Monday, September 30, 2013

The USDA Wants YOU!


Of concern to all dog owners and breeders in the US are new APHIS rules set to go into effect in November, 2013. The rules are intended to address internet sales, which the USDA alleges are problematic. I'm still waiting to see the facts and figures which provoked that allegation, but am not holding my breath. 

These new rules expand the influence of USDA/APHIS. They will increase the number of breeders who will be forced to comply with USDA regulations. The new rules are ninety-one (that's 91) pages long and are posted on the APHIS website. There is also a Q & A document on the APHIS website, which raises even more questions than it answers.

We do know for certain that anyone who houses more than four intact bitches (or in combination with females of any other covered species) on his or her premises AND who ships any dog by so-called “sight-unseen” methods will now be required to be licensed and inspected by the USDA.

The new rules explanation is vague, leaving many specific questions unanswered. How will breeders be able to comply with commercial kennel guidelines when raising dogs in a home environment? How can I be available during business hours for inspections, when I have a full-time job outside my home? Will rescues be held to these same guidelines? How will that be possible when they do not breed and raise the dogs on their premises? Why is shipping suspect, when all airlines require veterinary health certification prior to shipping? What if you want to sell a dog that is not born and raised on your premises? Why is offering dogs to pet homes considered an undesirable activity, subject to investigation and regulation? What is the definition of a “breeding bitch”? What is the definition of a “working dog”? What proof will be needed for exemption as a breeder working to preserve bloodlines? Why is the Federal government now usurping states' rights to regulate intrastate commerce? Why are small breeders who only sell at retail being subjected to rules meant for wholesalers and dealers?
Unfortunately, during the telephone conference calls with USDA officials, the answers to many of these questions invariably reverted to “we will determine that on a case-by-case basis”. Nothing quite as malleable (and subject to being overturned) as vague rules and guidelines.

The USDA employs animal rights activists in high positions, including Ms. Sarah Conant, formerly an HSUS attorney and now the chief of enforcement at APHIS. The USDA under Ms. Conant has demonstrated a crusader-style, anti-breeder bias, and with these new vague rules that lack specific guidelines, we will likely find that our exemptions are not as available as we think they may be.

The advice from APHIS to breeders is to give the USDA a call, to run your “business model” past them, and then they will inform you whether or not you need to be licensed with them.
USDA licensed breeders have long been subjected to a campaign of hate and discrimination by animal extremist groups. If licensed by the USDA, your information goes public and you may be vulnerable to attack by animal enterprise terrorist groups. These groups like HSUS, PETA, Best Friends and CAPS have conducted smear campaigns against USDA licensed breeders, and they have driven pet shops out of business and pushed for laws making pet sales in retail stores ILLEGAL in certain locales like California. How long until that “no retail sales” mentality is extended to those who sell dogs as! The hobby breeders who are exempt from USDA licensing, because we are in the same category of retail sellers! So we'll be damned if we do get a USDA license, and damned if we don't.

In addition to Ms. Conant, there are other known radical animal rights activist associations at the USDA. The head of the department is Tom Vilsack. Tom's wife Christie was the recipient of HSUS campaign contributions and a near-million dollar campaign television advertising blitz funded by the HSUS in her Iowa congressional bid against Steve King. Deborah Dubow Press, an animal rights activist who co-founded the Student Animal Legal Defense Fund at Cornell University, and received a grant from the HSUS's PCRM, was also employed by the USDA until just last January as an APHIS enforcment specialist.

The “intent” of the breeder is being judged by the Federal government; if you sell mostly pets, then the USDA feels that you need to be subjected to excessive regulations and red tape. The “intent” of the USDA seems clear enough. Though they deny it, it is obvious that they hope that there will be a chilling effect on the breeding of pets. The goal is to gradually and incrementally eliminate breeding of pets.

As a branch of the United States government, the USDA was created to collect and distribute the best farming knowledge.  In 1862, Congress passed a bill establishing a Department of Agriculture. Its mission was “to acquire and to diffuse among the people of the United States useful information on subjects connected with agriculture in the most general and comprehensive sense of that word.” When did we jump the fence and allow the USDA to over-regulate every little agricultural detail? What happened to the mission of EDUCATION?

Who dreamed way back in 1862 that the people at USDA would turn out to be the most threatening animal enterprise terrorists of all?

Sunday, September 22, 2013

Rock Bottom

Imagine you live in a state where it is illegal to buy or take possession of an animal in a public place. Where you cannot buy a pet in a pet store, unless it is a "rescue" or shelter animal that may be trucked in from another state or even another country. Where dogs must be spayed/neutered by law in many localities, and where the state  government actually wanted to pass a mandate that every dog in the state be sterilized. 

In this hypothetical place, you cannot easily own an intact animal. In order to qualify, you must show your dog in competition, belong to a breed club with an enforced code of ethics, and pay a hefty fee. Breeding is out of the question because government requires you to qualify for an expensive breeding permit before you can ever consider the possibility. Any pet that is "adopted" through a shelter or rescue MUST be sterilized BY LAW. There are limits on how many pets you can own. All the while, you hear grumblings on the street that there aren't enough homes to absorb the strays. Well, that last part about not enough homes for the strays is a lie,  but you have heard so many lies told so often, that you now just accept those lies at face value and believe them as truth. 

Now imagine that you don't care too much about any of that, because you don't have any plans to be a dog breeder. You are happy to own an occasional pet or two. None of those problems affect you, right?

Let's see about that. 

Believe it or not, our hypothetical state actually exists. It's called CALIFORNIA. 

So, one fine sunny California day, you decide that you would like to get a puppy of a certain breed that you have long admired.

You pick up the Los Angeles Times and pull out the classified ads. You quickly scan to the "Pets for sale" section. Notice anything strange? Where there used to be dozens of ads for puppies and kittens on a daily basis, now you are lucky to find a handful. And darn it all, there is NOT ONE AD for the breed you want.

You go to your local pet store. They do not sell pets, they inform you, only pet supplies. Maybe on the weekend you can come back when they have an "adopt-a-thon"?

So now, you are looking online, researching about the breed of puppy you would like to buy. You come across a website that urges you to contact a local breed club for breeder referrals.

You find the local club for the breed you are interested in, and contact them. But no one has any puppies available. In fact, few members are even planning to have any litters in the near future. Even fewer are interested in talking to you, a complete stranger, who could very well be a government agent looking for people breeding dogs "under the radar".

You decide to look a bit farther from home, maybe in Nevada or Arizona or Oregon. Now you are being told, it may be possible to buy a puppy but none of those breeders will ship due to new federal regulations. Can you afford to take time off from work to drive out of state? Can you afford to buy a round trip plane ticket for yourself, and then an extra fare for the puppy?

So there are no puppies available locally in either pet stores or from local breeders. Going outside the local area is too difficult and expensive. Just where will you find a puppy? Rescues and shelters may have a dog that looks similar to the breed you are interested in, but you have no way to know the health history of the dog and its relatives. That makes you feel uneasy. They don't have any puppies, only adults. You really want the joy of raising a puppy of your own. Also, when buying a shelter or rescue pet, there are no money-back guarantees, like the state requires when you buy from a breeder or a pet store.

Sure, you have adopted shelter animals in the past, and they can be wonderful, but you really want a puppy of this particular breed THIS TIME. Why can't you find one? And while researching online, you have read the latest canine health studies that have given you pause about spay/neuter, particularly at a young age. If you are lucky enough to find a puppy or dog of the breed you want through a shelter or rescue, why are you being forced to sterilize your dog, when you don't want to?

So now, you are starting to get pretty pissed off. You can actually feel your knickers twisting, and it is quite uncomfortable. What right does the government have to limit your choice of pet and what you do with it? Why all the insane rules?

Maybe you give up, throw up your hands in frustration, and settle for a pet rock. Or maybe, just maybe, you mobilize your family and friends and insist that your politicians answer to you for the anti-pet laws they are passing on a regular basis.

Once you have hit rock bottom, please don't settle for a pet rock. Speak up! Elections DO have consequences, and we are now paying the price for electing current AR-friendly politicians at the state and federal level. 

Here's a novel concept. How about we vote for those politicians who uphold the constitution and preserve the rights of the individual? And make sure to let them know WHY you are voting either for or against them. 

Two thirds of US households own pets. Once politicians realize that we are a voting force to be reckoned with, they will not be so eager to pass such oppressive laws.

May you find the puppy of your dreams, but at this point, I'm not real optimistic about that possibility.

Wednesday, September 18, 2013

Read Between the lines - USDA Conference Call

I've got the transcript in front of me from the USDA conference call regarding the new rules for retail pet stores, that took place on Sept 10, 2013, Thanks to the Sportsman and Animals Owners' Voting Alliance! I've also listened to the recording of the call, courtesy of The Cavalry Group. After examining the details of the call, I tried to imagine how it might go with a "read-between-the-lines" interpretation. Here we go!

Welcome, callers. After suffering years of much yammering in our ears from scam groups like the Humane Society of the United States, the Doris Day Animal League, the ASPCA and other radical animal extremist groups, we are posting new rules limiting your exemption from the Animal Welfare Act as a retailer of pets. Dogs, primarily. But of course we will combine different species to "count against you" in order to limit you further.
We've discovered that 80% of breeders out there are hobbyists and are escaping our iron fist. That will never do! We want them to change to a business model.

The humaniac supporters of our new rules claim that USDA licensing is the hallmark of a "puppy mill". We're not so sure about that, but we are really listening to them. It seems that even though they don't like USDA licensed breeders, they want to have thousands more of them. Go figure! But, we need the money so we're anxious to get started. Why, they've already greased the palms of the politicians who appoint us with millions of dollars! We are DETERMINED to please them! Maybe we'll enjoy more of that sweet gravy!

We relied on the HSUS and other animal fanatics to help write up these new rules. They decided that you should be allowed no more than four female dogs on your premises. Any intact bitch "counts against you" as long as she is not too old or too young. But we will be the ones to decide if she "counts against you" or not! It's good to be queen, no? We don't bother with those pesky little details, like whether or not she is ever actually bred.

Further, our good friends, the humaniacs, insist that you must have a face-to-face meeting involving buyer, seller and the pet when the transfer is made. This doesn't need to be at your home, where you could be robbed at gunpoint or targeted by animal rights nuts who enjoy turning breeders in to authorities for any infraction of rules or laws, whether real or imagined.

No problem! You can meet in the WalMart parking lot. Just like all the people who sell sick dogs out of the backs of their trucks that they brought up from Mexico a few days ago.. You just go ahead and model your business practices after them. Many of them claim to be "rescues", so we can be sure that they are more noble than the rest of humanity. We like those "rescues" because they don't intentionally breed dogs. At least, we can't prove that they do, so no point in pursuing them. They are exempt from any and all rules.

Even though all dogs shipped currently are examined by a veterinarian, we have no confidence in the ability of a veterinarian to evaluate health. A veterinary health certificate is useless, even though all airlines currently require one to ship a dog. The buyer knows better than a veterinarian if the pet is healthy or not. Besides, we really don't care about health. It's all about getting snitches into your home in our quest to stop you from breeding.  

We are fully aware that hundreds of thousands of you oppose being brought under wholesale, commercial breeder regulations. We also know of the many concerns you have and exactly WHY you are opposed. We've read all of your comments, petitions and letters; but frankly, WE DON'T CARE. These are the new rules. If you don't like them, then you can just quit breeding dogs. Please.

We are only here today to explain to you, the BREEDERS who sell and ship sick, genetically defective pets to poor, unsuspecting buyers, why you can't do that any more. We will answer your questions if we feel like it. Regarding the questions we don't understand or don't want to be truthful about? Well, we will simply hem, haw and hedge.

Frankly, we don't like the fact that the information superhighway has facilitated sales of pets. Things have just been too easy lately for buyers and sellers. We prefer the days when people had to rely on classified ads in newspapers or the back of magazines to sell pets. That really put a cramp on pet sales, and we appreciated that. We really thought it was terrible that Sears, Roebuck and Co. sold dogs by catalog, but we could never figure our any way to "get" them for doing that.

Until now, that is.

We initially provided estimates on how many more breeders we thought we would be licensing, but we really doubt that will happen. We know that most of you will give up your dog breeding entirely, or at least cut it back significantly. If you want to give USDA licensing a whirl, we anticipate that you will need a one-time investment in an amount to effectively double the size of your current mortgage, to convert your home into a commercial kennel. Of course, your local zoning laws will prevent that anyway, so don't worry! It's all good.

OK let's get right to those questions! Who is first?

Susan from Virginia Federation of Dog Clubs and Breeders:
My dogs both work in the field and are pets and are show dogs, too. Must I become USDA licensed? What do you consider a "working dog" for purposes of exemption?

Dr. Russian:
Let me get this straight, you have a dog who does multiple things?

Susan: Right.

Dr. Russian:
Wow that's incredible! Then you must keep separate kennels. Dogs that work must be kept separately from dogs who are pets.

But it's the same breed. It's the same dogs. All my dogs have multiple uses. They are retrievers, they hunt. I don't keep them in kennels. They are house pets too. Would hunting dogs and retrieving dogs be considered "working dogs" for purposes of exemption?

Dr. Russian:
What a conundrum. I really don't understand the concept of dogs having multiple uses and purposes. I suggest you call me and run your "business model" past me. That way I can figure out the best way to harrass you, OK? And make sure to tell all the other people in your group to call me, too! Next caller.

Roland from the National Finch and Softbill Society:
Are birds exempt? What about birds or dogs bred to a breed standard? How many comments opposed your new rules? Will the USDA contract out their inspections?

Birds are exempt. That's why we took your call. Geez, why did you have to ask other questions too? Who the hell is screening these callers?

Well, let me try to tackle the other questions, since this is probably all going on the record. We have no plans to outsource inspections at this time. Why should we when we have HSUS lackies employed right here at the USDA for that purpose? No comment on how many comments were submitted in opposition to the new rules. We frankly don't care. As to standards, we have our own standards, and they are arbitrary and capricious. That suits us just fine. We don't care about you.

Again, why are show standards not taken into consideration?

Dr. Russian:
The rules are up, read them and get back to me. We've already told you, we don't give a shit about show standards.

Sarah from HSUS and Doris Day Animal League:
We are SO EXCITED that OUR new rules are going into effect!!! We only hope that they can do enough damage to really cripple pet breeding here in the US before this gets challenged in court. Our group (DDAL) already tried to push retail hobby breeders into the same regulations as wholesale, commercial breeders, but the courts ruled that we couldn't do that. The nerve of those courts, upholding the constitution! But that won't stop us from continuing on our crusade to ban breeding! My question is, how will you make effective use of your time and limited resources? How soon will you jump on board our bandwagon and start reaching out to bitchslap some breeders?

Not to worry, Sarah and other goodie two-shoes. We want to get to the most people as quickly as possible in order to protect animals from being exploited as pampered pets. We will look initially at those breeders we can catch who appear to have high volume, then we will be happy to take complaints from humaniacs such as yourself. So we will be depending on you guys from HSUS, DDAL, CAPS and other to help us out here, OK? Please don't let us down!!

We are ready, Kevin!! We won't fail in our quest to shut down every dog breeder in the US! Thanks again!

Jennifer from the HTPCB:
What is the definition of a "breeding bitch"?

It doesn't matter as long as you let people into your home to inspect you. Why are you breeders so hung up on definitions? We make the definitions up as we go along.

Dr. Russian:
Breeding FEMALE (oh I just can't bring myself to use that "B" word!). I say, it's a dog that can breed. Ultimately, we decide what does or does not "count against you" for your numbers limit. End of story!

Cathy from Animal Welfare Institute:
Hallelujah! Our prayers have been answered! New rules to put more pet breeders out of business. I just want to be sure you cover each and every species of pet. There is too much animal suffering, forcing them to be pets.

Yes, don't worry. All species of pets are covered.

Whew! Thanks again!

Tracy from the HSUS:
We are thrilled that those greedy, evil breeders will now be forced into the USDA system or quit breeding entirely. Thrilled, I tell you! When can we get started?

Well, by law, we have to wait 60 days to start enforcing any new rules. However, our motto here at the USDA is "why wait on legal technicalities"? Let's start right now looking for people to harrass by going through breed registries and looking at people advertising on the internet. We hope they will voluntarily just give up breeding on their own, or turn themselves in for enforcement, but if not, don't worry, we'll be on the lookout for them.

Larry, President of North American Falconers Association:
Are birds exempt?

Another call about birds? Great! Yes, birds are exempt.

But you just told the lady from Animal Welfare that all species of pets are included?

Well if you were looking for honesty, Larry, this is the wrong place to be. Birds are exempt. We haven't figured out how to include them "at this point". Our friends at the HSUS are helping us work on getting standards in place to regulate birds.

Great!! Birds are exempt! Yay!

Linda, hobby breeder:
Currently buyers all come into my house. I don't ship. So I'm a retail store, right?

You are covered.

Dr. Russian:
People don't need to come to your home for you to be exempt. Don't listen to Kevin, he doesn't know what the fuck he is talking about.

Wal Mart parking lot is OK?

Sure, why not? But be careful not to get arrested in the states that have laws against sales in public places. Those new laws are awesome!! Hooray for HSUS! We're so glad to see that selling animals is now a crime in many places.

My daughter and I both have breeding bitches, she has three, I have five. I also am a broker for other people. How does all that work? These new rules are confusing.

Dr. Russian:
We see intact dogs on your premises, they are being counted. If you don't ship any dogs you are not covered. But now that we know you are a dog breeder and broker, we are going to definitely have you on our radar screen.

But I don't ship.

We will wait, maybe, for a few months or even years before we start to go after people like you. But rest assured, we WILL be coming after you eventually. What we say now, and how the rules are written, may be two entirely different things.

I advertise online, sometimes dozens of dogs for sale at a time.

Boy, you are one of those upfront, honest people who will be the first to go. SUCKER!!

Since you say you don't ship, we will be leaving you alone. Temporarily. Rules will be tightened up in the future to better protect dogs and persecute breeders.

Deborah from ASPCA:
Thank you thank you! How can we make sure that everyone is licensed within 60 days? How will we go after people who don't apply for a license?

Dr. G:
We will outreach beginning immediately. We will try to get the more naïve to turn themselves in and those who don't, we will be on the lookout for them. Rest assured, humaniacs, that your wish is our command.

Carla, breeder of Aussies:
There is an exemption for working dogs. What about stock dogs? And, if I have a state license, why do I need a license with the feds?

We don't care how many layers of bureaucracy you have to contend with. The more, the better. I don't know what a "stock dog" is so I'll let Dr. Russian address that part.

Dr. Russian:
Good God, I don't know what a "stock dog" is either. But if it isn't used for research, teaching, testing, experimentation, exhibition or use as a pet, then we can't sink our meat hooks into it. Darn.

Kara from MPBA:
Can we advertise on the internet as long as we don't ship? What about my stock dogs? What if I say I'm selling breeders? Can't you give us a few loopholes to work with?

Dr. Russian:
We LOVE people who advertise on the net, that's where we will go a-huntin' for breeders. So advertise away! Your business model is what we are looking at. If you sell dogs, then how you do it is OUR decision!

After all these questions about dogs for stock, I am really wondering now what the heck you are talking about. Stocking the shelves of your stores? Making soup? You breeders are really wierd!!

We are from the government, and we are here to help! Restraint of trade is what we do best. Who needs free enterprise? Phooey.

We suggest if you are confused about the rules that you call us so we can begin to investigate you immediately. We need to know about your "business model" even though you are a hobby breeder, not a business. We don't take into consideration your profit or loss, only the fact that you dare to sell pets. At the end of the day, that's all that matters. We are here for the animals, and as long as we draw breath and continue to collect our six-figure salaries (provided by your tax dollars), we are committed to continuing to dream up new ways to screw over anyone evil enough to breed pets.

I will happily refer those of you with further questions to our knowledgeable enforcement division: Sarah L. Conant, former lawyer for the Humane Society of the US, and animal rights extremist Deborah Dubow Press. They are waiting to prosecute you to the fullest extent of the law. They'll even do it with a smile!

And, if we can drive a few breeds extinct, or prevent someone from getting the dog of their dreams, then our efforts will not have been in vain.

The dog of tomorrow, once breeding is stopped.

Wednesday, September 11, 2013

USDA Strikes Again!

Way back in 1966, the USDA was given the authority to regulate commercial dog breeders. Hobby breeders were OK with that, as they felt exempt. After all, they were not commercial breeders and never would be, right??

Well, surprise surprise. It took a few decades, but now the animal rights nuts have succeeded in their campaign to regulate just about everyone who is NOT a commercial breeder right out of existence. Here's what we get for allowing the USDA carte blanche over our trade.

Despite literally hundreds of thousands of written objections from groups and individuals, new rules are going into effect that will force many small breeders to apply for a commercial breeders' license with the USDA.

If you so much as ship one dog "sight unseen" to a buyer in another state or another country, you will need to apply for the privilege of USDA licensing and submit to unannounced inspections. Got a job outside your home? Travel to show your dogs? Too bad for you! You need someone at home during business hours so the almighty government bureaucrats can tell you how you should be raising your animals.

Why should breeders be forced to allow strangers to traipse through their homes? People have had puppies stolen at gunpoint by allowing strangers in. Other have been turned in to the local animal control department by AR nuts with an agenda who came into their home under the guise of wanting to buy a puppy. There is no animal welfare regulation anywhere that trumps human rights. Not in MY book.

Some of the biggest violators of animal welfare will, however, be exempt from this new rule. Every day we hear on the news that some fly-by-night "rescue" has sold sick dogs, or an animal shelter has imported dogs from another country, so they can have products to sell. Not one SHRED of regulation involved there.

If that isn't bad enough, anyone who owns more than four "breeding females" also will be required to apply for a USDA license. What is a "breeding female", you might ask? Why, it is ANY intact bitch over the age of four months old. Doesn't matter if they are actually ever bred, or not. The USDA has declared that only they shall determine if an intact female is exempt from being considered a "breeding female". You can bet your bottom dollar, if she is intact, she will be considered "breedable".

Small breeds with tiny litters require that we keep many more than four intact females to have a meaningful breeding program. We might like to keep them intact and grow them on for evaluation, or so that we have a variety of bloodlines to ensure health and genetic diversity. We might like to keep them intact so they can have the necessary hormones to develop normally and avoid painful orthopedic problems like hip dysplasia, patellar luxation or bone cancer.

But none of that matters one whit to the USDA.

What's all the fuss about anyway, why not just get a license and keep all the intact dogs you please?

I'm glad you asked.

People NEED to know that while they are frantically trying to decide if they should go the USDA route or not ---- it is IMPERATIVE that they know the first greatest risk is that all USDA facilities (those holding licenses) are listed publicly with the following information:

Names (These would be the breeders)
Address (Yes, that's your home! Online for anyone to see)
Phone numbers (No - you get no privacy!)
The number of animals at the time of inspection.
Any violations.

Aerial views of your house and property are available online once an address is obtained. From there you are easy prey for harrassment from any animal rights anti-breeding nut job. Because, you know, according to the animal rights people, every USDA commercial breeder is a PUPPY MILL.

Ever checked the website of "CAPS"; the "Companion Animal Protection Society"? They dedicate their existence to harrassing pet shops and commercial breeders until they can manage to bully them out of existence. There are big groups on Facebook dedicated to finding all USDA-licensed facilities and publishing them on FB in order to hunt down, harass and, in essence, destroy them.

Being a USDA licensed breeder is a big red flag screaming "COME AND GET ME".

The government's idea is that these new rules will help to regulate commercial breeders who currently skirt the AWA by selling online instead of through a retail pet store. If anyone can avoid the iron thumb of the USDA, I say more power to them! We already have state and local laws to cover animal welfare.

Neither the federal, state nor local agencies have the funds to fully enforce all the intrusive laws currently in effect, so enforcement will primarily be complaint-driven.

This makes us literally sitting ducks for these anti-breeding humaniac crusaders.

On a more mundane level, people who breed dogs as a hobby already operate in the red, but now they will find they need to spend even more money to paying annually for a Federal license.

This factor alone could force many people to stop breeding wonderful dogs. How many more breeds will face extinction?

To get your USDA license, you will need to comply with all requirements of the Animal Welfare Act. This includes housing standards that are difficult to meet in a home environment. Carpets and upholstered furniture are forbidden in the dogs primary enclosure. Stuffed toys are a no-no. Concrete is preferred. Regular use of harsh disinfectants is required. Want to raise a litter in your bedroom? Fuggedaboudit.

Free run of the house is a red flag. APHIS admits as much in their Q&A "Factsheet". Most hobby breeders allow their dogs free run of the house, and wouldn't want to have to change that.

Phooey on the USDA!

A Federal Bill dubbed "PUPS" or the "Puppy Uniform Safety and Protection Act" was proposing similar requirements, but now they don't even need to pass that bill, we've already got the government flexing its muscle to control us without even so much a a vote on the matter!

Where is Ron Paul when we need him? Abolish the USDA!