Crossposted:

The Harrisburg Kennel Club Dog Show on Saturday, April 14, offered an opportunity for the American Kennel Club and the Pennsylvania Federation of Dog Clubs to hold a few meetings to bring people up to date on the various legislative issues threatening dog owners and breeders in the state and to offer some information on how to combat them.

In all, about 50 people attended, many on Friday and a dozen or so on Saturday (which was a repeat of part of the second part of the Friday program). On Friday, Sarah Sprouse of AKC gave a presentation on how to combat draconian laws and proposals. On Friday and Saturday Jim Holt, the Federal Lobbyist for the American Kennel Club gave an update on the process and status of the proposed changes to the Dog Law Rules and Regulations.

One of the themes that emerged, following the meetings and in conversations with Jessie Smith of the Bureau of Dog Law Enforcement, was the suggestion that we should compromise. I want to share with you my concern about this concept. Compromise sounds like a nice thing to do, a way to get part of what we want while only giving up a little. But in the case of the proposed changes to the rules and regulations I believe that compromise is a very slippery slope.

The request for compromise is always accompanied by the suggestion that our constituents can be given various exemptions. Of course, this is an effort to divide the “stakeholders” and get them to argue among themselves. Buying our way out with compromise, perhaps at the expense of others affected by the proposal, will simply mean that we will be more vulnerable when the next set of regulations is directed at us. We believe that regulations should be written in such a way that they apply fairly to all those who fall within the regulated community. Although we might not always agree with some of the segments of the dog community that will be affected by the proposal, we should not allow those who would limit our right to breed and own dogs to divide us up and devour us piecemeal.

Although there might be a few items in the proposal that would improve dogs’ situations, there is not enough to make the proposal worth retaining. While we are willing to continue to discuss the specifics of the proposal, our position at this time is that the entire document must be withdrawn. Therefore we are encouraging you to contact your Senators and Representatives directly and ask them to contact the Bureau of Dog Law Enforcement and the Governor, requesting that the proposed changes to the Dog Law Rules and Regulations be totally withdrawn. It will also be helpful for people to write as many “Letters to the Editor” to their local papers as possible. Politicians are very sensitive to public opinion.

Thank you for all your hard work so far. It has made a tremendous difference in this process and has obviously made it clear that the supporters of the proposal are limited to the more extreme animal rights groups. Please contact me privately if you have any questions.

Nina Schaefer
President
Pennsylvania Federation of Dog Clubs, Inc.
pennafeddogclubs@aol.com
www.paonline.com/pfdc
FX: 215 938 1201
1405 Grasshopper Road
Huntingdon Valley, PA 19006

Dear Pennsylvania Friends,

Your Department of Agriculture's December 16, 2006 proposed kennel regulations http://www.pabulletin.com/secure/data/vol36/36-50/2452.html and the public comments submitted on them have been reviewed by the State's Independent Regulatory Review Commission (IRRC). That review totally savages the proposal, giving particular weight to Harrisburg legislator comments, as expected. The IRRC 3.2 MB report may be downloaded at http://www.irrc.state.pa.us/download/2559%2004-16-07%20COMMENTS.pdf Basically, the Department has been told to go back to ground zero and start over from scratch, e.g.

Next steps for this rulemaking
Given the considerable public involvement and legislative interest in this proposed regulation

and the strong support for major revisions in the rulemaking, the Department should work to

guarantee full public review of proposed revisions. We strongly encourage the Department to

organize stakeholder meetings with representatives from all types of kennels to develop a full

understanding of their operations, dogs and clients. In this way, it can develop standards that

will protect the health and safety of dogs while simultaneously recognizing the unique functions

at different kennels. The Department should work with affected parties, experts, concerned

citizens, and the General Assembly to develop improved ideas for achieving its policy objectives

without imposing unnecessary or unreasonable financial burdens.

Section 902 of the Dog Law (Law) (3 P.S. § 459-902) requires that the Department hold a public

hearing before it promulgates final regulations. The Department could use this hearing as one

opportunity for input. We urge the Department to make proposed revisions available for the

public and legislators to review before the hearing. Interested parties could submit written

comments and participate in the hearing. The Department should also publish an Advanced

Notice of Final Rulemaking and provide an opportunity for public comment to resolve any

remaining issues before submitting a final-form regulation.

There's no published timetable for this new effort, but this is a major setback for the rulemaking's animal rights supporters and the Department of Agriculture. Thank you all for responding to SAOVA's call for action and in particular for sharing your concerns with the members of the Senate and House Agriculture Committees.

Freely share this good news.

Sincerely,
Bob Kane
Sportsmen's and Animal Owners' Voting Alliance -
Issue lobbying and working to identify and elect supportive legislators
Help fund our pro-animal owner advocacy via PayPal http://saova.org

It's different state from state?