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!
Kevin:   
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.
Susan:
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?
Kevin:
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.   
Roland:   
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? 
Kevin:
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!!
Sarah:
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"?
Kevin:
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.   
Kevin:
Yes, don't worry. All species of pets  are covered.
Cathy:   
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?
Kevin:
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?
Kevin:
Another call about birds? Great! Yes,  birds are exempt.   
Larry:
But you just told the lady from Animal Welfare that all species of pets are included?
Kevin:
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.   
Larry:
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?
Kevin:
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.   
Linda:
Wal Mart parking lot is OK?
Kevin:
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.
Linda:   
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.
Linda:
But I don't ship.
Kevin:
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.
Linda:
I advertise online, sometimes dozens  of dogs for sale at a time.   
Kevin:
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?
Kevin:
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!!
Kevin:
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. |