Normally we want to keep our blog posts about the dogs and what we’re up to with them, but something has come up that we feel is important enough to warrant a more serious post.
The USDA has proposed a rule change to the 40 year old Animal Welfare Act that is a severe threat to the Ryman types and all other rare breeds or strains. Detailed information about the proposal and why the USDA is taking this step can be found here:
http://www.naiaonline.org/articles/article/the-usda-proposed-rule-and-you
http://www.naiaonline.org/articles/article/send-your-comments-to-usda-aphis
In a nutshell, any breeder owning more than four breeding age females who ships even one puppy to a remote buyer, even a repeat customer, would now be required to be licensed and inspected by the USDA. Same goes for a breeder of any size who takes a stud fee pup or buys a potential breeding dog from someone else and later decides to sell it.
Most breeders of Ryman types fall into this category. Most who do (all?), like us, will not be willing to submit to the substantial cost, regulations, and invasion of privacy involved in the licensing requirements. We will basically have two options if the rule goes through. Our most likely response will be to stop shipping puppies, never sell a dog that wasn’t born and raised at our kennel, and hope that we can keep operating. The other option would be to downsize so that we can still ship. We probably would not consider that option because it would be too limiting genetically.
The NAIA web site (linked to above) has many good points about the problems with the rule. In addition, here are some of our thoughts on it.
- You will no longer be able to buy a puppy from most breeders unless you are able to spend the time and extra money to go to the kennel in person to pick up the puppy. The rule would cause substantial extra cost to people who would like to purchase a pup from a particular breeder who happens to be on the other side of the country.
- Small size does not necessarily mean healthier pups. Breeders who don’t take good care of their pups come in all sizes, and we know of some with as few as one or two females who don’t. Conversely, there are large breeders who regularly send out healthy and well cared for pups.
- If we had been limited to only four females during the last 20 years we never could have achieved the progress we’ve made on hips and other health issues (not to mention our goals for field performance, conformation, etc.). Our kennel size is bare minimum to get anything done, and progress can be faster if a breeder is bigger. Inherited health problems are part of animal welfare too, and a rule that encourages only very small breeders will have unintended detrimental consequences to genetic diversity and long term health of the breeds.
- The USDA assumes an average of 1.5 litters per year from each female as part of how they came up with the limit of 4 breeding females, which is vastly over estimated, at least in our experience with Ryman types. This number of litters would require breeding every female on every heat, a practice which is generally frowned on. Breeders who do it are often accused of acting like puppy mills. None of our females have had more than four litters in their entire lifetime. Some have only had one. This is typical of the breeders we know.
- Apparently the USDA has received complaints about the condition of puppies (or other animals) shipped from breeding facilities that are not open to visits from buyers. A kennel like ours, that is open to anyone who does want to visit or pick up their puppy in person, already has the public oversight which is one of the goals of the new rule. In our opinion, licensing all breeding facilities that are closed to visits from customers would be a reasonable alternative to the proposed rule.
A simple way to respond is to sign the AKC’s petition.
http://www.akc.org/petition/
Comments submitted directly to the USDA may be more effective. http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001
We hope everyone will consider this carefully and either sign the petition or submit reasoned comments (or both). The comment period ends July 16th.
I’m running into problems with submission via the website. I plan to “snail mail” my comments if it doesn’t resolve by Monday. Gotta love the government: Let’s write bad legislation, and make it impossible for the voter to give feedback! I may be jaded due to being a falconer…but still!
Some people have had the same problem, but others’ comments have gone through OK. I was able to upload a .doc file the first try- my comment was way too long for their online form:-) Someone has suggested also calling our representatives in Congress, which is a very good idea.
Lisa
As a longtime member of the English Setter Association of America, I regularly receive updates on this pending rule change. It is, in my estimation, draconian, and entirely unnecessary to cast the net so widely as to destroy the hobby breeders in this country. The whole purpose was originally to regulate the puppy mills. The perpetrators of this new dragnet are totally ignorant of the dedicated and honest breeders who sign the code of ethics required by the breed clubs. The vast majority of us absolutely guarantee the health and welfare of every dog we produce, for it’s lifetime. It is ludicrous that the breeders of specialized dogs like our English Setters will be completely shut down by this BAD LAW. I have urged everyone I know, not just dog people, but friends and relatives, to comment and oppose this bill. Who knows what will eventually happen, but I keep my fingers crossed that reason will prevail.
Jacque Phillips
Rimrock Setters
Wenatchee, WA