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A letter from the OESCA Legislative Liaison

Note: The deadline has been extended until Wednesday August 15th 2012.

Dear OESCA members,

Many of you know about the threat of changes in regulating breeders within the federal regulation of the Animal Welfare Act (AWA) within the Animal and Plant Health Inspection Service (APHIS) of the Department of Agriculture (USDA).  I understand when you do not understand how this will affect you.

THE USDA already regulates large commercial breeders to some degree.  What APHIS proposes is to change the regulations to include the small hobby breeder, particularly if they sell over the internet, as well.  AKC and your parent club feel strongly that we should be exempt because we consider ourselves "hobby" breeders who do not breed for a business but for the future of our breed. You may find another entry on our national website that details the practices of many or our members who are breeders.  After reading "A Good Breeder…..", ask yourself if commercial breeders are breeding with the same motivation as our member breeders are?  Based on your own experiences with breeders I hope you will agree that commercial breeders have a long way to go before they demonstrate the same commitment to protecting our breed from extinction.  You may not be a breeder, but the next time you or a friend is looking for a new or rescued dog you will want to deal with a member breeder who has gone to great lengths to ensure your purchase is as healthy as possible and has a beautiful temperament regardless if you choose a pet or a show dog. This rule change has the potential of discourage some from further breeding if enacted.  THAT is why you need to be a part of those who are commenting on these proposed changes to regulations.

Now, before you think this is too involved to know what to write, you also need to understand that changes to "regulations" differ significantly from "legislation."  Proposed regulations only address a narrow part of an existing law and therefore do not require congressional votes, but rather the votes of a few who are assigned to duties within the department, this issue being the US Dept. of Agriculture.  Prior to their vote then, this is our opportunity to provide clear information and explanation of how this will impact you.

We are coming upon the last days of getting your voice heard regarding these changes.  PLEASE TAKE THE TIME TO LET YOUR VOICE AND OPINIONS BE HEARD!!!!
The USDA has given the public the opportunity to comment on these changes until
Monday July 16th 2012    Wednesday August 15th 2012.

So how do you get your voice heard?  One way is to write. The address is:
Docket No. APHIS – 2011 – 0003
Regulatory Analysis and Development
PPD<APHIS< Station 3A – 03.8
4700 River Road, Unit 118
Riverdale, MD 20737 – 1238

I would be remiss if I did not tell you also that AKC Government Relations is also interested in your concerns and questions. These may be addressed to loglaw@akc.org.

To send your comments via email information and details are available on the AKC site.  Here's the path to take:

Go to "akc.org" – When you are on the website, look at the list on the Right side of the page and click on "Legislative Alerts."  From there click on the entry entitled "USDA/APHIS……" – (I strongly suggest that you read this alert because it will give you some talking points to help you write your response to their proposals.) 

Some of the talking points from the AKC Alert are:

  1. Geographic distance often makes it difficult for purchasers to personally visit the breeder to see the puppies before buying.  This regulation is designed appropriate for large commercial breeders but not practical for small breeders such as our membership.
  2. The regulation restricts the number of intact females an owner is allowed to have; but does not define at what age a female dog might be considered a "breeding female".
  3. Our parent club (AKC) believes that based on its own experience in kennel inspections and breeding operations and the regulatory impact analysis provided in the proposed rule change, both the number of individuals who will be impacted and the expense to its occasional breeders if they must establish commercial – level facilities is grossly underestimated.
  4. ????  Comments you may share that are important to you………

After reading this, I suggest you write down your thoughts in a separate document….you should limit your comments to 2000 characters.  Follow the AKC alert down to "WHAT YOU CAN DO" on the document and click on "online here." – This will take you to a different web site called "Regulations.gov."  On the upper right hand corner, click on "comment now."  That will bring you to a place to put in your name, contacts, etc.  THEN, on the right of that, you will see a box to put your comments in and you should copy/paste what you want to submit from your separate document. Don't forget to then click "SUBMIT."

Please be nice.  Remember, we are not the problem but we are a part of the solution.  Members of OESCA are bound by our Code of Ethics.  Let's educate our representatives so they will know we are part of the solution to protecting our breed and all dogs so that they live within a safe environment and are cared for humanely.

The USDA is motivated in part to protecting the general consumer.  Sales by internet have too often resulted in many disgruntled consumers, and often with good reason.  THANK YOU!  EVERY LETTER COUNTS AND EVERY COMMENT THAT WILL EDUCATE THESE REPRESENTITIVES WILL BE HELPFUL!

FINALLY, if you are NOT in a local all breed club/or canine activity club in your area, apply for membership so you can be made aware of federal/state legislation issues.  AKC does a great job on addressing state/national issues but unless we let them know of local issues going on around us, it is impossible for them to know how they can help us. If you have an issue, send me as much info as you can, including scanned newpaper articles and I will send it on to AKC.

By being the member of a local club you can also suggest that your club invest in purchasing magnetic bumper stickers that say "I own a dog and I vote!"

This idea is especially timely now since we have a general election coming up in November.  The club can get these through AKC at $7.00 @ and by charging $10.00, the club can make a little money to help with other educational/service activities in your community!  Besides, this is a good way to educate the public – when someone sees your sticker, you will have an opportunity to educate people on why we are a solution to their canine related problems through education and training classes.

FINALLY, the things to which I have discussed here are serious threats to our freedom to maintain and protect our breed!  I once again refer to the "saintly" judge in Kentucky who declared that pets are private property.  I hope you will not fail to join those of us who are adamant that we must speak out!   If you have any questions, please feel free to contact me at oeslegislation@comcast.net or 219-464-3403.

My best to you as you begin this process.

Sandra Johnson
National OESCA Legislative Liaison