Tuesday, June 19, 2012

US Dept of Ag Changes to Animal Welfare Act

The USDA APHIS rule changes combined with successful Grey2K USA efforts will lead to the destruction and extinction of the greyhound breed.
The USDA APHIS has proposed changes to the regulations surrounding the definition of a 'retail pet store'. These changes will destroy responsible breeders, if passed, chances are that with few exceptions, most AKC greyhound breeders will be unable to comply with them and they will stop breeding. Then, if Grey2K USA is successful in abolishing greyhound racing, there will be few, if any, NGA bred greyhounds because most of those breeders will stop breeding. I ask you...

What will happen to the Greyhound breed?

Litter of AKC Greyhound Pups
It does not take a giant leap of the imagination to realize that our beloved breed, Greyhounds, will become extinct here in the United States.

Make no mistake, the proposed APHIS rule is heavily influenced by the Humane Society of the US (HSUS). Remember, the long term goal of HSUS is to outlaw all breeding of companion animals and to abolish all legitimate uses of those animals.

The proposed new USDA/APHIS rule and PUPS law would prevent most animals from being raised in a home and family setting. The Animal Welfare Act limits licensed breeders to only commercial/laboratory style settings.

Allow farmers, breeders, show competitors, hatcheries, working/service animal producers, shelters and rescues to choose any humane method that works for them, their animals and their goals.

 Please oppose PUPS legislation and the APHIS-2011-0003-0001 proposed rule, "Animal Welfare; Retail Pet Stores and Licensing Exemptions."
Everyone, who is involved with animals as companions, pets, working animals, etc., needs to send a note to the USDA APHIS.

We have talked to USDA officials and they tell us that form letters will count as ONE comment, not one comment per letter. They are not interested in a vote count -- they want thoughtful comments from breeders and purchasers of puppies.

The USDA has also stated that they cannot enforce this. This response drives me more than a little crazy. First, this country should not pass laws OR regulations that cannot be enforced but make criminals out of thousands of people. Second, it WILL be enforced sporadically -- every time a neighbor gets mad at a breeder, a puppy owner has a complaint, or an animal rights fanatics decides to pretend to be a puppy buyer to gather evidence against breeders. (And believe me, this happens.)

These are new regulations, not legislation. It is IMPERATIVE that everyone make a comment. To have any influence, people have to comment on the official site here:


These changes are a freekin' nightmare and they will destroy responsible breeders. If this is passed, the reality is that the only breeder from whom puppies will be available are those breeders like the Hunte Corporation.

Hmmm...  no pets or pets from the Hunt Corp?  That's one helluva decision that I hope I never have to make.

Yours in greyhounds....

18 comments:

  1. Last time I looked they were still breeding racing and coursing Greyhounds in Ireland, England and Australia, and the USDA has no jurisdiction there. While I agree that it would be better not to have the U.S. government poking its nose into so many aspects of our lives, including responsible hobby breeding of dogs, I think some of ya'll who oppose this proposed regulation hurt your credibility by making these dire, exaggerated sky-is-falling predictions about the real life effect of the regulation if it is put into effect. It speaks volumes to me that the most vocal opposition of this regulation comes from show breeders, many if not most of whom can hardly be considered "responsible" breeders by virtue of how they change and exaggerate the breeds to win in today's show ring.

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    1. John, unlike you, many people cannot afford to import dogs from foreign countries.

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    2. Dear John:
      The most vocal opposition to this regulation comes from the world of dogsport simply because those are the folks who are the most educated. I honestly don't know what your comment has to do with anything.
      Best,
      CJ Brennan

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    3. CJ -- I don't consider dog shows "dogsport"; they're "beauty" pageants having nothing to do with sport or athleticism.

      Elaine -- The proposed regulation won't keep anyone from breeding Greyhounds, here in the U.S.or elsewhere. It has nothing to do with the cost of importing Greyhounds. By the way, the cost of acquiring our British Greyhounds (including flying them here) was well less than the $2000 - $2500 I see these American hobby breeders advertise Greyhound puppies for now, so I'm afraid you're class warfare gambit doesn't hold up to scrutiny. You're the one who makes the absurd GREY2K-like claim in your post above
      that "It does not take a giant leap of the imagination to realize that our beloved breed, Greyhounds, will become extinct here in the United States." For someone who spends an enormous amount of time arguing with Eric and other GREY2K minions on all and sundry media outlets, you're certainly quick to use the same kind of exaggerated rhetoric that GREY2K does.

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  2. Elaine, you should point out your personal stake in this regulation, if you want to be truthful. Then again, why start now? This diatribe is full of hysterical and untrue statements, reaching a new low even for this blog.

    The idea that, "The proposed new USDA/APHIS rule and PUPS law would prevent most animals from being raised in a home and family setting" is preposterous. The changes would affect breeding of animals, not having them as pets as you imply. And there's nothing about the regulation that prevents people from breeding pets - unless you want to make a business out of it. If you want to do electrical work on your home - that's on you, but if you want to pass yourself off as an electrician - you better meet the applicable regulations. This is no different.

    Also, you need to decide if the regulation will or will not be enforced. In consecutive sentences, you post both possibilities.

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    1. Eric Jackson, you are right, I did write this particular post. However, as I've previously told you, I have nothing to gain or lose if greyhound racing is abolished.

      If these proposed rules go into effect, all animal lovers stand to lose, not just me. I'm not a big time breeder, I've bred three litters in 16 years. I'm of an age, where I'm trying to decide if I really want to breed another litter. If these proposed regs go into effect, it's no big deal for me. But it will be a big deal for the dogs. Most AKC greyhound breeders are elderly. I cannot see them continuing to breed should these regs go into effect and, as previously stated many times, if greyhound racing should be abolished, the racing people will no longer continue to breed. The breed will go extinct here in the USA. Like it or not... those are the facts.

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    2. Dear Eric:
      It is clear where the hysteria is coming from. You want animal lovers to believe that everyone who breeds dogs is a "greeder" and that somehow there is language in this regulation that would do one single thing to help suffering animals that isn't already being done. it's drafted strictly to be punitive enough that the most dedicated will quit and only the casual breeder you describe - one who has an accidental breeding because they aren't even responsible enough to spay or neuter and won't encounter any vet bills because they let "nature take its course" - abuse through ignorance and lack of purpose - will dump the puppies on the local shelter or "rescue" ----Eric, those people won't give a rip if this regulation is passed or not. Only the responsible ones care.
      People love dogs and lots of people love purebred dogs. It costs money to do it responsibly. Accept it. Don't ya think our regulators have better, more important things to do than threaten small business persons? Really, Eric? Think, man, think. Regardless of what info you may have pulled out of your butt, the people who are in business to breed healthy puppies believe it will have a negative impact. Again, dude, people who don't breed responsibly and fill the shelters and rescues WON'T GIVE A RIP. Get it?
      You are a bully and an ass.
      Best,
      CJ Brennan

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  3. I'm still trying to figure out what a proposed USDA regulation that would put some restrictions and/or licensing requirements on breeders who sell puppies over the internet has to do with the fact that GREY2K lies, regularly.
    Perhaps the name of the blog should be changed to GREY2K Lies Or Personal Agenda -- Take Your Pick. Truth in titling and all that.
    Elaine from where I sit you're flirting dangerously close to the tactics of GREY2K with all the exaggeration and economical use of the truth. Is the protection of internet puppy sales really that important to you ?

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    1. Contrary to popular belief, this proposal does NOT do anything to regulate internet puppy sales. The proposal does not address how people make contact with each other, such as over the internet, or how the sale is finalized. It only addresses the definition of retail pet store. I've read the proposed changes. People can continue to make contact & sell puppies on the internet and, as long as the people come to their home each & every time, they will be exempt from the AWA requirements on sanitation, housing, etc. I don't know about you, but I really don't want to have people coming to my home and inspecting any & all parts of it.

      Meeting someone half-way at a convenient spot will not be allowed, unless you become a USDA licensed dealer.

      Shipping a puppy somewhere, including overseas, will not be allowed, unless you become a USDA licensed dealer.

      If you buy a puppy and then sell it at some point in time as a pet (after it's retired), you have to be a USDA licensed dealer.

      So tell me, John, were any of your puppies shipped to their new owners or did they all come to your home to claim them? If they were shipped, you would be subject to the new regulations and to USDA licensing.

      The only thing this proposal does in change a hobby breeder into a commercial breeder, requiring that 1) they allow people to enter their homes and inspect any part of the premises OR 2) become USDA licensed commercial pet dealers and then subject to unannounced inspection by the USDA. Like I said, I don't want strange people in my house and I do not want to raise my pups according to the USDA regulations.

      My concern is based upon the long term health & viability of the breed. This is a greyhound issue, especially if Grey2K is successful with their propaganda campaign in getting greyhound racing abolished. That is addressed in the post.

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    2. Yes, "grey2k lies" all the people who got our puppies have been to our home and yes, "bealsie2" I have read the proposed regulation -- every word of it. (Why is it you folks don't use your real names in these comments ?) I'm not in favor of this regulation on general libertarian principles that government has no proper role here. But what I object to in the context of this blog is that (1)the subject has nothing to do with GREY2K lying and (2) the vocal opponents of the proposed regulation are using the same dishonest tactics as GREY2K does -- exaggeration, dramatic declarations of the "likely" outcomes of the regulation if enforceable (about which eforceability, in practical real life terms, there is signficant doubt)and the usual Chicken Little
      it'll-be-the-end-of-purebred-dogs-as-we-know-them predictions that are always made by the show breeders when any such regulation or law is proposed.
      The real issue that lies at the heart of the proposed regulation is the question of when being a hobby breeder crosses over into being a small business. Perhaps if you have four breeding females at hand (and there's been no evidence cited to support the claim that "breeding females" will be interpreted to be the equivalent of "intact females"), and you're shipping puppies around the country and the world to buyers you wouldn't want on your property (which raises its own questions as to who you'd sell a puppy to), then you're no longer really a hobby breeder and have crossed over into the territory of running a business, albeit a small business. Deal with it folks -- the government over-regulates most small (and large) businesses these days. Want that to stop or at least slow down ? Don't pull the lever for most Democrat candidates when you go to the polls.
      I try to look at the bright side -- perhaps the annoyances of dealing with this regulation if it becomes effective will mean that fewer show dogs ( in the context of this blog, fewer show Greyhounds) will be bred. Given what we're seeing in the show ring these days, I'm not so sure that's a bad thing for dogs.

      John Parker

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    3. “the vocal opponents of the proposed regulation are using the same dishonest tactics as GREY2K does -- exaggeration, dramatic declarations of the "likely" outcomes of the regulation if enforceable (about which eforceability, in practical real life terms, there is signficant doubt)and the usual Chicken Little
      it'll-be-the-end-of-purebred-dogs-as-we-know-them predictions that are always made by the show breeders when any such regulation or law is proposed.” A tactic of which you are also demonstrably guilty with your persistent head-in-the-sand rhetoric.

      “The real issue that lies at the heart of the proposed regulation is the question of when being a hobby breeder crosses over into being a small business.” That is in no way the issue. USDA doesn’t care whether you consider your operation to be a hobby or a business. And they don’t care if somebody else considers you a hobby or a business. All they care about is whether or not you are required to be licensed. Under the current regulations, the vast majority of small hobby breeders do not require USDA licensing. Under the proposed regulation, a huge fraction of that majority will either have to change their normal way of doing business or will have to become USDA compliant. And being USDA compliant is not just a matter of filling out a form, paying a licensing fee, and having an inspector come to your home once a year. It Is a matter of having a USDA compliant facility and for most hobby breeders, who generally keep their dogs in their homes, it will be significantly cost-prohibitive to build a compliant facility.

      “Perhaps if you have four breeding females at hand (and there's been no evidence cited to support the claim that "breeding females" will be interpreted to be the equivalent of "intact females")” Dr. Rushin of USDA, in the initial stakeholders’ teleconference, stated that APHIS has been using a working definition of “dogs that have the ability to breed”. The most likely interpretation of that, if left unchallenged, will be “intact females”.

      “you're shipping puppies around the country and the world to buyers you wouldn't want on your property” See the reference above to exaggerated, dramatic rhetoric. There are as many reasons as there are people why a buyer might not come to a seller’s property. To imply that the only reason a seller ships a puppy is because the seller does not want the buyer on her property is disingenuous at best. Not to mention deliberately insulting.

      Belittling a serious threat to continued animal ownership in this country as we have always known it as a means to further your own political agenda I’m pretty sure is a bad thing for dogs.

      Susan Beals

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  4. It's pretty obvious that neither John nor Eric has read this proposed rule. If they have, they have not bothered to think through the ramifications. Eric is right - there is nothing about the rule that will prevent people from breeding pets, and it has nothing to do with whether or not they want to make a business out of it. In fact there is nothing about the rule that will prevent someone from having 300 dogs and breeding them at every heat for their entire lives - as long as every purchaser comes to their establishment every time.

    However, if a breeder - and admittedly we are talking mostly about show/hobby breeders here - has more than 4 intact females (probably the count will be of all covered species - dogs, cats, hamsters, guinea pigs etc. so don't forget to count your kids' pets and 4H projects people) and elects to, for example, meet a puppy buyer half way between their houses to save driving - well that breeder better be either licensed and USDA compliant or prepared to pay a whopping (up to $10,000 is the rumor) fine. Or if a breeder gets a puppy back from a co-owned bitch and sells it (and for this one it doesn't matter how many intact females the breeder has on her property - could be none) - well that breeder better be either licensed and USDA compliant or prepared to pay a whopping fine.

    There are many more examples of current practices used by responsible breeders that would be, in essence, against the law under this proposed regulation. The supposed need for this regulatory change is based on faulty information. USDA claims to have complaints about internet sales, and I'm sure they are not lying about that, but they did none of the required studies to determine either the need for or the impact of this rule. The ARs in positions of power in USDA simply wrote it and the only reason it is even out for public comment is because they are required by law to do so.

    And it's not just breeders that will be affected. If your brother, Joe, helps out his neighbor by taking one of the neighbor's oops puppies and selling it to a co-worker for $25 to cover his time and expenses - Joe better be USDA compliant or face a fine (before you jump on me, read the rule - the $500 de minimus exemption does not apply to dogs).

    Familiarize yourselves with the consequences of this rule change. Think it through and think about how it will affect you - as breeders and as puppy buyers - and then comment.

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  5. Wow ...De Nile isn't just a river, is it?

    Should this proposal go into effect, breeders will have three choices:

    1. Sell all pets only from their own premises. No shipping, no meeting halfway or at a show, etc.

    OR

    2. Keep four or fewer females and sell only their offspring which you breed and raise on your own premises. Co-ownerships will count for all owners and other small pet species will also count. It will not matter that a particular bitch is too young (in your judgement) or not of suitable quality for breeding or is retired, or belongs to a friend ...

    OR

    3. Set up an AWA-compliant kennel and get a USDA dealer's license. ($50,000-up, IF you can get zoning approval and don't mind the side effects.)

    So ... What'll it be?

    There's much more info, here:

    http://virginiafederation.org/introduction

    Including the link for making comments. Figure out how the requirements above would affect you, then -- unless you think they're okay -- make a comment at the address given.

    Remember: Even if you as a breeder CAN cope with these requirements, you depend on a gene pool that is already too small. If many other breeders decide to give up, where does that leave you and the greyhound breed?

    Walt Hutchens, Timbreblue Whippets

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  6. Walt,
    Please cite any legal or regulatory authority which supports the interpretive stretches you take in #2 above. Nothing like a little spin to shore up the Chicken Little, stir-up-the-show-breeders strategem. I'm starting to see the connection with GREY2K lying.
    The racing/cooursing Greyhound gene pool and its diversity is doing just fine, thanks, and much better than the gene pools of the sighthound breeds which depend on the show culture to sustain them. That's what comes from being a sporting/working breed rather than a show breed.

    John Parker

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  7. Addendum to Post:

    It is thought that "Rescues" and/or "Adoption Groups", 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. As you know, many greyhound adoption groups send dogs by way of GUR runs to the new adopter. That action would require them to be USDA licensed & inspected.

    Shelters, such as municiple animal control premises, will meet the definition of “retail pet store” as the purchaser will be on their property prior to each sale and will be able to inspect the premises. However, if they were to ship an animal without the end purchaser coming to the premises, they would automatically lose their exemption and have to be USDA licensed and inspected by APHIS.

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    1. Our adoption group, GPA-Atlanta, like many Greyhound adoption groups, is a licensed animal shelter, licensed and inspected by the Georgia Department of Agriculture. We have to submit forms related to our foster homes (in addition to the inspection of our adoption kennel). Guess what? When we had to become licensed and inspected, it was an annoying hassle (and still is), but we didn't miss a beat, it hasn't prevented us from adopting out the same number of former racing Greyhounds, and more intrusive government regulation didn't end Greyhound-adoption-as-we-know-it. And this proposed regulation won't have that effect on the breeding of dogs.
      It seems to me that it would be more intellectually honest to oppose this new regulation on the grounds that (1)it's unnecessary and (2) it will create annoying hassles for dog breeders that don't protect buyers of puppies or improve the conditions in which puppies live before being sold. Both those objections are much more grounded in reality than all this end-of-animal-ownership hysteria, which is not very effective because of its lack of credibility.

      John Parker

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    2. Elaine, that's a ridiculous stretch, above and beyond the exaggerations you've made earlier. Remember, these rule changes apply to "breeders" and "retail pet outlets." Neither applies to a municipal shelter or the typical animal adoption agency. And I have NEVER heard of a group charging a foster home to take a dog. That defies the common understanding of foster home. I can only suppose you have some stake in this, because your BS is so over the top, it's ridiculous.

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  8. Here's the comment I left on the comments section for the proposed regulation:

    "This is an unnecessary and potentially harmful extension of the regulatory authority into the realm of hobby breeders who are not "puppy mills" and are not selling puppies as a business. It will make the breeding activities of these hobby breeders more difficult to carry out without any concomitant benefit to puppy buyers or the living conditions of the puppies themselves. Some good faith, responsible breeders who are helping preserve certain breeds of purebred dogs and their genetic diversity may stop breeding because of the regulatory burden placed on them, and this could be harmful to the genetic diversity of the breeds in which they are involved.
    The proposed regulation is also vague in failing to define with any precision the term " breeding female." It should be defined to include only those intact females intended to be and/or actually used for breeding, NOT all intact females in a breeder's home or kennel. It is not at all unusual for a breeder or other dog fancier to have 5 - 6 intact females on his/her property, yet only 2 or 3 of those females are intended for or will actually be used to produce puppies because of health and/or breeding quality characteristics.
    Absent any substantial evidence that this "loophole" results in substantial, widespread harm to animals or to buyers of those animals, this proposed regulation would appear to be "fixing" a problem that doesn't exist and/or regulating more broadly than is necessary."

    Comment Tracking Number: 8105e0cb

    I realize this lacks the high drama and hyperbole that so many show breeders trot out whenever a new law or regulation like this is proposed (a default setting they share with GREY2K), but hopefully it will be unique in that way and will thereby get the attention of the regulation deciders.


    John Parker

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