CFA Legislative ALERT
Last Updated: August 17 2005
CFA Legislative Group | Legislative Articles | Legislative Alerts
June 8, 2005
TO: Dennis Sprung, AKC President
Members, AKC Board of Directors
Dear President Sprung and American Kennel Club Directors;
I am writing to you, on behalf of the Cat Fanciers' Association (CFA), to express our concerns regarding the Pet Animal Welfare Statute of 2005 (PAWS) S.1139/H.R.2669.
CFA is disturbed that the American Kennel Club, in conjunction with the Doris Day Animal League and the Humane Society of the United States, has participated in crafting legislation that would have serious implications for cat fanciers who breed and register their cats with CFA. Numerous dog fanciers have also expressed their concerns. The PAWS bill poses a significant threat for the very future of our organization, yet CFA was not given any opportunity for input and only became aware of the bill through simultaneous press releases issued on May 26, 2005 from HSUS, DDAL and AKC.
For over ten years CFA has enjoyed an excellent working relationship with AKC and especially with Dr. James Holt who has always in the past consulted with us on federal legislative matters concerning dogs and cats. CFA and thousands of cat fanciers fought alongside AKC and the dog fanciers for over 3 years to maintain the concept of wholesale selling of dogs and cats as the characterization of "commercial" in the Animal Welfare Act. We assisted in achieving the U. S. Court of Appeals decision of 2003 that resulted in overturning the DDAL law suit against the USDA to change the definition of "retail pet store" which would have allowed the licensing and regulation of private home breeders. We are dismayed that the PAWS bill now completely discards the sound rationale all of us developed and supported in our efforts to reject changes to the historical concept of the AWA, which is to regulate the commercial wholesalers of dogs and cats.
Portions of the PAWS bill do not affect cats, such as regulation of those importing or selling dogs from foreign countries, and we realize there are provisions that would improve the USDA's ability to enforce the existing AWA regulations. CFA would reconsider our opposition to this bill if it were amended appropriately, as long as the changes are based on improving the welfare of animals and not related to regulation of breeders who sell directly to the public.
AKC has evidently reached a conclusion that retail breeding/selling of dogs has become a sufficiently large animal welfare problem that warrants this drastic legislative action and reversal of previous objections to retailer regulation. We have not seen documentation to back up this presumption. We know that large commercial breeding of cats simply does not exist to any great extent either at wholesale or retail. Commercial cat breeding is neither a viable nor practical business because of the inherent vulnerability of cats to infectious diseases, stress factors and other reasons. CFA is the largest feline registry in the world. Our breeding activity records indicate that only 66 breeders - throughout the United States, Canada, Hawaii, Europe, Japan and elsewhere - have registered 20 or more litters during 2004. CFA's determination of a "high-volume" breeder is a cattery registering litters that represent 75 kittens/year. All are required to have cattery environment inspections.
We urge you and the AKC Board to not support PAWS as it is written.
- AKC's own policy on "Breeding Restrictions" states opposition to "the concept of breeding permits". Breeder licensing/permits is the most detrimental tool that the animal rights movement uses to advance their goal to end pet ownership, considered by some to be an exploitation of animals. AKC has traditionally opposed federal regulation of hobby/private home breeders or state breeder permit laws and should continue to abide by this policy. Addressing breeding restrictions on the state level in the future would be impossible with this contradiction.
- When AKC decides to "compromise" with organizations who want to stop all breeding this is actually capitulation. AKC has become a collaborator in advancing a detrimental process rejected by dog and cat breeders over many years for sound reasons. HSUS in an article praising the PAWS bill reiterates their well known stance - "the best dogs are the ones available for adoption at the local animal shelter". The PAWS bill opens the door to continuous pressure to lower the thresholds established because HSUS and DDAL consider all breeders to be unscrupulous commercial businesses that should be taxed and regulated by federal, state and local agencies.
- This bill would greatly expand the numbers of facilities/homes that would be regulated and inspected - possibly 5000 more dog breeders and 1200 more cat breeders added to the existing 3000 breeder licensees. This is beyond the limited resources of the USDA. Some wholesaler breeders would also be deregulated, which is not in the public's best interests.
- We have little confidence that AKC could ever assure the USDA can write new regulations that will "likely include appropriate standards applicable to newly covered breeders who breed and raise puppies (kittens) in a residential environment". (from AKC FAQs) Since cat breeders commonly raise kittens in their bedrooms and living rooms USDA standards and inspection procedures would be challenged well beyond their capability. Commercial breeders now licensed will not tolerate different or more lenient standards for hobbyists/retail sellers.
PAWS will not protect or separate hobby/private breeders from commercial breeders. The thresholds established, based on what AKC considers a "high-volume" breeder (sale of 25 or more and/or whelping 7 litters) has no relevance to cat breeding. From our perspective this bill impacts cat breeders with conscientious and moderate breeding programs and concern for genetic diversity. Responsible cat breeding requires mating cats according to their constant heat cycles to maintain the health of the individual cats. In most breeds females will produce more than one litter per year. Fanciers with as few as 4 or 5 females would therefore have to be USDA licensed. This is by no means a commercial breeder.
The outcome of this bill will mean that many serious show exhibitors/breeders will either leave the cat fancy or keep their litters/sales below the thresholds. The availability of fine home-raised cats, as well as dogs in some breeds, will be greatly diminished. When the demand for pedigreed cats and some purebred dog breeds cannot be met by the hobby breeders we believe a change in breeding/selling dynamics will occur that could lead to increased commercial breeding and selling of purebred dogs. While this would be unfortunate for the quality of purebred dogs it will eventually result in the loss of our cherished pedigreed breeds of cats.
The intent of congress and the Animal Welfare Act has traditionally been to regulate the commercial selling and handling of dogs and cats. We hope that AKC will once again respect this concept and withdraw their support of PAWS. We urge you to work to amend the bill to include only the enforcement provisions and any necessary wording regarding the importing of dogs.
Thank you for considering our concerns.
Sincerely yours,
Joan Miller
The Cat Fanciers' Association, Inc.
Legislative Coordinator
JMillerArt@aol.com
Cc Pam DelaBar, CFA President
Thomas H. Dent, CFA Executive Director
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To correspond with the CFA Legislative Committee, please send email to legislation@cfa.org
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