[ SHOWGSD-L ] CO legislative alert- PACFA regulations hearing 8/10/10

  • From: "Ginger Cleary" <cleary1414@xxxxxxxxxxx>
  • To: <showgsd-l@xxxxxxxxxxxxx>
  • Date: Tue, 10 Aug 2010 00:08:48 -0400


Ginger Cleary, Rome, GA
My Blog
Men fight for freedom, then they begin to accumulate laws to take it away
from themselves.  ~Author Unknown


-----Original Message-----


Dear AKC Club Officers, Delegates and Judges,

The following informational update is being sent to you on behalf of the
Colorado Federation of Dog Clubs. Please forward this message on to members
of your clubs.

Sincerely,

AKC Government Relations

Message from CFDC:

Last fall the PACFA (Colorado Pet Animal Care and Facilities Act) department
formed a subcommittee to the PACFA Advisory Committee to review the licensed
dog breeder regulations and update them as needed.  These regulations have
not been fully reviewed since they were initially written in 1995.  The
Federation was one of several dog breeder groups that requested this review
after problems with enforcement by the PACFA program led to bills being
introduced at the state level in 2008 that would have done considerable harm
to the dog community if passed. 

The Subcommittee included interested parties who had applied to be part of
the process.  CFDC was represented by Linda Hart, CFDC Secretary & State
Legislative Liaison, and also by CFDC President Doug Johnson who is a
licensed small scale dog breeder under PACFA.  Other members of the
committee were representatives from rescue, animal control, large scale dog
breeders, small scale dog breeders, animal shelters, PACFA inspectors, and
HSUS representative Holly Tarry.  The discussions took place over about a 5
month period and an agreed upon version was submitted to the Advisory
Committee at their meeting in May.  That draft was discussed and passed on
to the Agriculture and PACFA departments for final drafting and submission
into dog breeder regulations.

What transpired after that is of concern.  The final draft for hearing
approval has had language changes and provisions added that were not
reviewed or accepted by the Subcommittee or the PACFA Advisory Committee.
These changes in some instances significantly changed what was reviewed and
approved by those who participated in this process. Some changes could have
serious financial impact on parts of the pet industries being regulated such
as dog mushers who have an exemption for tethering sled dogs. 

We are supporting the Colorado mushers in their opposition to the changes
added after the fact and not supported by science based research.  In other
areas of concern, language changes were made which do not meet the goal of
clarifying rules to those being licensed, nor were some regulations
changes/additions discussed or approved at any committee meetings.  In
addition, a Cost-Benefit Analysis requested by DORA (Department of
Regulatory Agencies which oversees rules for any regulated industry in
Colorado) was only released on Friday 8/7/10 with little time to review
those findings before the Tuesday morning hearing.  We found the Analysis as
submitted to DORA by PACFA to be lacking in several areas and ignoring
undisclosed financial hardships on some regulated industries. This does not
meet our expectations of fairness nor acceptable practices by the PACFA
department on behalf of those facilities it regulates. 

The Colorado Federation of Dog Clubs, Inc. is requesting that the PACFA dog
breeder regulation amendments as published for the 8/10/10 hearing be
withdrawn from consideration and given back to the subcommittee for further
review and approval by that committee as well as the PACFA Advisory
Committee.  It would then be resubmitted to DORA and the Agriculture
Department for rulemaking review and public hearings.

Please pass this information on to your Colorado clubs and members.  We do
not need attendance at this hearing but any interested parties are welcome.
If you want more information please contact me and I can send you links and
or copies of the data we have used to make our decision to oppose.  There
may or may not be testimony accepted from the general public and the room is
quite small.  Linda Hart and Doug Johnson will be attending on behalf of the
Federation and an update will be sent out Tuesday after the hearing is
concluded.

For more information, contact Linda Hart at  <mailto:kharahs@xxxxxxxxxxx>
kharahs@xxxxxxxxxxxx


Sincerely,

Linda Hart

CFDC Secretary

& State Legislative Liaison

 



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