To all rescue clubs, shelters, small reputable breeders, show homes, breeder/exhibitors and handlers, and,
To everyone who has ever purchased from a responsible, honest breeder, who has or had a loving, healthy, good tempered pet in their lives, please read below and take action. The only ones who can comply with this proposal are the huge commercial kennels who produce solely to make a profit and meet supply and demand, the ones this so called law is suppose to get rid of. They can afford to make changes to comply with the law, let alone pay the fines. This is happening all across the country, Kentucky has already passed it and Delaware, Pennsylvania is next and then it will move on to other states. The people who are dictating these laws have no concept of what it takes to breed healthy, good tempered, well socialized puppies and dogs, they're solution is to keep them in outbuildings with runs -- where's the human contact and care then, and fine the hell out of a breeder. Shut down the puppymills and brokers and deny pet stores the right to sell dogs is the way to go, period -- these are who profit at any cost. Where will our service dogs come from then if the small/breeder/exhibitor kennels are attacked and made to pay the consequences this objective was suppose to target? Owning a dog in PA will not be a right afforded to anyone.
The deadline to comment had been extended to March 18. This affects breeders, rescue groups, and also Clubs.
Please write a letter!!
A Commentary on Pennsylvania's Proposed Dog Law Enforcement Proposed Rules and Regulations
http://www.pabulletin.com/secure/data/vol36/36-50/245
2.html
For many years now, the animal rights and animal welfare groups have been
telling the entire nation that Pennsylvania is the "Puppy Mill" capital of the
east. I have always been suspicious of this emotionally charged, hot button
term. The phrase was introduced in the 1980s and the HSUS has used it at every
opportunity since. Perhaps the phrase was first used to describe genuine, sub
standard kennels - but it has s ince morphed into a catch all term that has been
used to demonize even the most reputable of breeders.
There is no doubt that large, sub-standard kennels exist in Pennsylvania.
Laws were in place that should have regulated such kennels, but they were not
strictly enforced. Because the animal rights activists tend to cry "puppy mill"
even when there are none, we must question their motives and credibility. We
cannot allow these ridiculously stringent regulations to pass into law.
Laws are made to cull out the bad apples. Unfortunately, the bad apples
usually do not adhere to the law. Many have already shut down their operations
entirely or moved them to another state. These proposed regulations will become a
burden on those who have always maintained professional kennels. The honest
person is being punished for the misdeeds of those that the regulations were
written for.
What is so onerous about these regulations is that t hey are nearly impossible
to follow unless you are fortunate enough to have a full time staff. They are
time consuming and will incur great expense to kennel owners. The potential
for the regulations to be subjectively enforced is of extreme concern and must
be taken into consideration.
Ironically, reputable breeders joined the animal welfarists in the crusade to
clean up or shut down unprofessional breeders. Unfortunately the line between
hard core animal rights and genuine animal welfare is very blurred, and often
the former merely poses as the latter. I warned readers many years ago that
animal rights people do not compromise - they see things in black and white
(i.e. all breeders are bad). They can't be trusted and the newly appointed dog
law advisory board and their proposed regulations are proof positive.
The PA Department of Agriculture admits they have relied on and borrowed from
provisions set forth in the Animal We lfare Act (AWA) and in the Military Dog
Training Manual. Both of these documents were created by and operated by the
federal government which has ample funds to adhere to them. The U.S. military
certainly has the budget to maintain a state-of-the art kennel. It is not
reasonable to place those same standards upon a private citizen.
Taxpayer money will be used to purchase equipment necessary for measuring
lighting and ventilation. It is estimated that $15,000 per warden will be
allotted the first year and $5,000 for the next four years, or $35,000 per each
warden. The information I have has 79 dog wardens listed - there could be more. 79
x $35,000 = $2,765,000, nearly $3 million dollars.
The proposed amendments to the regulations will impose additional costs on
those regulated. Licensed kennels will need to comply with very restrictive
specifications regarding lighting, ventilation, space requirements, sanitation,
housing req uirements and record keeping. "Temporary homes" will also have to
comply with these regulations. The new dog advisory board estimates the costs for
each person and kennel to come into compliance with these proposed
regulations will range from $5,000 to $20,000. That is excessive and unacceptable.
Dog owners of every type need to make their voices heard NOW. We cannot a
fford to hide our heads in the sand any longer. If we do, we will deserve the
regulations that will be imposed on us. Please be sure to send copies of your
letters and comments to your State representatives (both houses), a copy to your
federal representatives (both houses) and to Governor Rendell. They need to
know what the Pennsylvania dog-owning taxpayers have to say about these proposed
regulations.
Comment letters should be sent on or before February 10, 2007 to assure
receipt by the comment deadline. Please also send copies of your letter to your
State Senator and State Assemblyman and to the Pennsylvania Federation of Dog
Clubs. Names and addresses are available on the website at Pennsylvania
Federation of Dog Clubs
Bureau of Dog Law Enforcement
Attn: Ms. Mary Bender
Pennsylvania Department of Agriculture
2301 North Cameron Street
Harrisburg, PA 17110-9408
717-772-4352 (FAX)
Governor Edward G. Rendell's Office
225 Main Capitol Building; Harrisburg, Pennsylvania 17120
To telephone the Governor call:(717) 787-2500
If you have not read these regulations yet, you need to do so. The link to
them is at the top of this article. The first time I read them, my head was
spinning. These should be guidelines for an ideal kennel; not law.
The 26 Dog Rule
Any *establishment that keeps, harbors, boards, shelters, sells, gives away
or in any way transfers a cumulative total of 26 or more dogs of any age during
1 calendar year must obtain a license. Th ose which do not fall under this
definition shall obtain individual, rather than kennel, licenses.
K-1 kennels are currently described by PA law as those with 26-50 dogs. These
are small operations that will most likely choose not to renew their kennel
license if they are subjected to the restrictive and expensive regulations that
are being proposed. Large corporations, such as the Hunte Corporation, can
afford to buy puppies from smaller breeders while maintaining facilities that
meet all the proposed requirements. These regulations encourage such factory
farms, that will in turn, sell puppies to pet shops across the east coast!
The below example illustrates how detailed the proposed regulations are.
*(An establishment includes the home, homestead, place of business or
operation of any individual or person, including a dealer, which includes all of the
land, property, housing facilities or any combination thereof, on, in or
through which any dog is kept, bred, harbored, boarded, sheltered, maintained,
sold, given away, exchanged or in any way transferred. Establishment shall
encompass all of the individuals or persons residing thereon. It may be public or
private and includes an individual, person, organization, business or operation,
which utilizes offsite or temporary homes to keep, maintain, breed, train,
harbor, board, shelter, sell, give away, adopt, exchange, or in any way transfer
dogs. A housing facility includes any land, premises, shed, barn, building,
house, trailer or other structure or area housing or intended to house dogs for
any period of time.)
Obviously the new, improved PA Dog Enforcement team wants to be able to
legally access an establishment owner's entire premise and be able to inspect
everything which they own. Buying a kennel or dog license conveys an obligation
attached to ownership rights which puts one under obligation to abide by the
governing laws, rules and regulations. The potential to violate Constitutional
rights is just too much to risk in my opinion.
Of course, each time the Department decides a regulation has been broken they
can file an injunction against the kennel and may also impose a fine of not
less than $100 nor more than $500 for every day the kennel operates in
violation of the act or regulations. (For instance, operating a kennel without a
license, operating with a revoked license, suspension of a license, selling dogs
without an out-of-state dealer license )
Seizure of dogs. The Department may seize, impound and direct forfeiture
proceedings of dog(s) for the following reasons: Revocation, suspension or denial
of a kennel license or an out-of-State dealer license. The owner shall pay for
transportation costs, care and feeding of the dog(s) even though they are not
in his possession.
These new regulations provide similar penalties that are used in alleged
animal cruelty cases where animals have been seized. A person is judged guilty
until proven broke. Remember, violation of any of these rules and regulations
could theoretically result in punitive actions against a dog owner or kennel.
There are procedures to appeal an ACO or dog warden's decision, but they are time
consuming and expensive. Few people are able to retrieve their property
(their dogs) once they have been forfeited. The holding fees are quite steep and
unreasonable. Some of the animals die while in the care of a third party; some
become diseased and others are sold or adopted out.
This is Administrative Law. The Dog Advisory Board not only writes and in
corporates new rules and regulations into the statutes, it is also responsible for
administering and enforcing them as well as judging whether they have been
broken! It is difficult to fight such a system.
Extensive recor ds on each dog kept at a licensed kennel must be maintained
for at least 2 years. The records must be legible and be open to inspection and
may be copied by any employee of the Department (with or without notice). All
records must include the minimum information: the breed, color, markings, sex
and age of each dog; the date on which each dog entered the kennel, and where
the dog came from. Other information may be required depending on the type of
kennel license one owns. The PA kennel license number or out-of-state dealer
license is necessary for dogs that enter a kennel along with the name and
address of the individual breeder or former keeper. Similar records are kept for
dogs leaving the kennel including detailed vet records about the dog. (spayed,
neutered, vaccinations etc etc)
Similarly, the housing requirements are quite detailed. Temperature control,
safe housing, space requirements, protection from the elements, strict sanitation protocols, and even lighting specifications are set out in great detail
for both indoor and outdoor facilities.
The following are just a few of the details covered. Outdoor dog shelters
must be raised off the ground and built to be draft free, and yet must be well
ventilated. They must have clean and dry bedding at all times. There must be a
wind and rain break at the entrance and a mud free area with no standing or
pooled water nearby. It must be easy to clean and sanitize. Dogs may not be
housed in drums or barrel houses.
Shade must be provided by a permanent fixture; not a tarp. The shade area
must allow for air movement in excessive heat and protect the dogs from the
direct rays of the sun. The shade areas must adhere to strict space requirements.
Both indoor and outdoor facilities must be equipped with waste disposal and
drainage systems built on a slope and in the best possible manner to wash away
anima l waste and allow for quick runoff. (At least 1/8" per foot) Outdoor
kennel runs must be sloped to a gutter outside of the end fence of each run.
Drains and gutters shall be sanitized daily then flushed with water.
The exercise run associated with each dog box must be at least five times the
length of the largest dog in that run and two times as wide as the length of
the largest dog in that run. Outdoor runs and exercise areas may be
constructed of concrete, gravel or stone. Again, the regulations set for very definite
specifications. Outdoor facilities, including runs and exercise areas shall be
kept free of grass and weeds. Grass and weeds shall be cut back from the sides
of runs and exercise areas to a distance of 5 feet to help prevent tick, flea
and other parasite infestation.
Each dog shall receive 20 minutes of exercise per day. Dogs shall be walked
on a leash by a handler or put in an exercise area. The exercise area mus t be
fenced, shall be kept in good repair, and equipped to protect dogs from
becoming wet, matted or muddy during their exercise. Outdoor facilities must be
fenced and be constructed to minimize or prevent vermin, animal, insect and pest
infestation and other vectors of disease.
Records shall be kept regarding dates and times:
When the housing facility was cleaned.
When the housing facility was sanitized.
When each individual cage, dog box or primary enclosure was cleaned.
When each food and water bowl was sanitized.
When new food and potable water was provided each dog.
Every keeper of a kennel shall keep a record of the following for each dog
housed in the facility:
The date, time and detail of daily feedings, cleaning of kennel, and changing
and refreshing potable water.
The date, time and detail of exercise activity of the dog.
The date, time and detail of any medication administered to a dog.
Any accident or inci dent in which the dog is injured.
The date and time of any veterinary care administered.
Records of veterinary care for each dog.
Any veterinary ordered or voluntary protocol for vaccination, medication or
other recommendation for medical treatment of the dogs.
Tethering rules are set forth for dogs that are outside. Accessible hot and
cold water, sinks, showers, towels and soap are mandated for animal caretakers.
Dogs housed in indoor and sheltered kennel facilities shall be provided a
regular diurnal lighting cycle. Primary enclosures must be placed to protect the
dogs from excessive light. A minimum of 10-foot candles for kennel building
and primary enclosures; 20-foot candles for bathing, grooming and toilet areas
and 70-foot candles for food preparation and storage areas are required.
Electrical systems in wash down areas must have ground fault circuit interrupters
and all others must be the all-weather type with a spring cov er.
Dogs not acclimated to current weather conditions shall be kept indoors
Puppies not born in the receiving kennel facility shall be quarantined for a
minimum of 14 days. Adult dogs entering the kennel from another place shall be
quarantined. Dogs must be separated according to sex, size and temperament during
prescribed daily exercise times.
Detailed provisions regarding dangerous dogs are described. Dangerous dogs
must be registered, restrained and under strict supervision. Liability insurance
is required. Violations may result in misdemeanors, confiscation of the dog
and its euthanization.
We have very briefly touched on the main subjects covered in these extremely
oppressive regulations. The regulators need our input. These proposed rules
must be modified. Left as they are, there is too much room for them to be
unfairly enforced and administered. There is too much room for them to be enforced
subjectively withou t common sense. We, who read the news, see this happen each
and every. Such ideal guidelines cannot be legally enforced without causing
harm to innocent, law abiding citizens.
http://home.paonline.com/pfdc/
Nina Schaefer
President
Pennsylvania Federation of Dog Clubs, Inc.
pennafeddogclubs@aol.com
www.paonline.com/pfdc>>>>
Here's more information:
Attached Message
From:
pennafeddogclubs@aol.com
To:
pfdc-l@yahoogroups.com
Subject:
[pfdc-l] Please cross post -- this should go to everyone who is concerned
Date:
Mon, 5 Feb 2007 10:56 AM
OH YES THEY WILL!
Dear Pennsylvania Breeder:
Small breeders and kennel owners are being told not to worry about the proposed new Pennsylvania kennel regulations. They’re being told the dog law officers won’t have time or the desire to enforce the proposed regulations against people who raise dogs in their own homes. They’re being told these regulations will really only affect large commercial breeders.
Nothing could be further from the truth! These regulations
WILL apply to
every licensed kennel operator, every boarding kennel, every professional handler located in Pennsylvania, everyone who participates in breed rescue - every person who keeps more than 25 dogs overnight in their home or kennel during the year for any reason and receives any compensation or payment - even if you never have more than just a few dogs at one time!
Anyone -
not just a dog law officer - can file a complaint against you. If they do, the Bureau of Dog Law Enforcement has
no choice but to investigate you, and cite you if you are not in full compliance with the regulations.
The animal rights activists who have an agenda of eliminating the breeding of dogs and keeping of pets are trying to lull small breeders into complacency - “Not to worry, this won’t affect you!”
They know we have political clout if we get involved. They don’t want that!
Now is the time to act - for your own sake and for the sake of hobby and show breeders throughout the Commonwealth! The Pennsylvania Federation of Dog Clubs and the AKC, along with several other organizations, have persuaded the Secretary of Agriculture to extend the deadline on the written comment period on the proposal until March 16, 2007. Please study this proposal, and register your concern by submitting a comment letter.
Every single letter counts!
You can get information about this proposal, and links to all of the other information you will need, at the Pennsylvania Federation website at __________.
Here’s what you need to do,
before March 16, 2007.
GOOD:
Visit the Pennsylvania Federation website, read the information and download the model comment letter. Add some personal information, your name and address, and any additional concerns you have. SIGN and send your letter to the address on the letter by March 16, 2007.
Also send copies to your Pennsylvania state Senator and Representative and to the Federation.
BETTER:
Read the proposed regulations. They will scare you!
Write your own comment letter on the issues you feel are most important. Don’t just say you oppose a particular requirement, describe specifically what’s wrong with it. If you have suggestions for improvements, offer them. Then sign and send the letter by March 16, 2007.
BEST:
In addition to writing your own comment letter, contact all your friends, neighbors, clients, customers, puppy owners, kennel club members, etc. and urge them to write letters too. Call your state Senator’s and Representative’s offices and ask to meet with them to discuss your objections to the regulations. Even if you don’t get a meeting, the fact that you’ve requested one will have a tremendous impact.
Yes, we know that these are lengthy and complicated regulations.
The advocates of these regulations are counting on that to discourage you.. They’re figuring you will just give up and not get involved. Don’t prove them right! It is imperative that
every dog fancier in Pennsylvania get involved to protect small hobby and show breeders.
The people that will be most adversely affected by these regulations are you - the small breeders. These regulations are written for commercial establishments. The reality is that the people best able to make the investments and comply with the regulations will be the large commercial breeders. Just look at some of the requirements:
· All surfaces the dog comes in contact with must be impervious to water.
· There must be a ventilation system that provides at least 6 air changes per hour
· There must be a minimum of 10 foot-candles of light in housing areas at all times
· You must keep records of the date and time you feed and refill
each dog’s water dish
· You must keep records of the date, time and manner in which you exercise
each dog
· You can not allow dogs under 35 pounds to run with dogs over 35 pounds
Does this sound like your home? We doubt it. And this is just a small sampling of the requirements! Only large, commercial kennels could hope to comply with these requirements.
You must act now! Don’t think that by keeping silent you won’t come to the attention of the authorities.
Remember - any citizen can file a complaint against you. A disgruntled neighbor, an animal rights activist -
anyone! Staying uninvolved is a recipe for disaster. The advocates of these regulations are deadly serious. Please write a comment letter and talk to your state legislators
NOW. Thank you.
Nina Schaefer
President
Pennsylvania Federation of Dog Clubs
P.S. Don’t rely on someone else. A letter from your kennel club is
one letter. A letter from every member of your kennel club is a
lot of letters.
Everyone needs to write a letter!
Annise
Buldoon's Bulldogs
I think some other sections of the City are in need of them. I know for a fact that the corner of VanKirk Street and Harbison Avenue is treacherous. People speed and blow that light on a regular basis. It has totalled quite a few automobiles and damaged property over the years, yet nothing is really done about it. The next intersection down is also prone to a lot of accidents from speed and going through the light and that's Cheltenham and Harbison Avenues. Anybody who knows these sections, know they're as bad, if not worse than those on the Roosevelt Blvd. Who else thinks more cameras should be installed in dangerous areas? If so, where?
I have noticed a change somewhat on the Boulevard, but I'd like to see more changes in and around the city. Too many hit and runs.
Would like to see those with no insurance lose their vehicles and be responsible for the accidents they commit too, but so many hit and take off. Some I have found to have license plates that have fictitious names and addresses - how's this possible?
Hi I'm the Organizer for the Philadelphia English Bulldog Meetup. We meet every month (weather permitting) on the 2nd or 3rd Saturday at alternate locations. One is at the Canine Creature Comforts, 81 Lancaster Avenue , Malvern, PA or at the Schuylkill River Dog Run, South 25th Street between Locust Street & Delancey Place, Philadelphia , PA 19103. To get notices every month, you need to become a member of the Meetup Group (they also have other types of meetup groups you can join) on this site,
http://www.meetup.com/login/?returnUri=/. The next meetup is scheduled for October 14th at the Canine Creature Comforts in Malvern, PA.
Sometimes we have special parties (finances and participation permitting), they would be scheduled and announced separately from the actual meetup and to be informed, you need to be a member, its free. There's also a Message Board bulldog lovers can post on, there may be helpful information on there about a problem with your bulldog.
AMc
