For all breeders and buyers PLEASE submit your comments

[vneerland]

I assume all breeders and puppy buyers already know this but.....

There is a new USDA rule in the making, with the intent to prevent the sale of sick puppies to the public.
That's a good thing, right? Yes, BUT...
The way they are proposing the rule, it can possibly affect most DS breeders and even buyers.
The proposed USDA regulations would narrow the currently exempted definition of “retail pet store”
to mean that each buyer would have to physically enter the business or residence and observe animals
for sale prior to purchase and/or taking custody. How many of us travel to the breeder? With our small breed, it is not unusual at all to have a pup shipped long distance. This rule has the potential to take that right away from us, so that we can only buy our brindles at our corner store? That would be a horrible development for your already small breed.
So then go ahead and become USDA licenced, right? But that would mean meeting the requirements of the Animal Welfare Act, like separate food preparation areas, waterproof surfaces, floor drains, kennels. This would make it impossible for breeders to keep dogs in the home. Who should want a barn raised pup, vs one that grew up surrounded by their human family? What happened to the concept of imprinting and socialization?
Maybe we all think that it would not apply to us as a breeder, since we would never have 5 brood bitches. Really? The proposed rule only states 'intact' bitches, regardless of our intentions with that dog. What if you got a dog back that needs a new home? What if you never did spay that older bitch yet? What if there were some female pups that are still looking for their forever home? Who can be sure that that would never happen to them?

PLEASE read, and please take the time to submit comments, before. July 16.
And please spread the word.

http://www.ukcdogs.com/Web.nsf/News/Wil ... 12085215AM

[Choochi]

Who's brain child is this anyways?

[vneerland]

You would never believe if I said this was some government institutions idea of making things 'right', would you? (Is goverment any better in Canada?)

[Olie]

It`s funny how people have different opinions around the world.

I live in a very small country, it takes 10 hours max by car from one end to another. I`m not sure that`s relevant, but I guess it is. People here are encouraged to visit the kennel, even more than once, before buying a puppy. Meeting the breeder on a parking lot, having a puppy shipped and not meeting the parents is considered irresponsible and possibly encouraging for dog farmers. Responsible breeders never consider shipping a puppy unattended. People often travel abroad to get the dog etc.
This is how responsible, informed and educated buyers/owners/breeders do/think.

On the other hand, there are tons of back yard breeders, dog farmers, illegal import of sick puppies of non-existant but possibly popular breeds (i.e. "mini-maltese"), creaton of new breeds (bandog). Castration is considered "normal" for females for only maybe, last 10 years, but for males is still like "why`d you do that?!?" But I never heard of anyone got a puppy shipped, except a friend of min who wanted to import a japanese chin from USA (they are very rare, if any, here) and wanted to have it shipped by plane.

(Im not saying our way is better then yours, or right and wrong, just exchanging experiences)

[Dutchringgirl]

In a small country , I can see how that would work great. But ours is so large, that really makes that impossible. We have bought a few bassets from Ch breeders with out going to see the pup, we went by word of mouth from other show breeders that we knew. For the idea of weeding out the back yard hack breeders, Im not sure that would work as well in reality. What if someone kept a nice house / Kennel, but had poor quality dogs. Some people just dont know enough anyway to realize that its a hack breeder. What about adopting? I read the article but I dont remember if it refers to that. The pet stores are nothing but puppy mills.

[alspyce]

A petition you can sign through AKC, to help protect the rights of small, honest breeders:

http://www.gopetition.com/petitions/joi ... /sign.html

[vneerland]

It`s funny how people have different opinions around the world.

I live in a very small country, it takes 10 hours max by car from one end to another. I`m not sure that`s relevant, but I guess it is. People here are encouraged to visit the kennel, even more than once, before buying a puppy. Meeting the breeder on a parking lot, having a puppy shipped and not meeting the parents is considered irresponsible and possibly encouraging for dog farmers. Responsible breeders never consider shipping a puppy unattended. People often travel abroad to get the dog etc.
This is how responsible, informed and educated buyers/owners/breeders do/think.

I think it really is relevant where you are from, yes. If someone is not willing to drive a couple of hours to go see their future 'family member' for the next 10 to 15 years, you could argue that they might not be interested enough in the dog, and might not be 'worthy'. I would absolutely hope that someone who lives in the same state that I live in (Texas) would be willing to drive. However. That can already be a tall order. It takes a 12 hour trip, by car, pretty much non stop, keeping the speed limit, to go from north to south in this state alone, and about as long from east to west. You would have to agree that the State is the size of many a large country in Europe. And shipping a dog several states over, ads even more to the distance. Would you be willing or able to drive some 1200 miles, 2000 kilometers on way (!) to pick up a pup? Would you be able to spend that time (and money) on a road trip? What if you are sure that the best breeder for your dog lives that far away though? You have learned their breeding philosophy, you like the parents of your future pup and this is the combination you have your heart set on? Good pups do get shipped. After an (honest) breeder tells the buyer what the pup is all about, after sending pictures, descriptions and videos. And with a guarantee that if the pup is not a match with the intended new home, that they can send it back.
I guess you would have to envision the DS of your choice being in Greece. How many times can you go see it, if at all, before you buy? Or would you be willing to have it shipped, if you had a good feeling about the breeder?

On the other hand, there are tons of back yard breeders, dog farmers, illegal import of sick puppies of non-existant but possibly popular breeds (i.e. "mini-maltese"), creaton of new breeds (bandog). Castration is considered "normal" for females for only maybe, last 10 years, but for males is still like "why`d you do that?!?" But I never heard of anyone got a puppy shipped, except a friend of min who wanted to import a japanese chin from USA (they are very rare, if any, here) and wanted to have it shipped by plane.

DS's are also rather rare, on both sides of the ocean. I do understand that the concept of shipping is literally foreign to you. I lived in Europe too. Distances here are vastly different though. And to have breeder choice dictated by rules (of distance) that may be designed to weed out bad breeders, but that will hurt a lot good ones, does not seem to achieve the goal of animal welfare. Because like Dutchringgirl said: a decent facility does not make for good quality dogs. And being forced to raise pups according to USDA regulations means that they will be have to be banned to kennel buildings that meet specifications of drains, and non porous surfaces etc. What happens to the wonderful choice of raising pups in the house, surrounded by the smells and sounds and activity of the families that the dogs will hopefully go live in for the rest of their lives? When did well socialized and well loved pups become something that needs to be avoided?
How does it make sense that the rules would not apply if someone had less than 5 intact females, or if that breeder never shipped a pup?
BTW. Both the American Kennel club and the United Kennel club see the danger of this rule affecting many honest and good breeders. I agree that there is a need to stop puppy mills. But this is not the way/rule that will accomplish (just) that.

[vneerland]

Allow me to bump this topic. Time is running out. Breeders and buyers, please, take this seriously.
Alspyce provided an easy petition link above.
I copied some of the reasons why this is bad news below. I stole it from an even longer post, but if you can take the time to read it, you will understand why the rule needs to be opposed.

Important Considerations

* Hobby breeders do not breed their breeding females with the frequency estimated by the drafters of the proposed rule so the proposed threshold to maintain exemption is set way too low. Assuming that every breeding females who can have puppies will have puppies is incorrect when considering hobby dog breeders;

* Most hobby breeders wait until the health tests recommended for their breed have been complete, often waiting until their breeding females are 2 years of age or older before the first breeding;

* They don't breed their breeding females while they are competing in shows or trials, a period that often spans more than a year;

* Many keep their breeding females intact long after their breeding careers have ended, and maintain their breeding females until they die of old age, years during which they are capable of having puppies but will never be bred.

* Limiting the number of breeding females an exempt breeder can keep to a maximum of 4 is the wrong standard to impose. It is not the number of intact bitches owned but the welfare of the ones who actually have litters that should determine USDA's involvement. There are local and state laws governing ownership and cruelty.

* A threshold this low and so ambiguously defined will bring under regulation thousands of small scale, low-risk breeders, using up the resources needed to address the genuine problems cited in the OIG audit.

* The requirement that every dog sold by an exempt breeder should be one that was bred and raised on the property is onerous for small-scale hobby breeders, especially those who maintain rare breeds. This requirement guarantees that several thousand additional small, low-risk breeders will be brought under regulation, and could threaten the extinction of some rare breeds.

* Hobby breeders operate with a relatively small number of breeding females so they often work with other hobby breeders in order to maintain genetic diversity in their breeding programs. As part of this working partnership, they co-own dams with each other and they often take back puppies, some that they ultimately sell. Under the current proposal, a breeder, no matter how small the risk potential, would lose their exemption if they sold even one such puppy because it was not bred and raised on their property.

* Hobby breeders sometimes take a puppy in lieu of a fee for stud service and later sell that puppy. Such a breeder, no matter how small or how low the risk potential, would lose their exemption if they sold this puppy since it was not bred and raised on their property. This would bring even more small, low-risk breeders under federal regulation.

"Redefining a retail pet store so that it only includes those places of business or residence that each buyer physically enters in order to personally observe the animals available for sale prior to purchase and/or to take custody of the animals after purchase, and where only certain animals are sold or offered for sale, at retail for use as pets"
*would create a hardship for those consumers who cannot or do not want to travel to the breeders facility to take possession of their puppy in person;
* Would undermine the agency's expectation to exclude traditional retail pet stores and hobby breeders, which is expressed in the Regulatory Impact Analysis & Initial Regulatory Flexibility Analysis;
* Would undermine the agency's intent to concentrate their regulatory efforts on those facilities that present the greatest risk of noncompliance with the regulations by expanding coverage to thousands of small, low-risk breeders who;
* sell most of their puppies in ways that comply with the proposed requirement but sell an occasional puppy to a person who cannot, or does not want to come to their facility, often a repeat buyer who is familiar with the breeder, or someone who knows the breeder by reputation or referral, and executes a contract that satisfies their individual concerns;
* are engaged in a heritage breeding program aimed at preserving rare and endangered breeds, where so few litters are produced each year in the US, there is often great distance between the breeder and the person seeking a puppy of this particular breed. More than a third of all the breeds registered with the AKC, the largest US registry produced less than 50 litters last year, and there are registries devoted only to rare breeds;
* would needlessly lose their privacy through federal inspection of their homes,
* would be forced to impose industrial care standard on dogs who are currently treated as well cared for household pets, something that would not improve the welfare of their dogs in any way;
* would lose their exemption if they sold even one puppy remotely, even using methods such as magazines and referrals that were seen as providing an acceptable degree of public oversight prior to the advent of the Internet;

[felixone123]

signed!!

[vneerland]

Thank you Barbara!

[leih merigian]

Well, Judith, just color me ignorant, as I wasn't aware of this bill until I read your post. Thank you so much!

I am so glad I squeeked in by the deadline. I was able to write my congressman, and both senators, and also sign the petition...whew!

Sometimes you gotta wonder where these morons come from. I know they are well-intentioned, but my mind is constantly boggled by what some people think is a good idea (how about we sell some untraceable guns to Mexico, then try to trace them?).

I sure hope this particular bill bites the dust!!!

[vneerland]

Wow! Thank you Leih, and thanks to all those who have opposed the bill. It appears that the lobbying to get this adjusted has at least resulted in an extended deadline, or that is what I heard last night. Hopefully, more than that will come out of the relentless protests from our side, but it's a start. Keep it up, please. I am all in favor of putting a stop to puppy mills, but this is not the way to go about it.

[vneerland]

>From RPOA Texas Outreach and
Responsible Pet Owners Alliance
Crossposting is encouraged.
July 13, 2012

Hope springs eternal! Forget that it's Friday, the 13th! USDA/APHIS has
announced they are extending the deadline for comments until August 15th
regarding the proposed revision of their definition for "retail pet stores."
This definition now includes all retail pet sales from breeders' homes and
exempts these homebased breeders from USDA Licensing. RPOA is urging
everyone to contact their legislators and urge APHIS to "withdraw this
proposal" as USDA regulations can't be met in a home environment. This
source of well bred, well socialized pets (all species) in private homes
will be shut down.
RPOA received responses from Senators John Cornyn and Kay Bailey Hutchison
acknowledging receipt of our correspondence and said they will give them
consideration. There has been no response yet from Congressman Francisco
Canseco.

Tina Perriguey, President, United States Working Dog Foundation (USWDF),
mailto:TPerriguey%40GMail.com is circulating the email below now that their
involvement can be made public. The good news is that USWDF has been able
to speak directly with a Senior Adviser to USDA Secretary Tom Vilsack - not
an easy accomplishment. Thanks to everyone for your hard work and keep the
comments going in on a regular basis. We can win this!

Tina wrote:
RE: *Docket No. APHIS-2011-003 Proposed Rule.*

After several weeks of Stakeholder calls, private phone calls, and detailed
written correspondence with several individuals at APHIS - including Dr.
Gipson, Dr. Rushin, and Hallie Zimmers... I began to have serious concerns
that our message was not getting to the one man in the country with the
decision-making authority to do what needs to be done.

Consequently - on June 29th, the United States Working Dog Foundation
opened a dialogue with a Senior Adviser to USDA Secretary Tom Vilsack.

On July 5th, a Stakeholder Conference Call was held with this individual,
myself, Linda Kaim (USWDF Secretary and member of our Expert Advisory
Panel), Peggy Richter - USWDF Expert Advisory Panel member, Rebecca Blue,
Kevin Shea, Christine Jones, and Hallie Zimmers.

Many important areas of concern were covered in this call, and have been
explored in greater detail in written communications from the United States
Working Dog Foundation.

Pursuant to all of this (including our relentless requests that Secretary
Vilsack withdraw the proposed rule change completely) - we were informed
that the Public Comment Period would be extended.

I certainly don't want to imply that the United States Working Dog
Foundation takes full credit for this extension. As with all the fights
where we've stood shoulder-to-shoulder with our friends and colleagues in
the Pet-Law Family - this has been a team effort.

But I know that we have made great progress in a primary goal: *Ensuring
that Secretary Vilsack himself is fully apprised* of our many objections to
the proposed rule - and why in fact - the right thing to do is to withdraw
it completely.

Thank you - from the bottom of my heart - to everyone in the Pet-Law Family
for your tireless efforts, and your persuasive Comments. Please don't
relent now. It's time to pour it on in posting Comments.

USWDF asks that each Comment you post end with this statement. "I
respectfully request that Agriculture Secretary Tom Vilsack withdraw this
proposed rule completely."

Thanks. More details to follow. Just wanted to send a quick response to
your question.

*Tina Perriguey*
*President, United States Working Dog Foundation (USWDF).*

[Marjolein]

so there is a bit of hope?

[Dutchringgirl]

an exstension is good. Gives more time to quash this thing.

[GSDNanny]

Commented, signed and sent! I dont plan on breeding in the future but never know when I would want to import. Either way, we already have way too much government minding what they dont have a clue about. Heck they need to focus on their own backyard right now!!!

[leih merigian]

Whew!

Not over, but so much better than already done!

[alexis]

I'm not even remotely qualified to chime in on this issue, but I do deal with Federal rule makings in my job sometimes.

One thing to know is that policy makers give much more weight to the number of unique letters submitted than to the number of signatures on a petition or form letters sent in. So, if you want to make a difference in the final policy decision, take the time to add your personal story or take on the issue when writing a letter (even if you use the bones of an existing form letter). It's also helpful to give alternative suggestions to how they might accomplish the goal without causing the harms that would occur as a result of the proposed policy.

[leih merigian]

Good suggestions!

[Dutchringgirl]

Interesting Alexis, thanks for telling us that.