[gemy]

You are commenting on a Proposed Rule:
Animal Welfare; Retail Pet Stores and Licensing Exemptions (APHIS-2011-0003-0001)


INFORMATION




First Name: FailMiddle Name: Last Name: McLarnonMailing Address: City: TorontoCountry: CanadaState or Province: Ontario Postal Code: Email Address: Fax Number: Organization Name: Submitter's Representative: Government Agency Type: Government Agency:
Your Comment Tracking Number: 8103b05d

COMMENT




This regulation makes very little sense, and will provide a real risk most especially for the rare pure breeds. It puts an unfair burden on the hobby breeder of all breeds. Many times distance especially in our two countries where east to west comprise thousands of miles, making the buyer travel onerous distances to see the puppy in the breeders home.
It particularly makes no sense when you are talking about repeat buyers.
Should the breeder need to/must at times sell sight unseen, the regulations that they will be subject, basically throw out all that is great, good, and necessary for a properly socialized puppy raised in a home environment. Required to keep their dogs and puppies in kennels? Outside of the home? Makes absolutely no sense. These are companion animals destined to live in a family home!

The argument that retail stores provide some sort of "check: on the welfare of the puppies is specious!. Noway does the buying public actually get to see what goes on behind that cute little puppy in the window, or can observe what happens overnight.

And not to put to fine a point on this, you are also creating an unfair advantage on your best US hobby breeders, who will now be at an economic disadvantage when competing against the best Canadian hobby breeders. They will probably need to incur ongoing additional expenses, and have to raise their most valuable breeds in subpar conditions that kennels impose. The socialization of these puppies in particular will be inferior to what can be done in the home.

Just exactly how will you handle co-ownership of breeding bitches, never mind co-ownership that crosses international boundaries.

Just what is the definiton of a breeding bitch? One who is not neutered but never been bred before? One that has been bred but will never be bred again?

How do you think the rescue agencies are going to be able to handle your requirements? Are they now going to be considered a RETAIL agency?