APHIS Redux

The following article originally appeared in the July 20, 2012 issue of Dog News. It is posted here by permission of the author.

APHIS Redux

Carlotta Cooper

Many of you have been closely following the APHIS rulemaking process since it was announced on May 15. For those of you who haven't been, and just to catch everyone up, here is where we currently stand.

At almost the 11^th hour on the Friday before the Monday, July 16^th deadline for comments, APHIS extended the deadline until August 15. We now how a few more weeks to make persuasive arguments that this wrongheaded effort to regulate breeders should be scrapped. You can make comments directly to the APHIS site through this link.

The Sportsmen's and Animal Owners' Voting Alliance is putting together an opposition list to the proposed APHIS rules. They will be sending this list to Washington DC when their lobbyist meets with congressmen at the end of the month. The deadline to add your club, state organization, business, or self to this list is July 30. You can be added to this list by sending a brief message of opposition signed by an officer of your organization to Susan Wolf at cubhill@earthlink.net. Scores of parent clubs and kennel clubs have already signed. <http://www.saova.org/APHIS_Opposition.List.html> If APHIS will not listen to breeders, perhaps pressure from Congress will do some good. Each of these clubs represents dozens, even hundreds of people who vote, something that legislators care about, even if APHIS doesn't.

The AKC's petition to oppose the APHIS rules is still active, as of this writing, and has about 66,000 signatures. Isn't that amazing! The petition was to close on July 15 so it could be delivered to APHIS prior to the end of comments. I don't know how long it will remain open now that the comment period has been extended, but if you haven't signed it, please do. <http://www.gopetition.com/petitions/join-with-the-akc-to-protect-responsible-small-breeders.html> The petition will only count as one comment to APHIS, but it is a powerful indicator of the unity of AKC's breeders, buyer's, and supporters. The petition DOES make a difference. HSUS is also collecting signatures on petitions and we need to show that we have numbers, too.

The AKC has been attacked directly by HSUS on several occasions during this rulemaking process and on each occasion they have responded in a strong, dignified manner. They have shown that they are, and WE are, the experts when it comes to knowing and caring for dogs. HSUS has stooped to sending a troop of Girl Scouts from Maryland to the office of the Secretary of Agriculture and having the girls send a letter to the AKC claiming that the “AKC is mean to puppies” in order to try to get the AKC to change their opposition to the rules. As the AKC explained, “one-size-fits-all” rules are not in the best interest of dogs. AKC has a routine inspection program in place and they have inspected more than 55,000 kennels that register AKC dogs since 2000. No other registry has such a program, and they enhanced their Care and Conditions of Dogs policy at the recent April board meeting. If or when inspectors find signs of cruelty, the situation is reported to the proper local, state, and/or federal authorities, as they should be. Through the Canine Health Foundation, Companion Animal Recovery, and parent club and other rescue programs, the AKC is the leader in caring for dogs. In terms of animal welfare, the AKC does more for dogs than any other organization in the United States, bar none.

That hasn't stopped HSUS from attacking and lying online. They are also lying in the media about the proposed APHIS rules and what their impact would be. (I have a blog for Tennessee pet laws and I know that HSUS people have been trying to post messages about the proposed rules which are flatly inaccurate and misleading. Those messages are moderated and never posted. Likewise, they have not been posted by others with pet law blogs.) HSUS shills are out in force trying to tell the public and others that you can keep dogs in your home under the proposed rules, for instance. This is based on something that was written in the revised fact sheet that was posted by APHIS a few weeks ago in which they stated that your home could be considered your “primary enclosure.” Pardon me while I laugh here. The only way that your home could be considered your “primary enclosure” under the APHIS-AWA regulations is if you set aside a basement or some other room in your house that can be sterilized to 180 degrees and which has no sharp edges anywhere. (Can you sterilize your carpets? Hose down your hardwood floors? Do you have Venetian blinds in your rooms?) Any room your dogs inhabit would be subject to unannounced USDA inspections. If you raise puppies in your bedroom, you would have APHIS inspectors in there. So, if you want to live in a kennel and have unannounced visits from government inspectors, then sure, I guess these rules won't bother you at all. Don't believe anything posted by these HSUS mouthpieces who are just trying to get into your home and stop all dog breeding.

Currently there are about 9000 comments on the APHIS site and there are more comments opposed to the APHIS proposed rules than for them. The comments opposed to the rules are also of much better quality. Many of the comments in favor of the rules read like, “I hate puppy mills! I support these rules.” And “Shame on the AKC.” There are many “Me, too” type comments and they aren't very smart. They do not show any familiarity with what is actually in the proposed rules. However, HSUS claims that they have another 100,000 comments to deliver. Whether you believe that or not, and whether they are any better than the comments in favor of the rules so far, is anyone's guess.

Comments from breeders, parent clubs, and others opposing the rules have been excellent, for the most part. They show a much deeper understanding of the proposed rules and how they would impact breeders and their dogs. But more comments are needed, so please continue to post. You have until August 15. No one knows what it will take to make APHIS drop these rules, or if that is possible, but we need to keep writing.

If you have questions about the proposed rules there are many good places to look online for more information. You can check the AKC resource page: http://www.akc.org/governmentrelations/usda_aphis.cfm

SAOVA has an entire page of information: <http://www.saova.org/APHIS_rulemaking.html> with links.

NAIA has information: <http://www.naiaonline.org/articles/article/the-usda-proposed-rule-and-you>

And there are many good articles and blog posts online.

Please keep writing. If these proposed rules are passed, our rarer breeds could disappear and the quality of the remaining breeds will be seriously hurt. We need to stop these rules.