ASC of Montana Position Statement on proposed APHIS Rules

This document linked below has been respectfully submitted to the APHIS comment page by ASC of Montana Affiliate Representative Thomas A Morarre who is on record as opposing the proposed changes to the United States Animal Welfare Act Definitions and Regulations, as published in the Federal Register by USDA APHIS (Animal and Plant Health Inspection Service) on May 16, 2012

Position Statement on proposed new APHIS Rules –  ASC of Montana

Australian Shepherd breeders, owners, and potential owners, as well as breeders, owners, and potential owners of all purebred breeds, are encouraged to submit their comments to APHIS by the deadline date of July 16, 2012. Comments can be submitted online at the APHIS portal or by mail to the APHIS mail address listed on the
portal: http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-0001

Online comments are limited to 2000 characters each, but multiple comments addressing individual issues are encouraged, as are attachments (up to 10 MB) providing background information on the comments submitted. Since the online APHIS comment form times out after 20 minutes, it is suggested that the writer compose comments in a word processing program, and then copy and paste to the comment form. Background information and APHIS’ explanation and justification for the proposed Rule are also accessible on the APHIS portal, and it is strongly suggested that dog owners become familiar with the wording of the proposed Rule prior to submitting their comments in order to best address specific issues raised by these contemplated changes.

APHIS has especially expressed interest in comments that would show a negative impact on individual breeders’ ability to carry out their breeding hobby or business under the proposed Rule, as well as questions regarding the Regulations and Definitions terminology
used in the proposed changes.

Although this is a proposed agency Rule and not legislation, dog owners and breeders are also encouraged to send copies of their comments to their U.S. Congressional Representatives and Senators after submission to APHIS. Should your comment involve purebred dog breeding, you may also wish to submit a copy to AKC Government Relations at this email address: doglaw@akc.org
The American Kennel Club also has expressed concerns on this issue, and has encouraged purebred dog breeders and owners to submit comments prior to the deadline. For further information, please refer to the AKC Legislative Alert issued on May 17, 2012:
http://www.akc.org/news/index.cfm?article_id=4656
Referring to the “harsh and unintended consequences… on responsible small and hobby breeders” that these changes would bring about, AKC has also set up an online petition opposing the proposed Rule that will remain up until July 15, 2012, and is encouraging all dog owners to sign: http://www.akc.org/petition/

However, in addition to signing AKC’s petition, it still remains essential that all dog breeders and owners submit their own comments to APHIS , especially describing how these changes would impact them personally. APHIS needs to hear from each and every
one of us!

The above suggestions as well as portions of the position statement are based on a document originally appearing on the Norwegian Elkhound Association of America’s Web page.

8/4/2012–There is a new petition that is being sent to congress.
Investigate USDA/APHIS and Stop Proposed Rule to Regulate Pet Sellers Petition | GoPetition