dragon before) as "4 breeding females" and voila...you need a USDA license and then you have to comply with all their mandates which only industrialize the whole breeding process. 

(FYI Reptiles have NEVER been included in the USDA legislation before...to my knowledge. As someone else said, they can't even get the care of cows right...let alone the entire pet industry)


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## PammiPoodle (Jul 16, 2011)

ArreauStandardPoodle said:


> If it was as easy as paying a fee and being inspected, I would have no issue at all. BUT, according to the Wind Hound page, my puppies are NEVER, until after four months of age, to be in the presence of any canine other than their mother.
> 
> Every surface the animals come into contact with must be able to be FULLY saniitized...eliminates cuddling with a puppy on a bed, on a couch, on carpet....



This brought tears to my eyes. Who the he!! makes these rules!? Why are so many people - with power, no less - so ignorant of what dogs need and deserve in their lives?!! Ugh, the whole topic of puppy mills makes me sick. I signed the petition and I'll be spreading the word. Education and legislation are both important, this is simply NOT the legislation we need.


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## cheleann (Jul 15, 2012)

*Helen Poole (Breeder)*

Hello! I was just reading through the thread, and came across LoveMyDogs comment about Helen Poole and I couldn't help but reply. I actually purchased a puppy from her in 2003. He is a registered AKC Poodle!

Troubles










Let me add that he sheds, his ears stand up, and as of the date of this picture he hasn't needed a haircut in 6 months! 

Helen was a Very Nice Lady....But this is the AKC Poodle she sold us!


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## NOLA Standards (Apr 11, 2010)

The deadline to comment on the RIDICULOUS legislation proposed by APHIS has been extended.

That means if you have not already spoke out against this legislation, you still have time to protect responsible hobby breeders and fanciers.

Join With the AKC to Protect Responsible Small Breeders

and

Regulations.gov

and another

https://www.change.org/petitions/u-...dangers-rescues-responsible-breeders-and-more


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## NOLA Standards (Apr 11, 2010)

Food for thought...

Here is a photo of an USDA approved facilty.

Really!!!


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