posted July 13, 2012 10:33 AM            

Form is in link

USDA Proposed Animal Welfare Act Regulation
ASPCA Position: Support, with comments.
Action Needed: Please use the form below to submit your comments to the USDA. Do not delay—comments are due this Monday, July 16, so we will be closing this form at 8:00 A.M. EST that morning. Tell the agency that you support its effort to close a major loophole in federal regulation of puppy mills.

Unlike the breeders who supply puppies to pet stores, the vast majority of breeders selling dogs directly to consumers are unlicensed by the U.S. Department of Agriculture (USDA). Right now, the USDA considers any commercial dog breeder who sells puppies directly to the public, including over the Internet, a “pet store” and exempts them from federal oversight—no matter how large or abusive their breeding operation is. As a result, thousands of dogs are bred and kept in filthy, inhumane conditions with no basic welfare standards. This antiquated view of what constitutes a pet store urgently needs updating!

The loophole means that any breeder who sells puppies directly to the public is not required to open his or her kennel doors to federal inspectors. Unscrupulous breeders have been exploiting this loophole for decades by meeting unsuspecting consumers in parking lots and flea markets—and more recently, by selling puppies online.

This gaping loophole in federal law is under government scrutiny, and we need your help to ensure it is closed! In mid-May, the USDA released a draft of its proposed new rule to close this massive regulatory loophole. The proposed rule represents a meaningful effort by the USDA to target problematic, large-scale breeding operations that sell puppies to the public, sight unseen, by requiring these breeders to meet the minimum care standards of the Animal Welfare Act. While the rule is not perfect, we are hopeful that with your help, USDA will make the changes necessary to fix this problem once and for all.

While we often hear about the plight of the puppies who come out of puppy mills, the mothers of those puppies also urgently need protection. Breeding female dogs in puppy mills are forced to bear litter after litter without any break for their bodies to recover. They typically suffer from lack of proper nutrition, socialization and veterinary care. Support the USDA’s efforts to require more large-scale, commercial breeders to open their kennel doors to federal inspectors.
What You Can Do

The USDA wants your comments on the rule. Join the ASPCA in urging the USDA to make sure all puppy mills are regulated, and that legitimate rescues and shelters are not inadvertently impacted. The agency needs to hear YOU speak out in about this rule! If you haven’t done so already, please use the form below to send an official comment to the USDA today in support of the proposed regulation. We encourage you to enter your own text in the box provided to let the USDA know why this issue is important to you.

On behalf of the dogs, thank you!
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Submit Your Comment to the USDA
Re: Animal Welfare; Retail Pet Stores and Licensing Exemptions
(Document ID APHIS-2011-0003-0001)

Dear Secretary Vilsack,

Thank you for proposing a rule aimed at protecting dogs raised by large-scale, commercial breeders. I support the USDA’s effort to close a loophole that has left many thousands of dogs vulnerable to inhumane treatment without any government or public oversight.

While I support the USDA’s effort to close the retail pet store loophole, in order to ensure that all animals are protected, I strongly urge you to require that buyers be allowed to personally observe all animals on the facility’s property and their living conditions prior to purchasing any animal in order for a breeder to qualify for the newly proposed retail pet store exemption. If the USDA intends to exempt a breeder from USDA inspection, all dogs and their living conditions must be open to buyers’ full scrutiny to truly ensure the well-being of all animals, including those used for breeding purposes. This small adjustment to the rule fulfills the original intent of the retail pet store exemption by allowing the public to oversee what the USDA does not.

Additionally, I ask that you also ensure this rule absolutely does not impact legitimate rescues or shelters. These groups serve their communities by finding homes for needy animals, do not operate for profit, and were never intended to be covered by the Animal Welfare Act.

I commend the USDA for striking an appropriate balance by attempting to exclude hobby breeders while targeting the most problematic large-scale, commercial breeders. Responsible breeders already meet the minimum standards of the Animal Welfare Act and never sell animals without first meeting the prospective buyer.
I strongly support the agency’s efforts to close the retail pet store loophole once and for all. However, I urge the USDA to do so in a meaningful way that ensures adequate protection and oversight for all dogs used in the commercial breeding and pet industry.