[ SHOWGSD-L ] Fwd: [TX_RPOA_E-News] Report: USDA Conference Call & APHIS Rule
- From: Bokenkampgsd1@xxxxxxx
- To: showgsd-l@xxxxxxxxxxxxx
- Date: Wed, 8 Aug 2012 14:01:16 -0400 (EDT)
There are many suggestions for comments on the new APHIS proposal....if you
have not made a comment yet please do and do it today. The regulations are
absurd and they WILL affect you...each and every one.
Molly
____________________________________
From: rpoa@xxxxxxxxx
Reply-to: TX_RPOA_E-News-owner@xxxxxxxxxxxxxxx
To: TX_RPOA_E-NEWS@xxxxxxxxxxxxxxx
Sent: 8/8/2012 11:29:58 A.M. Central Daylight Time
Subj: [TX_RPOA_E-News] Report: USDA Conference Call & APHIS Rule
TX-RPOA E-News
>From RPOA Texas Outreach and
Responsible Pet Owners Alliance
Crossposting is encouraged.
August 8, 2012
Deadline for USDA Comments was extended to August 15, 2012. RPOA urges
everyone to request withdrawal of this massive overreach by the federal
government! Pets don't grow on trees and HSUS continues to push their
"Meatless and Petless" Agenda in the U.S.
.......................................................
By Terry Martin:
MY REPORT ON 8/6 CONFERENCE CALL WITH USDA RE: APHIS RULE
on Tuesday, August 7, 2012
As you all probably know I was on the conference call yesterday (8/6) with
the USDA and the Animal Agriculture Alliance. I was told there were 122
people on that call. There should have been hundreds, but won't go there.
It was conducted as a question and answer of course about the proposed
APHIS
rule that we are fighting against. I have waited a day to report on it as I
am not sure exactly what I got from it. What I write here are my
impressions and if anyone else on the call has anything to add, please do.
For positives, it was at the least a chance to get a feel for where these
people are coming from. I did definitely get the impression that they are
very aware of what we are writing in comments, and also the impression they
are just a bit confused, uneasy. But I wouldn't get too overly satisfied
with that feeling - they have the POWER in the end. I would just say our
comments are not just being ignored. They reiterated some things I have
tried to get across about writing comments.
1 Form letters are only considered one time. Letters that simply state the
author is for or against the rule are not considered - they want reasons.
2 This is not a numbers game. It does not matter how many pros and cons
they get - it is the content of the letters that is being considered. They
said every letter is read (obviously by many people) and I believe the law
requires them to do that.
3 Since we were not allowed to comment but only ask questions about the
rule
and the faq sheet they continually said, "put that in a comment on the
site".
They want to hear why the rule is a problem and why the rule is not going
to
do good for animals and buyers.
Who was on the call? Some people never said anything and they did not take
any kind of formal roll call. Sheila someone was there from AKC but did
not
ask questions that I remember. Frank Losey was there and asked quite a few
very good questions. Rob Hurd, Michael Glass, Alice Harrington were the
ones who asked questions who I know from facebook.
They began with asking for agriculture related questions since this was who
they were meeting with. There were quite a few questions about the
"domestic farm animals" wording in the rule, questions about
farmers/ranchers who raise a pet breed but also have livestock and will
the
inspectors have problems with their livestock who are nearby if they are
inspecting the other part of their operation. I got the impression that
they did NOT get the answers they were looking for in any concrete
way...especially as to why they are included in this rule in the first
place
when there are other parts of the USDA that cover livestock. They kept
referring to aimals for fur or food not being covered. I asked about
horses, ponies, donkeys - no answer.
I believe there were more dog people on there than anything else - at least
who spoke. Since this rule appears to be very much aimed toward us, that
was not surprising. The APHIS reps harped on the two things below and
were continually questioned about them - often with no answer other than
"write a comment".
1 The first was the "face to face" transaction that they have decided must
happen. If you have read the proposed rule and then the faq sheet, they
changed their tune between one and the other. In my opinion this is a BIG
one we should hit on in comments!
Originally in regard to what they call "internet sales" but would cover any
sale where the dog is shipped or delivered they say in their document, "As
a
result, customers of these businesses are often unable to enter the
retailer's
place of business to observe the animals before taking it home. Thus APHIS
believes that they lack sufficient public oversight to ensure the humane
treatment and care of these animals."
In their recent fact sheet they changed this to say, "Pet animal retailers
who sell their animals to their customers in face to face transactions at a
location other than their own premises are subject to some degree of public
oversight and therefore are not the focus of this proposal and would not
need to obtain a license."
Whoa! First they want the buyer to oversee our premises and how the
animals
are treated and now we can sell puppies in a WalMart parking lot (that
exact
question was asked on the call) or from the back of a pickup at a flea
market? That is "some degree of public oversight"?
They had no answers that I can recollect on that one other than insisting
the face to face meeting allowed the owner to see the puppy.
2 The definition of "breeding female". I do have a bit of transcript on
that one:
Terry - breeding females - how determined?
Rushin - "We have an exemption for whole-sale, what we currently regulate,
the 3 breeding females. And the way that is done we look at is capacity to
breed. That is a fact by fact determination BY THE INSPECTOR- so we will
look at things as age, physical condition of the dog, and etc etc. So just
because a dog is not spade there still are ..garbled examples??.. where a
dog is not considered, is not part of the breeding females."
Alice - Where are those listed?
Rushin - THERE IS NO LIST. [emphasis added]
Alice - There is no list. So we still have no way of knowing what a
breeding
dog is or isn't.
Rushin - As I've said before - definitely submit that as a comment.
WOW. The inspectors are going to decide whether or not a female is a
"breeding female". In other words we don't know until they descend on us
whether we comply with this rule or not. I would suggest bombarding them
with comments on this one and explaining just why YOU don't consider a
female a breeding female until she is at least two years old and throw a
reference to OFA in there.
The rules constantly refer to dogs sold as PETS. I know a lot of us have
questioned this. I specifically asked if stockdogs such as cattle dogs and
sheep dogs (in case they didn't know what a stockdog is) and livestock
guarding dogs would count under the rule. They immediately said no, they
would be exempt. BUT I understand in the AWA definitions these dogs are
NOT
considered working dogs. Someone else brought up competition show dogs and
I mentioned agility dogs - they hedged all over the place on those
questions.
3 The number of four breeding females. Several people tried to ask them
about (and were told this was a comment, not a question) dogs being shown,
dogs in training, dogs kept back as possible breeding stock but needing
health checks, evaluation etc. They didn't want to even answer this one
but
I would say this needs to be hit hard in comments.
They have three choices after this comment period. They could decide not
to
do it at all. They could revise it. IF they reword it they then can send
it out for comment again OR just implement it. They were hit also on where
does APHIS get the authority to regulate commerce - someone smarter than
me
might want to check that out too.
Last impression - they are hell bent on doing this but are in some way are
considering the comments - they extended the comment time 30 days, have
done
the fact sheet even though it just confuses the issue more, and allowed
this
conference call. This last nine days they need to be hit hard with
arguments against this bill to show it is not going to accomplish anything
toward the welfare of animals and will harm buyers more than it will help
them. If you have had a puppy shipped, now is the time to explain why you
bought a puppy you could not purchase with a face to face transaction and
why it worked for you. Hit them with the number of four females and why
many intact females are not being bred. Comment here and comment again:
_http://www.regulations.gov/#_ (http://www.regulations.gov/#)
!documentDetail;D=APHIS-2011-0003-0001
..............................................................
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