The comment period for the U.S. Department of Agriculture proposed rule that would categorize many small/hobby breeders as commercial breeders and subject them to unnecessary licensing, regulation and inspections will close on August 15.
It is imperative that any breeder or owner who is concerned about this proposal provide comments to the USDA’s Animal and Plant Health Inspection Service (APHIS) before August 15. We also urge you to sign AKC’s petition to Protect Responsible Small Breeders. (Scroll down for details.)
AKC CONCERNS ABOUT THE PROPOSED RULE
The AKC shares the USDA’s concerns about substandard internet pet retailers. However, the current proposal is overly broad, difficult to enforce, and does little to address the actual wellbeing of animals sold.
The AKC believes that the USDA’s “one size fits all” proposal is not in the best interest of all dogs, responsible breeders, or puppy buyers. It is unreasonable and virtually impossible for many small hobby breeders to comply with the strict kennel engineering standards that were designed for large commercial operations. It would create unreasonable hardships that could threaten genetic diversity, the future of a vast number of responsible small hobby breeders, and the very existence of some rare breeds.
It would require all who own more than four “breeding females” and sell even one animal “sight unseen” to be regulated as a commercial breeder and be subject to federal commercial breeder licensing, regulation and inspections. The term “breeding female” is not defined, so it is unclear how USDA or even breeders themselves would determine who falls under these regulations. The term also includes multiple species (including cats, dogs, and other small mammals). This means, for example, that a person would not have to own more than four intact female dogs to be regulated for the sale of a single puppy sight unseen.
In many cases, geographic distance makes it difficult for a purchaser to personally visit or pick up a puppy at a breeder’s facility. Such scenarios are particularly common for breeders and fanciers of rare breeds and others who may be purchasing a second pet from the same breeder or already have an established relationship with a breeder. Requiring such individuals to comply with regulations designed for large commercial breeder/dealer facilities may not be appropriate.
The Regulatory Impact Analysis provided in the proposed rule vastly underestimates both the number of individuals who will be impacted and the expense to occasional breeders to establish commercial-level facilities.
WHAT YOU CAN DO
• Submit Comments Directly to USDA/APHIS by August 15 – You may submit comments online by clicking here. To view comments already submitted, click here. You may also 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
• Sign the AKC’s Petition by August 13 – If you have not already done so, visit http://www.akc.org/petition and join more than 69,000 people who have signed our online petition in support of responsible breeders.
Both actions are important in helping send a strong, clear message to APHIS on this issue. Direct comments will help educate the USDA regarding exactly how this proposal will impact responsible breeders, dog owners, and puppy buyers. The petition, which will be submitted with the AKC’s formal comments to the USDA, will demonstrate the immense number of people who are concerned about this issue.
AKC Government Relations (AKC GR) will provide more information as it becomes available. For more information, visit AKC’s USDA/APHIS Regulations Resource Page.
Further questions may be directed to AKC GR at (919) 816-3720 or firstname.lastname@example.org
Tue, August 7, 2012
by Matt Kremzar