USDA/APHIS RULE REMINDER: ONLY DAYS LEFT TO COMMENT!
August 11th, 2012 | 
Author: A reminder to help stop the pending legislation (USDA/APHIS) which will badly affect all small and hobby breeders. You can help:
**By August 13, please sign the AKC petition by control+click to follow link www.AKC.org/petition
**By August 15, 2012 Submit Written Comments to APHIS at: control+click to follow link below
http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001
ACTION NEEDED IMMEDIATELY: PLEASE HELP SMALL AND HOBBY BREEDERS
To my friends especially those who have enjoyed our Cavaliers over the years:
There is a ruling being considered to lump small and hobby breeders who do not make any living from breeding dogs with commercial breeders. This r**By August 13, please sign the AKC petition by control+click www.AKC.org/petition
**By August 15, 2012 Submit Written Comments to APHIS at: control+click to follow link below
http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001ule, if adopted by the USDA, would in effect stop ethical and reputable breeders like me from breeding and/or you from purchasing a purebred dog. It would not help stop the commercial and very substandard breeders from operating as there would not be enough USDA manpower to inspect and control. The rule would limit a small and hobby breeder to keeping only four breeding bitches where they be just puppies, retired unsprayed girls, co owned girls not even living on the property, and girls currently in the breeding program. At this point, Rattlebridge has only two girls to breed with three puppies waiting to hopefully be shown and/or bred but with no firm plans to do so. Show breeders “run on” or keep puppies up to two years or more waiting to see if they will make the show ring, pass all health checks, and be worthy of breeding. Puppies will count in the total of four. I am facing the end of my breeding/showing passion, but I would hate to see younger and very ethical breeders stopped from breeding. The Humane Society of the United States is pushing USDA/APHIS (the name of the actual legislation); the bottom line of the HSUS agenda is the elimination of all pet ownership. Please look at my blog to see entries concerning HSUS and animal rights activists. http://www.rattlebridge.com/blog Please help:
As usual I am late getting the word out but action is needed, but in short:
**By August 13, please sign the AKC petition by control+click www.AKC.org/petition
**By August 15, 2012 Submit Written Comments to APHIS at: control+click to follow link below
http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001
Explanation of United States Department of Agriculture’s (USDA)/ Animal and Plant Health Inspection Service (APHIS):
LEGISLATIVE ACTION ALERT USDA/APHIS
COMMENT PERIOD FOR APHIS PROPOSED
RULE EXTENDED TO AUGUST 15, 2012
Submit Written Comments to APHIS by August 15, 2012 at: control+click to follow link below
http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001
The newly proposed rule of USDA’s Animal and Plant Health Inspection Service (APHIS) jeopardizes your right to breed, sell and purchase purebred dogs. If adopted, it will adversely affect, directly or indirectly, virtually all breeders, show exhibitors and purchasers of purebred dogs.
Under the proposed Rule, all pet breeders with as few as five “breeding females” who sell an animal over the Internet or by phone or mail will be subject to rigorous federal licensing, inspection and animal care requirements under the Animal Welfare Act. Non-commercialized “hobby” breeders of purebred dogs were never intended to be regulated by this federal statute. APHIS’ proposed Rule will strip hobby breeders of their current exemption from stringent federal licensing requirements on the pretext of closing an alleged “loophole” for Internet pet sales.
Contrary to APHIS’ claim, the proposed Rule will not eliminate unscrupulous breeders or “puppy mills” with abusive practices who are driven by financial profit. Instead, it will force many responsible breeders, such as show or hobby breeders of purebred dogs who turn no profit, to downsize their breeding programs or close shop.
The federal animal care standards imposed by the APHIS Rules, which were originally designed for laboratory animals, are virtually impossible to meet in a home-based kennel environment. If adopted, the proposed Rule will subject hobby breeders to unreasonable costs and invasive home inspection requirements which ultimately will drive many responsible hobby breeders out of business. Do we need more Governmental regulation because of actual abuses, or is the APHIS proposal another veiled attempt by animal rights’ activists to eliminate pet breeding entirely?
View the proposed APHIS Rule at: control+click to follow link
AKC CONCERNS ABOUT THE PROPOSED RULE—Please Read:
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. 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.
WHAT YOU CAN DO:
STOP THE PROPOSED APHIS RULE IN FOUR EASY STEPS:
Step 1: Submit Written Comments to APHIS by August 15, 2012 at: control+click to follow link below
- http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001
- You may also 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
**Your written Comments are an important step to stop the proposed APHIS Rule.
APHIS is required to accept and respond to all timely submitted comments. Multiple comments on different points may be submitted. All comments should urge APHIS to withdraw its proposed Rule.
Note: When the rulemaking portal is opened, there are two options for electronic comment submission:
(1) Typing of comments in the box – which imposes a 20-minute time limit/
2,000 character limit. If this option is used to submit comments of less than 2,000 characters, we recommend that you paste comments prepared in separate draft form into the box to avoid the time limit; or
(2) Attachment of comments prepared in separate document format via
the “upload” option.
– The “attachment of document” option is recommended, as there
Is no time or character limitation.
Suggestions for comments and sample letters can be found at:
http://saova.org/APHIS_comments.html
http://www.thecavalrygroup.com/letter1.php
http://www.keepandshare.com/doc/4064127/the-cavalry-group-guidelines-for-making-comments-377k?da=y
Step 2: Sign the AKC Petition opposing the proposed APHIS Rule by August 13, 2012. (see below for AKC Concerns)
Signing AKC’s Petition is quick and easy. Read more here and sign the AKC Petition at www.AKC.org/petition
Step 3: Contact Your Federal Legislators
Congress determines the levels of funding for USDA and APHIS. Let your Congressional Representatives know that you oppose APHIS’ proposed Rule and that the proposal would drive many responsible hobby breeders out of business, without solving the problem of unregulated rogue, unscrupulous breeders. The proposed Rule would also adversely affect the economy and result in loss of job opportunities. Breeders of purebred dogs and related dog events substantially contribute to the economy and create jobs. For example, in 2011, AKC sanctioned dog events alone generated over $1 Billion dollars in national revenue.
“The Cavalry Group,” activists to alert the public against unnecessary and downright bad legislation has developed a sample letter and contact form to simply this process. Follow these links and take action with your federal legislators now:
To contact your congressional representatives clink here:
Step 4: Contact USDA Secretary Vilsack
2012 is a major election year. The head of USDA, Secretary of Agriculture Tom Vilsack, who is appointed by the President, should be informed that putting pet breeders out of business is not the way to turn this economy around. The Cavalry Group has prepared a sample letter and contact form to assist with submission of your comments to Secretary Vilsack. Follow this link and send a letter today:
http://www.thecavalrygroup.com/letter1php
We also urge you to sign AKC’s petition to Protect Responsible Small Breeders.
Further questions may be directed to AKC GR at (919) 816-3720 or doglaw@akc.org
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