Just in from talking to lots of people about this at Mission Circuit,so can tell you that any thought that you may have "thought up," has been thought up many, many times. and answered by more than me, many,many times. One, there is no definition YET, of what is a breeding female... whether it's any intact female from birth to death, so that's a BIG comment to make on the Federal Comments page. On the premises doesn't cover 'in concert with." Another point that needs to be made inthe Comments. It can mean any breeding female that you have ownership interest (same as PUPS) and that if you have those ownership interests, then if your co-owner sells the pup/dog, it is sold OFF your premises and your are caught under the 5 and over ... blah, blah... It was introduced to ward off PUPS and its 'progeny,' for sure, but if it is too weak, HSUS will STILL push that one or one like it next time. We wouldhave a good argument that the the regs were tightened up, Congress people, so why are animal radicals whining and crying about now. It CAN be beneficial, if the bad wrinkles are ironed out, but it's important to go to the Comments, make your own and check out some of the others. NAIA, AKC, SAOVA, USSA, etc., etc., will be releasing their own letter to APHIS and I will get this out as soon as I can. Not tonight :-) <G> Tired Stormy On May 26, 2012, at 10:22 AM, Pinehillgsds@xxxxxxx wrote: That's where I wasn't clear on the definition. (If I don't breed a female, I can make an argument she's NOT a "breeding female"). You'll also see "on the premises" mentioned throughout. I'm thinking co-owned bitches not on the premises don't "count". Here's the text from the PA Federation site: _http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001_ (http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001) I didn't see everything Stormy referred to this AM in there, but I have no doubt that there's been some clarification. Actually, if it cements/changes the definition of "retail", (exempting most of us from licensing and inspections), AND makes PUPS go away while at the same time cracking down on some of the Internet stuff going on, I see it as a plus, but then maybe I've been influenced by the federation. Kathy, member GSDCA, DVGSDC Celebrating generations of Dual Titled TC'd Champions visit _http://www.pinehillgsds.com/_ (http://www.pinehillgsds.com/) In a message dated 5/26/2012 11:38:10 A.M. Eastern Daylight Time, wynsum@xxxxxxx writes: On May 26, 2012, at 6:13 AM, Stormy Hope wrote: Under the proposed rule changes (USDA/APHIS) the rules to allow all who sell dogs, cat, small mammals and exotics are being changed. The rule would be that anybody who maintains 4 or less breeding females (up from 3) <reply> At what age does a female become a "breeding female" 3 months? 6 Months? one Year? This is an important definition/clarification ============================================================================ POST is Copyrighted 2011. All material remains the property of the original author and of GSD Communication, Inc. NO REPRODUCTIONS or FORWARDS of any kind are permitted without prior permission of the original author AND of the Showgsd-l Management. ALL RIGHTS RESERVED. Each Author is responsible for the content of his/her post. This group and its administrators are not responsible for the comments or opinions expressed in any post. ALL PERSONS ARE ON NOTICE THAT THE FORWARDING, REPRODUCTION OR USE IN ANY MANNER OF ANY MATERIAL WHICH APPEARS ON SHOWGSD-L WITHOUT THE EXPRESS PERMISSION OF ALL PARTIES TO THE POST AND THE LIST MANAGEMENT IS EXPRESSLY FORBIDDEN, AND IS A VIOLATION OF LAW. VIOLATORS OF THIS PROHIBITION WILL BE PROSECUTED. For assistance, please contact the List Management at admin@xxxxxxxxxxx VISIT OUR WEBSITE - http://showgsd.org SUBSCRIPTION:http://showgsd.org/mail.html NATIONAL BLOG - http://gsdnational.blogspot.com/ ============================================================================