[ SHOWGSD-L ] NC<>Guilford County Animal Control Ordinance Changes
- From: Stormy Hope <Stormy435@xxxxxxx>
- To: show list <showgsd-l@xxxxxxxxxxxxx>
- Date: Sat, 11 Sep 2010 10:22:40 -0700
Check the wording... borrowing from PUPS and the AVMA Model Legislation
Stormy
From Susan Wolfe
NCRAOA
(North Carolina Responsible Animal Owners Association)
Begin forwarded message:
Guilford County Animal Control Ordinance Changes
A public hearing is scheduled for September 16, 2010 at 5:30 PM in the
Commissioner's Meeting Room, 301 W. Market St., Greensboro NC.
Guilford County plans to update their existing animal control
ordinance. Although the county already has a comprehensive ordinance,
a kennel raid last spring provided the impetus for a new set of
extreme and detailed regulations for dog breeders.
Under the proposed regulations Guilford County plans to license and
inspect newly created classes of "high volume breeder", defined as
anyone who breeds more than 6 litters a year and "high volume
retailer", defined as anyone who sells or transfers 50 or more dogs
per calendar year. Mandates on these newly created categories of
breeder/sellers include: permitting; inspection; hiring of trained
staff as employees; diurnal lighting cycles; yearly vet exams; prompt
veterinary treatment of any and all illness or injury; records of
veterinary care; conspecific socialization between dogs; inanimate
environment enrichment (toys and structures); visual enrichment;
access to locomotory activity; documented programs to determine cause
of any displayed aggression; inspection by Guilford County Animal
Control personnel without prior notice; and more.
It is flawed logic to use numbers as criteria for regulation. While 6
litters in a large breed could be 40 to 50 puppies, in a toy breed
this could be as few as 6 to 12 puppies. Regardless of the number,
there is no correlation to quality of care. Two dogs that breed and
have puppies in the backyard of an uncaring owner can be in far worse
condition than 50 dogs in a well-maintained family-run kennel.
Further, this proposed criteria does not take into consideration co-
ownerships.
The definition for "high volume retailer" includes "..sale, resale,
and transfer that occur via the Internet", which will encompass rescue
organizations that use multiple foster homes who collectively sell 50
dogs/puppies in a calendar year, use their websites, the Internet and
Pet Finder to find buyers and conduct business.
The proposed ordinance "borrows" language from both the USDA Animal
Welfare Act and the newly introduced American Veterinary Medical
Association (AMVA) Guidelines for the dog breeder/seller regulations.
It has always been clear that the intent of USDA was to regulate
breeding and selling of dogs by commercial operations directly to
commercial outlets. The regulations were also geared to the well-being
and care of dogs housed and raised in research facilities. Notations
and background contained in the AVMA Guidelines are also drawn from
papers written by researchers for research facilities, sometimes based
on mere theories on animal behavioral needs. This level of regulation
is NOT and NEVER was intended for private breeders.
The requirements written into this proposed ordinance are so over-the-
top they defy any possibility for actual enforcement. There are no
standards for behavior protocols in the Federal Animal Welfare Act,
and to our knowledge, at any state level in the United States. These
requirements would be so varied among breeds, that any standards would
be nearly impossible to set. Further, "necessary behavioral needs" is
so poorly defined from a scientific sense, it would be unfair and
impractical to expect a breeder to develop a "documented protocol",
build facilities, and hire staff to meet these intangible "needs."
The proposed regulations mandate conspecific socialization/providing
full body contact. This is completely impractical for a number of
breeds of dogs, in which adult dogs (especially adult dogs of the same
sex) are assumed to be incompatible, based upon history of the
development of the breed.
Examples of such breeds include livestock guardian breeds (e.g.,
Anatolian), certain primitive breeds (e.g., Canaan Dogs), and bully
breeds (American Staffordshire Terrier.) Mandating full body contact
daily invites injury from aggression and too easily spreads disease,
and is impractical except for certain breeds highly compatible when
kenneled in established packs (Beagles, Foxhounds, etc) or among small
home breeders where a small number of dogs permanently live in a home
and are continually monitored for compatible behavior by their owner.
The proposed ordinance also mandates that "inanimate
enrichment" (toys) be provided in the kennel. This concept is borrowed
from the newly created AVMA welfare guidelines which use as a basis
for this recommendation a report entitled, "Comfortable Quarters for
Dogs in Research Institutions (Hubrecht, 1993)." Research facility
design and protocols have no bearing or relation to private dog kennels.
The same report reminds readers that "It must be remembered that dogs
have different personalities that are a product of their genetic
makeup and personal experiences" and "Any enrichment device has to be
practical, provide a measurable benefit for the animal and should not
interfere with the aims of the research protocol."
The fact "all dogs are different" can readily translate to mean that
many adult dogs are aggressive chewers well into normal adult age, and
are not safely left with toys, bones, or rawhide while others have no
interest in inanimate objects. The same article also states:
"Objections are sometimes made to enrichment items such as chews/toys
because it is considered that they can trigger aggression and cause
hygiene problems, or simply because the dogs lose interest in them."
Simply stated, mandating "inanimate enrichment" is excessive, invasive
of owner rights, has no basis or value in a private kennel setting,
and is lacking in reason. There is no chew proof toy or chewing bone
(no matter what the toy manufacturers say). Placing a toy in a cage
for a puppy or young dog, without constant observation, is an
invitation to disaster; should the puppy or young dog chew up and
swallow pieces of the toy, they could easily choke or develop a fatal
intestinal obstruction.
Is Guilford County willing to assume liability for injury/death should
the puppy or young dog chew up and swallow pieces of the toy, choke,
or develop a fatal intestinal obstruction?
What plan does Guilford County have to train and certify their animal
control officers in dog psychology, anatomy, locomotory activity, and
behavioral needs in order to assess and approve the required
documented plans kennel owners must write under the proposed
ordinance? We find it unconscionable that untrained personnel would be
given authority to not only evaluate these indefinable protocols at
breeder kennels, but use their determination as the basis to
potentially revoke kennel permits.
The proposed ordinance mandates that the kennel owner "provide prompt
treatment of illness or injury under the direction of a licensed
veterinarian." This would include something as simple as an upset
stomach, torn toenail, bee sting, or any minor issue often treated by
the breeder. In fact, allowing the breeder/owner to treat minor
routine situations would allow these to be treated in a more timely
manner than most veterinary offices could provide, speeding up the
healing process for the dog.
The proposed ordinance mandates "examination at least once yearly by a
licensed veterinarian for breeding dogs." There are no standardized,
specific laboratory tests or specialized reproductive examination
procedures that are suitable for assessing the health status of
bitches for breeding. The veterinarian will only be able to assess
external physical condition, maybe over or under weight or teeth
should be cleaned, and can only make observations that the breeder is
most likely already aware of. The veterinarian has no authority to
perform any treatment not authorized by the breeder/client.
There are no guidelines for what the veterinarian should evaluate or
for what is an acceptable veterinary report to be included in the
kennel documentation. There is no measurable benefit to this mandated
exam and serves only to increase maintenance costs for the breeder.
In addition, the ordinance bans feline and canine hybrids; requires
permitting for exotics, defined as "wild animal or a species of animal
not indigenous to the United States or to North America" (exempts non-
native species used as domestic farm animals and aquarium fish).
Currently there are 3 cat breeds, Bengals, Savannahs, and Chaussies
that would be affected by banning hybrid felines in Guilford County.
Bengals are one of the most popular breeds, worldwide, and the most
exhibited breed in TICA - the second largest pedigreed cat
organization in the US and 3rd largest worldwide. Savannahs are one of
the fastest growing breeds. They compete at cat shows along with
recognized breeds such as Persians, Maine Coons, and Siamese. Banning
these cats serves no purpose, eliminates choice, and would make
criminals out of Guilford county residents who may currently own any
of these breeds. The U.S. Federal Animal Welfare Act defines domestic
x wild hybrids as domestic cats.
A number of definitions have also been expanded or added. For example,
"Dealer, Pet Shop" now covers any person in Guilford County who buys,
sells, breeds, or boards a pet animal and is not covered by either
North Carolina or federal animal welfare laws. Expansion of this
definition therefore includes anyone who sells a dog because they are
moving, or anyone who retires a dog once used for breeding, or anyone
who sells an ooops litter, and every hunter in the county who sells a
puppy that didn't work out for field work; and entitles animal control
to inspect your premises to ensure this animal is not being abused.
Guilford County Commissioners should reject this radical proposed
ordinance in its entirety.
All breeders should be aware that bad ordinances can take a life of
their own and spread to other areas. We urge all breeders to contact
the Guilford County Commissioners and oppose this ordinance.
http://www.co.guilford.nc.us/commissioners/index.php
PLEASE CROSS POST WIDELY
Read the ordinance and more athttp://www.ncraoa.com/Guilford.html
Susan Wolf
NCRAOA
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