I think all the readers of this blog know that exempting pet stores (where customers enter the place of business) isn't a good idea.

I think that the government doesn't have enough inspectors to monitor puppy/kitten mills so adding "oversight" on internet businesses most likely won't do any good.

I think that increasing the number of breeding animals for hobbyists will legally allow backyard breeders to produce more animals.

I'm just don't see any teeth in this proposal.

Teeth in the proposal? How about doing what the ALDF has proposed to USDA (look up their letter in comments), allowing private organizations to "help" APHIS enforce this regulation? Yeah, I want anti-breeding, animal rights bullies in my home---NOT! As a long-time, well-respected small parrot breeder, I have clientele all over the U.S. and (1) they are not all going to come to my home (logistics issue), nor do they feel the need to do so; and (2) I am not going to build a $40,000 USDA-complaint facility outside my home for a small, home-based business--I raise my birds in my home, which is as it should be. If this proposed rule passes, I will stop breeding, because I have rare species for which there is little local market--therefore, I ship via airlines to other breeders and to pet owners--and I get new stock the same way. What a loss to many of these species if the "animal rights"-backed proposed rule gets implemented! (Unless, of course, you subscribe to PeTA's declaration, "better dead than bred" or "better dead than in a cage"--so much B.S., it's insulting).

This proposed rule is the last desparate brainchild of the animal rights groups who see the possibility of the end of this year being the death-knell for their influence in federal government (because of potential change in administration from AR sympathizers), so they are going all out to USE the federal government to further their anti-pet-breeding agenda. This rule, as written, would destroy small and medium pet animal breeding in this country, whether through "making an example" of some small breeder [google Dollarhite rabbitry persecution] or harassment by animal rights goons who look for "low hanging fruit" to go after.

It's sad when educated people like veterinarians support the animal rights agenda--whether through true ignorance or hostility toward animal industries.

And another 'fine print' problem that most overlook - even if someone becomes a USDA licensed breeder, they will not be able to breed rare breeds, like the one I have as my search dogs. How many people realize that a USDA licensed breeder can ONLY buy their breeding stock from another USDA licensed facility . . . oh oh, guess that means no more Otterhounds, or Clumber spaniels, or Irish terriers, or Dandie Dinmont terriers, or PBGVs, or border terriers . . . the list goes on and on, with breeds that are so small in numbers now that the AKC considers them endangered. And then there are the dogs registered with the AMerican Rare Breed Association, like Carolina dogs, Penn-mary-del foxhounds. The AKC Gazette breed column this month bemoans the fact that judging applicants can't find enough Neopolitan mastiffs to actually look and and touch, so that they can compare structure and temperament. Komondors are so rare now that the owners and breeders have to network across the continent, on the internet, just to find a location to hold a national specialty where there will be enough dogs to judge. Let alone do breed specific health checks and studies that are so critical to the health of the entire canine gene pool.

And purpose-bred cross breeds come into the picture as well, falling under this rule and would be in instant violation due to the number of intact females that must be maintained for selecting the proper combination of genes. I am thinking of police and SAR folks who are breeding bloodhounds with Majestic treehounds and some other carefully chosen breeds to make a superior scent hound. There are no "designer" dogs as a cash cow, these involve serious genetic studies to preserve drive, stamina, scenting ability, and improve the working ability we so need to save lives.

This rule is so CLEARLY what you say it is, that last ditch effort to get closer to the Animal Rights movement's goal of a petless and meatless society. All they have to do is say that this will reduce cruelty, and Americans are all over it.

It's like banning the manufacturing of automobiles in order to prevent drunk driving.

to think that a vet would support such an invasion of privacy and lack of knowledge about this very damaging "rule".
This rule says ( and forget the "fact sheet" it is NOT the actual written rule and it is sad to see you say that it is) that every person must 'enter the retail store" to buy their pet.. the "retail store" is your HOME for most hobby breeders..this is not always possible nor desirable.
Last year a friend of mine bred a litter of pups.. She lives in a fairly remote area..when the pups were about 3 weeks old her husband had a heart attack and was hospitalized.. so I took the pups to raise and place for her. Several of the pups had been pre sold ( isn't that what everyone wants.. homes BEFORE the pups are born?) Most of the people had been to HER home but none to mine.. a couple of the pups were being shipped to her friends who had known her for years.. This is a rare breed not one you can buy in any newspaper...they had seen the puppies by internet chat sites.. skype and I chat. so they knew what they looked like.. both parents were not "on scene" as she used frozen semen from a valuable dog.. i sent the mother home to be with the owner when the pups were weaned but before they were placed as the husband was very fond of the dog and wanted her to be with him.
so lets look at how many violations would have occurred
1. pups sold from a place where they were not born
2 pets were shipped to people who had never been to my "retail store" ( what APHIS calls your home)
3.People buying a puppy who had never been to the owners "retail store"
and more..
does this seem fair to you?
APHIS is being run by a former HSUS employee one Sarah Conant. Does that seem like a conflict of interest to you?
Animals have been sold 'sight unseen" for decades. Especially the lesser known breeds that will be decimated by this "rule".. many breeds will be at rick of becoming extinct. A musher in Alaska has a dog that they want to send to a friend in Montana.. nope.. cannot do that.. the person in Montana MUST COME TO ALASKA to pick up the puppy to enter the "retail store" of the breeder also known as their HOME.
The internet has not made it easier for substandard breeders to exist.. they have always existed.
These rules if enacted will cause hobby breeders to stop breeding.. exactly what the animal rights radicals want to happen.. Hobby breeders are "easy pickings' as they love their dogs and cannot imagine why anyone would want them to stop breeding and selling happy healthy puppies But oh look Dr. Coates say you can now have four "breeding females' wow such a deal.. note that this includes ANY natural female animal in your home.. three natural dogs.. and two natural rabbits puts you in the category of "commercial' and you will need a USDA license.. which means that your pets will now longer be able to be raised in your home.. that is unless your home can be washed down and sanitized with 180 degree water and much much more..
farmers cannot sell a domestic farm animal as a pet unless the person picks the donkey, goat, horse or what ever at the farmers "retail store'.. so no delivering a pet to a child at another farm unless they have been to YOUR "retail store"
I sent a puppy to a new home last week.. The buyers had never been to my "retail store". The puppy went from a show with a VET ( take note Dr. Coates)friend of mine who also shows dogs.. he lives about three blocks from the people getting the puppy. They saw the puppy through email photos videos and Ichats..they have two small children. Under APHIS rules they would have had to pack them up.. drive 600 miles to my house and back.1200 miles in all plus an overnight at a motel. the kicker.. this is the THIRD dog they have had from me. The first one had just passed away and the boys were devastated. I gave them the puppy so so much for being "greedy" still if I did this under APHIS "rules I would require a USDA license and my dogs wold not be lying under my feet right now but would be forced to be in kennels
Personally I am sick of vets like Dr. Coats who toe the animal rights line And even sicker when she spouts the radical elimination of well bred pets for family homes.
I OPPOSE these "regulations" that will do NOTHING to further the welfare of animals and much to eliminate a wonderful source of pets for the family home. I am tired of the HSUS and other groups hell bent on eliminating animals from our lives. I hope you are as well

And to add to this comment I will share a personal experience that illustrates the power that animal rights anti-breeding groups have over public opinion, and how the word "breeder" has been corrupted, joining the ranks of epithets and dirty names invented by the sick animal rights movement such as 'back yard breeder', 'greeder', 'puppy mill', and so forth. The powerful emotions we all feel when we see images in those heart-wrenching ads all over our TV screens from HSUS and ASPCA have been used in combination with these words to evoke disgust and shame by association. We can no longer rid our minds of these images, and the words now have new meaning.

I dear friend of mine had one puppy left from her last litter when her husband had a terrible accident, so similar to alice in lala land described. That one puppy had a testicle that refused to stay down, so the breeder still had him and had plans to find a pet home for him once he was old enough to tolerate the surgery that was more complicated than a simple neuter op. When this accident happened, she became worried that this puppy was not getting the attention he needed due to the breeder's long hours at the burn center, in PT, follow up doc visits with her husband. So, I picked this puppy up so that he could be trained, socialized and help find him a suitable pet home.

We took him to a local dog recreation area for some off leash play. People commented often on how lovely this pup was, and my husband told them a little 'too much' Bless my hubby, he doesn't get involved in the doggy politics. He had no idea that telling this little guy's story would cause so much trouble. The reaction from people was amazing. First of all, they treated me and my husband like we were some kind of amazing HEROES for doing something so simple as helping out a friend. At first it felt good, until it became clear that the majority of people were also saying, and clearly thinking, terrible, dreadful things about my friend. Things were said like "that poor baby, you rescued him from a kennel', or 'poor baby, he spent his WHOLE LIFE in a kennel (he was a puppy, for god's sake)', 'poor baby, he is so lucky you rescued him from a BREEDER . . .' Each statement was worse than the last, clearly filled with disdain and thinly veiled hatred for someone these people had never met, know nothing about, and had no idea the surroundings this lovely dog lived in - a palatial puppy palace, frankly, like a Bed & Breakfast of the highest quality. I would pay money to stay in this pup's "kennel".

This indicates the terrible hatred people have for anyone who breeds dogs, and these people have no earthly idea what it takes to breed and maintain healthy dogs for THEIR BENEFIT. They don't understand the expense involved, the depth of knowledge, the committment, the amount of love people have for these dogs. Whey does everyone believe that people would breed dogs if they didn't love them? Why? Easy money? HAH!

These people just parrot the propaganda spewed forth by HSUS, PETA and friends, and keep on sending them money to 'save the puppies'. Makes me very angry, as you can probably tell. ;-]

I often wonder what these critics do for a living . . . and do they expect to be paid for their work.

The proposed changes are NOT about animal welfare. Nowhere in the changes are welfare issues addressed. The proposed changes, simply put, attempt to control the METHOD of advertising and the METHOD of sales used by breeders. It limits the METHOD of purchase for the puppy-buying public. As sucn, it interferes with free trade. Additionally, there are serious concerns about violations of the 4th amendment regarind unwarranted searches and seizures SIMPLY BECAUSE A BREEDER CHOOSES TO SELL A PUPPY TO SOMEONE WHO DOES NOT VISIT THE BREEDER'S HOME. These proposed regulations will sound the death knell for the small, responsible breeder, breeders of rare lor low-number breeds, and will severly limit the petowner in his purchase options.

APHIS.. this is one "regulatory agency' we can do without.

First of all, Alice and Amy, both, are spot on with their assessment of this situation. I have another angle to look at this - the working dog world. I have trained SAR dogs for 15 years, returned loved ones to grieving families. I rely on well-bred dogs from breeders who raise their pups in their home, socializing them with family, surrounded by the sights, sounds and smells of a home environment. I also happen to work with a very rare breed, one that I have studied for more than 20 years, dogs that are very difficult to come by, and are not commercially bred, not in pet stores, and certainly not available in the mid west. To get my first one, I had to go to the public media - pre-internet - like Dog World magazine, and the AKC Gazette. Then I had to go through the intense personal grilling from very protective breeders who didn't want their beloved puppies to go to just anyone. Is there something wrong about that? There was no way I was able to drive to the east coast, where most of the breeders were located. Still this breed is rare, and finding one is quite a challenge.

As for working dogs, this rule will wipe out the suppliers of the finest working dogs in America, putting our national security at risk, literally. These dogs come from small breeders, most of which will fall under this rule.

My working dogs (1 aged retired male, and 2 actively working intact females) were DONATED to me by their breeder, in the spirit of community service. She asked only one thing - that she retain control over whether they are bred or not, and to whom, so we CO-OWN the girls. Right away this rule hits us, because between us we own more than 4 intact bitches. This includes one of another breed that belongs to the breeder's teenaged son, who is a top winning Junior Handler who has been awarded numerous college scholarships from the JH program with the AKC and local kennel clubs. Our older girl is not going to be bred, the JH dog is also co-owned by her breeder, and this is now a very complicated situation that APHIS and the general public have no knowledge of, a common practice in the world of show dog. Co-ownership actually means "owner" in this rule, so we are already upwards of 6 intact females. The APHIS rule does not define a "breeding" female, but past history tells us that all intact females in the same household in all other contexts are considered "breeding" females, regardless of age or plans to breed. My younger female has now had all her health clearances done, including hips, which cannot be done before age 2, and the breeder would like her to have a litter this year. Terrible timing if this terrible rule goes into effect. The pups will be whelped in my home, probably be the only litter I will ever breed, but if I find a new owner who can't drive to my home to pick up a puppy, we will be in violation of a Federal law, not something we want to do. But here we are, the owner of my girl's sire would like a puppy, but we had plans of delivering her pup to her at a large dog show about halfway between her home and mine. Bingo, a violation!

The fact is, working dogs come from what most people think of as 'hobby' or show dog breeders, and the rest come from discreet systems like Guiding Eyes for the Blind, who breed their own dogs. But SAR dogs in particular are bred by people who WILL fall under this rule.

I know the intention of the USDA is not to hinder the creation of America's best dogs. They also don't intend to reduce genetic diversity in breeding lines, or wipe out rare breeds - but that is what will happen if this rule happens. Maybe they know this, maybe not, but the puppies that make the very best pets AND working dogs are bred by small breeders, who breed only a select few bitches, maybe produce a couple of litters a year, or even a fewer, or could be like me, who will produce only ONE litter from an excellent representative of a rare breed.

So, in order for me to be in compliance, I will have to tell the owner of my girl's sire that she can only have a puppy if she drives 800 miles one way to "see my facility", in spite of the fact that she has known me for almost 20 years, and owns momma-dog's daddy . . . how ridiculous is that!

And how, exactly, will this rule make the life of even ONE ANIMAL better? How many substandard breeders will this rule actually shut down? If there really is a serious problem of internet sellers abusing animals, where are the statistics? And if there is a known problem, why can't these people be shut down through existing law? They advertise on the internet, how hard can it be to find them? Our own federal government tracks down internet criminals every day, often without leaving their desks. Animals have been sold long distance, sight unseen for hundreds of years, the internet is only a modern day version of magazine classifieds.

And what about rescue groups who use foster homes and search nationwide for just the right homes for dogs and cats? They are already asking for exemptions, but that won't work. There are just as many rescue groups who point fingers at other groups as being guilty of abuse and neglect and other crimes as there are breeders who claim that a "puppy mill" is the other guy. Figure that one out and come out alive, I dare you.

Did APHIS really think this through? Obviously NOT. But wait, this rule change is being demanded by HSUS. There's your answer, folks. HSUS and related groups are known to be anti-breeding of anything anywhere, do you think they really care about distinguishing between good people and bad people? Nope. All breeders are 'bad' according to everything they say, yet so many people go along with this lie.

Instead of reading the fictitious FAQ sheet, read the actual rule. The FAQ sheet paints a rosy picture, and ignores the fact that almost all the large facilities are already USDA licensed. And the people who are avoiding scrutiny are good always going to be there.

The Pet Buyer needs to do at least some homework here, not rely on the government to do their job for them. They can use the internet to look up everything - from the characteristics of the pets they are considering, to the criminal backgrounds of the people who are selling them a pet. The internet is not a tool for people to hide behind, the opposite is true! It is much easier today to learn about the source of your next family member, and you owe yourself and the animals at least that much, that you will do your part.

I can't tell you how angry I am at this whole corrupt mess. It makes no sense at all, and only indicates how a tiny minority of our population with radical, extremist beliefs have infiltrated our society and our government at the highest level.

This is a flawed proposal that fails to solve fundamental problems with the current USDA inspection and enforcement. Under current law the USDA inspects pet dealers who sell at wholesale to pet stores or for research. Unfortunately, there are too few inspectors to police the large, commercial breeders. The May 2010 Inspector General’s report on APHIS operations noted serious enforcement problems. Large commercial breeders with known violations are rarely reinspected. Serious violations are not prosecuted. This proposal does nothing to solve those problems. Instead of increasing enforcement where it is known to be lax, the USDA proposes to go after small, hobby breeders who don't sell to pet stores. Adding well over 1500 hobby breeders of cats, plus tens of thousands of hobby dog breeders and breeders of other species selling pets from their homes would result in an overwhelming drain on federal resources that would lessen the USDA ability to enforce the Animal Welfare Act as it was intended. This expansion of agency authority and responsibilities would diminish the capacity of the agency to carry out the intent of the Act, causing animals to suffer. When you get your next pet do you want a home raised pet or a pet from a poorly (if ever) inspected commercial facility? Leave the hobby breeders alone and enforce existing law.

For several years now I (and all the responsible breeders and rescuers I know, which is a LOT) have hated the loophole that allowed big commercial breeders to sell pups directly to the unsuspecting public, usually over the internet.
If it's designed to catch puppymills who ship puppies all over the country, WHY will it also apply to the breeder who meets someone they know well at a show to pick up ONE dog?
If this law is designed to protect the public, why doesn't it include puppy lemon laws? And if it's designed to improve the care given to dogs in commercial breeding operations - well to be honest there is no county in the US that doesn't already have laws against animal cruelty or neglect, so I don't see any point there.
And if it's designed to get all the large commercial breeders under the USDA umbrella, then WHY oh why will it apply to families with only 4 intact females - including puppies and old girls.
I don't think ANYONE has someone with 4 dogs in mind when they think of "commercial breeder".
What this law WILL do is prevent all those small breeders from raising puppies in their home. The advocates of this law don't realize that this will OUTLAW home raised puppies. Because to be USDA licensed you HAVE to keep your dogs in a kennel, even newborn litters. And they CANNOT be socialized with any animals other than their mother and littermates.
I don't think there will ever be enough inspectors to really enforce this, and many of the small but irresponsible breeders either will never know about it, or will ignore it and blithely continue on.
But it is scaring the crap out of the small responsible breeders.
Who exactly do we want to be producing our dogs in the future? The large commercial breeders are probably jumping for joy over this, because it will be GOOD for their business - soon they will be the ONLY place most people can get a puppy.

@BBRISTOL: "The large commercial breeders are probably jumping for joy over this, because it will be GOOD for their business - soon they will be the ONLY place most people can get a puppy." Of course you are correct. This rule will take away the selling advantage of advertising "home raised" puppies.

I don't see anything good at all in this rule. The HSUS is just tired of their onerous legislation being shot down and 'watered down' for years, that they finally played their last big hand. It doesn't deserve to pass either, but it just might. Follow the money. Sec. Vilsack's wife is running for office in home state, and HSUS donated the maximum allowed to her campaign. There are other political pay-offs involved here, and enough corruption to make Karl Rove blush, and the public doesn't know about any of it.

The 'marketing' of this rule by HSUS is just disgusting. They are using Girl Scouts, for gawd's sake, to shill for them, the troop leaders simply trashing the Girl Scout Promise, which I lived by growing up. It makes me physically ill that these idealistic, impressionable, 11-year-old girls were told lies and were convinced to slander another non-profit, with headlines on ABC News (Wayne Pacelle's fiance is Lisa Fletcher, ABC reporter) that say "Girl Scouts claim the AKC is mean to puppies." These girls were pimped out by their leaders, one of whom is running for office in Maryland, and buddy buddy with HSUS's Michael Markarian. After reading that whole thing I felt the need for a shower.

People need to understand the difference between a 'rule' and a 'law' here. A law is given public hearings, gets votes, goes through a vetting process before it can happen. A rule does not need anything but a wave of the Secretary of Ag's hand. There may be a Public Comment Period, but considering all the federal acts and regulations that have been violated so far, the clear corruption involved in pushing for this, the betrayal of public trust that has happened here, I'm not holding my breath that the comments will mean anything at all. I suspect that this rule has already been bought and paid for.

We'll have to see what happens after August 15th.

Dr Coates says:
"According to the USDA, the current situation has resulted in consumers receiving animals that are too young to be weaned and/or are suffering from contagious diseases, genetic deformities, and other medical and behavioral problems."

I would imagine that most of these pets are delivered by air as trains and trucks ( except for rescue dogs being trucked around the country and commercial breeders sending dogs to pet stores ( they are already licensed)are raely used by hobby breeders to deliver animals..
so.. each animals shipped by air cargo MUST have a health certificate attached to the kennel certified by a licensed veterinarian.. so Dr Coates.. as a veterinarian yourself are you saying the other vets cheat, lie and otherwise allow the shipment of sick, deformed and too young animals Wouldn't it be better for the welfare of the animals to clean up the act of those vets certifying the health of these puppies and other animals rather than expecting the public to do it?

Dr Coates statement is exactly the reasons animal rights and HSUS have given for shutting down pet stores that sell USDA regulated puppies. My, my, my now it is being used to shut down breeders that are most concerned with health because they may fly a dog to a friend that lives too far away to come to their home. Where is the research that supports that remote sales of animals result in less healthy puppies than those picked up from a pet store or a persons home? What qualifications does the average person have to determine health of an animal when picking it up? Whether a puppy is picked up or delivered all new owners should immediately take the pup to their personal vet even though when flown a current health certificate will be included.

"The advocates of this law don't realize that this will OUTLAW home raised puppies. "

sadly that is exactly their goal The HSUS/ASPCA are not only "advocates" of this regulation .. they wrote it

in the right direction - for who? Certainly not for the smaller breeding operations where dogs are part of the family. Dr. Coates, if you believe that your daughter and maybe future grandchildren should have the choice to purchase a puppy of their choice from a breeder of their choice or if they should have the ability to operate a breeding program of the breed or species of their choice in a home environment, then you should take a closer look at the actual wording of these regulations and who will really be affected. there have been a lot of very good comments already and many real life examples were given of situations that would violate the exempt status and make breeders have to become USDA licensend. If you think that becoming USDA licensed is not a big deal, I would suggest to take the time to read the actual requirements and try to envision how you could meet those requirements if you had 4 dogs that were part of your family and you had an occasional litter that you would like to raise in your home.
My breed of choice is a rare breed and there are few litters each year in the entire US. I don't travel because I don't leave my animals in someone else's care, so if breeders that I have known for years wouldn't be able to send me a puppy anymore, what does that do for the welfare of any animal?

The proposed rule will harm more than help. Dogs in cages will be allowed just as they are now under USDA Aphis rules with fees and inspections. The ones that will be harmed are those that are already doing things properly. Small quality breeders will be harmed.

If USDA can't monitor substandard breeders now with all the rules they have in place why does anyone feel they'll be able to with new rules. Every state in the union has rules against animal cruelty why are those not being applied?

The proposed rule will limit the type of dogs available and the ability of ordinary Americans to choose the source of their animals. This will unfairly impact Americans with disabilites, law enforcement, show hobby folks etc.

Quality breeders often refuse to breed a dog they have raised for years if it fails it health clearences or does not realize the quaity needed to ensure the best of the best. Those animals are spayed, neutered and placed as pets. Only allowing four intact bitches will bottle neck the quality breeder into requiring all persons come to their home in order to have the ability to raise an animal longer to be sure of its soundness and quailty.

It will violate the rights of ordinary Americans to pursue happiness and quiet enjoyment in their own homes without giving up some of their rights of ownership. This is a constitutional issue.

Finally, dogs are not the only ones involved. The rule will affect rats, mice, dogs, cats, farm animals, rabbits, hamsters, gerbils, ferrets - etc. What do you think will happen to costs to purchase one of these animals and how much will it cost to get a really quality animal? How will it impact farmers? This rule really casts a very wide net with little sense of what harm is being done.

@ maggie b - You "get it", maggie b, and I am so pleased to read your comment. Have you made a comment on the APHIS site, linked in Dr. Coates's blog? There is a limit of 2,000 characters, but it is easy to upload a longer comment as a .doc or .pdf. Uploading on professional letterhead is helpful. And a personal letter sent directly to Secretary Vilsack's office on a professional letterhead is suggested. I just received confirmation from USDA that my letter was received, and although it was a form letter, the topic was correct, which tells me that it was filed as "opposition". I also cc'd my legislators.

Email to Secretary Tom Vilsack: AgSec@usda.gov

Something is rotten in the USDA. First they propose anti-pet regulations and then they sent out a memo to their employees telling them not to eat meat on Mondays (later claiming it was a mistake). USDA needs to withdraw these regulations that are also a mistake because they will harm pets and consumers and then they need to do heavy duty housecleaning.

I will be interested to see if Dr Coates will rethink her position and blog about it after reading these intelligent thought provoking comments. We ( many of your clients) are dying out here..pushed to the limit by animal rights terrorists who want every dog to come from a "shelter" until there are no more... who abhor the fact that their might actually be people who love and care about their pets..and who are intensely and passionately trying to save certain traits like working dogs.. service dogs and just plain old companion dogs that are predictable and healthy.
ten years ago who would have thought anything like this could happen? That HSUS/ASPCA/Best Friends ( all in the same anti pet boat as long as it bring in MONEY)would have the power they have.. HSUS routinely raids people under the auspices of "helping the police" they have NO government authority ( yet).But they are working on it by pushing these "rules" and other laws that are mirror images.
Every breeder they see that writes "I will no longer breed my dogs, cats. gerbils, rabbits " etc is one more chance for them to dance with joy at the movement of their agenda of NO MORE PETS.. it is not just PETA..
The internet is NOT the enemy.. HSUS/ASPCA/BestFreind/ Mercy For Animals/ ADLF and more are..
so Dr Coates.. what do you think now.. are you with us or against us? There is no middle ground here.

http://www.rodeoattitude.com/facesofag/2012/07/26/usda-still-employees-hsus-plant-sarah-l-conant/

this is a link to a recent "raid" by APHIS on a man who has ( had) a thriving business raising hamsters.. in 21 years he had no violations.. NOW with Sarah Conant of the HSUS in charge he has been fined over 450 THOUSAND dollars which APHIS has gratuitously lowered to 22 thousand .. Ms Conant told him.. "no problem .. you can pay it off monthly".
This agency has been told to get busy and find those violations and to bring in the money.. while that happens more people get out of raising animals .. so with raids and fines like this what do you think hobby breeders will do? Their "retail stores' are their homes.. if you cannot pay there will be a lien put against your home, your court costs to fight this will be enough to make you penniless ( see the Dollarhite rabbit case). this is the worst kind for extortion by a government agency. It must stop.

HSUS is insanity masquerading as authority. Recently, HSUS came out publicly claiming AKC supported large commercial breeders ( HSUS labels as abusers) and did not support smaller show breeders (HSUS also labels as abusers). HSUS even went so far as to say AKC was for leaving dogs in hot cars. Insanity. In fact, HSUS and followers are pushing for these regulations that are aimed at the smaller private in home breeder claiming that the regulations are aimed at large volume breeders. Insanity. HSUS disapproves of large commercial breeders for the way they raise animals, yet are for these regulations that would force many smaller breeders to adopt the large facility practices. Insanity. The comments in favor with chants of all animals are treated cruelly and tortured by all breeders pains me to think that judgment impaired people may be taken seriously by APHIS concerning the welfare of animals. IN the future if APHIS wants input from authority they should ask AKC.

another story. My sister has a whippet.. this whippet came from a well known breeder in the midwest.. this dog is a finished champion that just did not fit into the breeders program.. when my sister decided after years of non pet ownership that a whippet would be the breed for her i put out a call to all people i knew.. this dog showed up.. I met the breeder at a show in southern CA and took the dog.. he was (is) a lovely boy.. came already neutered and in terrific condition. he has been a perfect pet for six years.. this would be illegal under the new APHIS "rules" as neither my sister nor I have ever been to the "retail store' of the breeder who owns more than four "breedable females".
after a few years of loving this whippet my sister decided to get another whippet. so I began the search ( I am a breeder.. she is not) I read about some site that was stopping internet shopping on their "marketplace" because of "puppy mills" "greeders" "backyard breeders' etc..etc.. so hmm I thought I will go to this site to see how many "bad guys" are on it. Just for fun I typed in whippet.. up came a beautiful 8 month old bitch AKC register.. natural.. and ready for a new home.. the seller had another breed and thought perhaps she would like a whippet.. the breed did not suit her.. so she placed the dog for sale..I called her.. she lived about 20 miles from my home.. i sent the photo to my sister and we drove over and bought her that afternoon. This sale would:
1. be illegal under the new APHIS rules as the dog was not "born and raised" at the owners "retail store"
2. would have never taken place at all as internet sales will be restricted or even banned.
meanwhile this lovely bitch has new home .. we entered her in her first show where she was reserve over many other dogs.. my sister now has a new hobby a dog has a great home.. and all is well.

all because of an internet sale..the internet is NOT a bad thing.. it is a TOOL..nothing more.. animals have been advertised and sold "sight unseen" for YEARS through "fancy" magazines like Dog Fancy.. etc..breeder referrals etc. HSUS/ASPCA and others are suing the internet as an excuse to shut down hobby breeders.

I encourage each of you and especially you Dr Coates to go to:
http://www.regulations.gov/#!documentDetail;D=APHIS-2011-0003-8581
type in Laura Sanborn and read her excellent letter in opposition to these "regulations" including many ads showing the past history of dogs for sale through media.
The internet is NOT the enemy.. HSUS is..

OMG On FOX news Pacelle, said that not having home breeders regulated gave them an *unfair advantage over USDA-licensed breeders* (paraphrased). That is like saying a person who bakes cookies for a fair or bake sale has an unfair advantage over bakeries. As I said earlier, HSUS is insanity masquerading as authority. He has time and time again referred to commercial breeders as being abusers putting profit above animal care and now he is concerned about their business? Insanity.

Not only did he say that, but he also said that breeders were "flocking" to support this proposed change. I am very active in the hobby breeder community and I have not found A SINGLE BREEDER who supports these proposed changes. I'm also the rescue chair for our parent club and I haven't found any rescue people supporting this. I am not sure what planet Wayne lives on, but it sure isn't the same one I live on.

HSUS is NOT an authority on animal husbandry. Do you honestly believe that someone who has a degree in history and environmental studies, and does not even OWN a pet, knows anything AT ALL about raising animals?

American public, and Dr. Coates, PLEASE wake up!

might I say he is "flocking " liar.. It is amazing to see him spin his deceitful web of lies with a perfectly straight face.. that is the sign of a pathological liar and sociopath. Unfortunately he is not alone..

Pacelle doesn't care about who is supporting or not supporting this rule - all he needs to do is SAY what he wants to say, regardless of the facts or the truth. He lives by Rule for Radicals, which tells people to simply lie, and when confronted with the truth, rearrange the words in the lie and repeat. And then repeat, repeat, repeat. And distract people, let them go off on tangents, and get lost in details, a great way to take our focus off of the consequences of the lie that was told originally. I brought this rule up to a friend, and before I could finish a sentence, she said "get rid of co-ownerships, and don't worry about it". Sigh. Our media is a sucker for these tactics and join in, repeating lies simply because of who they heard it from. And even people who should know better are thinking that they will just 'fly under the radar'. Oh boy, how dumb.

The APHIS FAQ sheet is a prime example of how to lie with the facts. That whole thing, including the re-write, is FICTION. It's all about sleight of hand. Look over 'here', and while you are looking, over 'there' is what is really going on.

I also want to know of Dr. Coates will re-visit this blog and change her position. This is so wrong in so many ways. It will WORSEN the welfare of animals. That is a fact, not an opinion, or a guess, a hard, cold fact.

As a pet owner, I would not have 5 of my current 7 rabbits if I had to go to the breeder to get them. 3 of them came from the same breeder who is about 3.5 hours away from me. Lucky for me, the breeder was coming down here anyway and brought the rabbits for me. This was on 2 separate occasions about 2 years apart. 2 of my other rabbits I had to have brought up from Oregon (I live in Alberta Canada). Since I don't drive and the cost to fly there and back with 2 rabbits was too much, I would not have these rabbits without great people who are willing to transport and that I can get rabbits without having to see them and go to the breeders house. While I would prefer to see the rabbit before I buy, that is not always possible.
I know that many rabbit breeders will have serous problems if this law is passed. Most do not let buyers onto their property. This is to keep disease out (you never know what someone might bring in), to keep the rabbits from getting to stressed with people coming and going and to protect their privacy. There are stories of animal rights people posing as buyers to get onto someones property, then organizing a raid and taking all the rabbits. For youth breeders, it can be a safety concern to have strangers at their house. Many breeder buy and sell rabbits at rabbit shows, this is how they get more variety and new blood lines as there are many breeders in one area, they would not have this opportunity otherwise. With national shows, this can be a way to get rabbits from across to the country.
While there is risk to buying any animal without first seeing it, a good breeder or seller should be willing to provide pictures, video and even skype if needed for you to see the animal. If needed, they might be willing to get them vet checked as well.

The USDA should have enough to do with regulating pet stores and puppy mills, they don't need to be targeting hobby breeders and those who buy from them.

Dr Coates in your practice how many diseased, deformed dogs have you seen that have bought "sight unseen"by clients over the internet? 100? 1000? 1?
10 per week.. 10 per month.. 10 per year .. compared to your other patients.. how many were purchased by novices "sight unseen' and how many people were "disappointed ' with their purchase..how many said they were 'scammed" into buying the wrong dog?
Where is the buyer responsibility in this? or should buyers always be the innocent party?
If i send a dog to someone.. and a few weeks later it is sick.. is that my fault? if the dog gets bigger or is smaller than expected. is that a "defect"? if after a year the animal bites someone is that my fault as a breeder due to "temperament"?
20% of shelters dogs end up right back at the shleter to be "recycled". how many dogs from breeders do you suppose are returned ?? not many

This is useless legislation. It won't do anything about puppy mills and backyard breeders who don't care about the health and genetic history of the animals they are breeding.

Breeders should only be breeding the best animals to continue a breed...and they don't all have to be show dogs in the end.

I can only hope that people continue to ADOPT and pet stores will some day not be allowed to sell animals.

then I guess we should change the name to "companion animal supply stores" instead of "pet stores' Pet stores sell all kinds of pets.. like guinea pigs ( where I purchased several when i was younger)hamsters. pet rats, birds, snakes and fish. where would people get these pets if not at a store? Do you know anyone who breeds fish that lives close to you? if you wanted a goldfish where would you buy one? a hamster? know any hamster ranches near you? Pet stores serve a purpose..
meanwhile the 'adopt" theory will only work for so long.. if all breeders are driven out of business.. where will you buy a puppy or kitten?
i have a huge failure to understand why people cannot see that the best way to keep animals OUT of shelters is to BUY a dog from a breeder.

Dinosmom, I think your heart is in the right place, but limiting breeders to breeding only 'the best' would mean the end of purebred dogs within a few generations. Why? Because it would shrink our gene pools to the point that the dogs would be so closely inbred that the breeds would die out of genetic diseases of various types. Breeders should certainly not breed dogs with severe faults, particularly those that have a deleterious effect on health, but if we take everything but the best, according to show standards or performance ability, we will not be doing our breeds a service.

As for buying dogs from a shelter (children are adopted, but if you pay money and take something in return, you are making a purchase, whether it is from a breeder, a pet store, or a shelter) that's a fine thing for people who have the flexibility and knowledge to deal with an unknown heritage and history, but those of us who want a particular pet for a particular reason should not have to apologize to anyone for making that choice. And shelter dogs are not alll perfect. As someone else pointed out, many are returned because they are not suitable for the family.

Last year I sold a puppy to a family that had been through three shelter dogs in about six months. My first reaction was that they must be awful owners. Then I listened to the story. The first had separation anxiety so severe that he could not stay in one room when the mother in the family was in an adjoining room. Fixable? Possibly, but the average owner does not have the skills of a trainer and cannot afford the damage to the home -- and possibly himself -- a dog like this can do.

The second dog was so shy and insecure that she stayed under the bed for days, coming out at night to eat and eliminate. This dog had been placed by the shelter with this active family with four kids...a nightmare for that dog!

And the third one was euthanized after he bit three (supervised) children over the course of a week. The last one was a neighbor's child and required extensive plastic surgery.

This is obviously an extreme example, but a shelter dog being the wrong fit for a family happens pretty often. You don't hear about it because the relinquishing owner feels guilty and the shelter is certainly not going to publicize it. The children in the family above were devastated at giving up their pets and had it not. Even for a determined mother, the family would have given up on the idea of a dog.

They came to me, we had several long conversations and a couple of visits. She had researched my breed extensively and when they finally took home an outgoing,well-socialized puppy, it was a perfect fit.

We have sold many puppies to people who have given up on the 'shelter/rescue experience.'
Yes, there are some great dogs in shelters and rescues, but we not doing anyone any favors by implying that this is the right choice for everyone.

Finally, I do hope the author of this article will read the actual regulations. This is the second FAQ Aphis has released and it simply tries to placate people with objections. There is NOTHING in the proposed regulations to back up the assertions in the FAQ. This whole endeavor by USDA has been suspect from the get-go and the ore we learn about it, the shadier it gets. I believe the USDA has its own 'Fast and Furious' scandal in this.

Anyone who has a brain or an ounce of sense knows that Sarah L. Conant the former employee of HSUS now the regulations enforcer for the USDA is out to end all breeding of all animals. She has been closing down all small animal breeders since she has been in office. This women has got to go. This Aphis rule does nothing for large commercial breeders its entire target are the responsible show/hobby breeders. Notice that the number of intact animals not just dogs but intact animals you can own without being licensed is 3. That means all hobby and show breeders must be licensed. This scam is about HSUS through the USDA getting control of all dog breeders who do not make money but love their breeds and show them HSUS wants all domestic animals to become extinct. Any vet who thinks otherwise does not know this man at all.
12 Things You Didn’t Know About The HSUS

1. The Humane Society of the United States scams Americans out of millions of dollars through manipulative and deceptive advertising. An analysis of HSUS’s TV fundraising appeals that ran between January 2009 and September 2011 determined that more than 85 percent of the animals shown were cats and dogs. However, HSUS doesn’t run a single pet shelter and only gives 1 percent of the money it raises to pet shelters, and it has spent millions on anti-farming and anti-hunting political campaigns.

2. HSUS receives poor charity-evaluation marks. CharityWatch (formerly the American Institute of Philanthropy) reissued HSUS’s “D” rating in December 2011, finding that HSUS spends as little as 49 percent of its budget on its programs. Additionally, the 2011 Animal People News Watchdog Report discovered that HSUS spends about 43 percent of its budget on overhead costs.

3. Six Members of Congress have called for a federal investigation of HSUS. In April 2011, six Congressmen wrote the IRS Inspector General showing concerns over HSUS’s attempts to influence public policy, which they believe has “brought into question [HSUS’s] tax-exempt 501(c)(3) status.”  [Ed: Link to Legislators that Get It: http://www.keepouranimals.com/legislators-that-get-it.html

4. HSUS regularly contributes more to its own pension plan than it does to pet shelters. An analysis of HSUS’s tax returns determined that HSUS funneled $16.3 million to its executive pension plan between 1998 and 2009—over $1 million more than HSUS gave to pet shelters during that period.

5. The pet sheltering community believes HSUS misleads Americans. According to a nationally representative poll of 400 animal shelters, rescues, and animal control agencies, 71 percent agree that “HSUS misleads people into thinking it is associated with local animal shelters.” Additionally, 79 percent agree that HSUS is “a good source of confusion for a lot of our donors.”

6. While it raises money with pictures of cats and dogs, HSUS has an anti-meat vegan agenda. Speaking to an animal rights conference in 2006, HSUS’s then vice president for farm animal issues stated that HSUS’s goal is to “get rid of the entire [animal agriculture] industry” and that “we don’t want any of these animals to be raised and killed.”

7. Given the massive size of its budget, HSUS does relatively little hands-on care for animals. While HSUS claims it provides direct care to more animals than any other animal protection group in the US [Ed, not in their own facilities – there are none), most of the “care” HSUS provides is in the form of spay-neuter assistance.  In fact, local groups that operate on considerably slimmer budgets, such as the Houston SPCA, provide direct care to just as many or more animals than HSUS does.

8. HSUS’s CEO has said that convicted dogfighting kingpin Michael Vick “would do a good job as a pet owner.” Following Vick’s release from prison, HSUS has helped “rehabilitate” Michael Vick’s public image. Of course, a $50,000 “grant” from the Philadelphia Eagles didn’t hurt.

9. HSUS’s senior management includes a former spokesman for the Animal Liberation Front (ALF), a criminal group designated as “terrorists” by the FBI. HSUS president Wayne Pacelle hired John “J.P.” Goodwin in 1997, the same year Goodwin described himself as “spokesperson for the ALF” while he fielded media calls in the wake of an ALF arson attack at a California meat processing plant. In 1997, when asked by reporters for a reaction to an ALF arson fire at a farmer’s feed co-op in Utah (which nearly killed a family sleeping on the premises), Goodwin replied, “We’re ecstatic.”

10.  Americans are now requesting the FTC to investigate the misleading advertising of the HSUS.  Heart-wrenching and misleading ad campaigns imply to the public that this is a true “humane society” that houses strays and unwanted or abused pets, and needs “your” $19/mo to do so.  FACTS: Contrary to public, celebrity and legislator opinion, the HSUS is NOT a humane society.  They do not own or operate ONE pet shelter in the entire country; despite their misleading name, they are not a government arm that systematically trickles donations down to the local shelters that to all the actual work.  If they shelter NO PETS, how can they be considered the “experts” on pet care practices?  Their vegan agenda, now unspoken because it wasn’t bringing in donations, is for the eventual extinction of both domestic animals, and all animal use, via legislation.

11.  At the request of over 6,000 grassroots voting letter-writers, representing all 50 States, the IRS is currently investigating the HSUS as to its under-reporting and over-lobbying activity as a 501©(3) organization.  Millions in back-taxes and penalties could be assessed if the IRS would conclude this 3-year old investigation.

12. Congressmen are now urging the Justice Department to investigate HSUS non-compliance with the Lobbying Disclosure Act of 1995, as anyone that attempts to influence legislation via continued contact with Congress and/or staffers is required to register as a lobbyist.  HSUS has never done this.

Dr Coates, It is disappointing to see you supporting this horrible idea. It's a step very much in the wrong direction, unless you are against pets being bred and raised in homes by the breeders who are most serious, experienced and dedicated to breeding and raising healthy, well socialized, quality dogs, cats and other animals, and preserving the genetic health of the breeds. (Do you think this is better for the well being of the animals?)

Please do not be misled by the revised FAQ that was apparently written to give false assurances to people who had expressed their opposition in the first part of the comment period. That FAQ makes claims that are not in the actual proposed rule or the AWA. It's outrageously dishonest.

I don't see that they have any evidence that there are more complaints about people buying via Internet than there are from people buying from pet stores. And in fact, APHIS finally replied after repeated questions from American Working Dog Federation, and admitted they do not even keep statistics on these complaints.

There's a good chance I may not have had my last 5 wonderful pets ( 3 from 3 different breeders, 2 from breed rescue) if I had had to physically visit the "retail pet stores" (breeders' & foster parent's homes). 4 of them were bought "sight unseen" and were shipped via air; I picked up the most recent at a cat show between my home and that of the breeder.

I had no problems or regrets in getting pets this way. The
rescues both had rocky pasts, and one in particular had difficulty trusting new people but the rescue had told me about his background before I adopted him and helping him learn to trust was an experience I greatly value.
Those from breeders were healthy, extremely well socialized and had clearly never known anything but love and good care. (Thank heavens they were raised in the breeders' homes, not in sterile kennel buildings under USDA rules for research labs and large scale commercial breeders.)

With some dog breeds, and with nearly all cat breeds (pedigreed cats are only 2 -3 % of owned cats, so the breeds are nearly all rare) it may be difficult or even impossible for buyers to visit the homes of breeders or rescuers (some of whom are also breeders) who have the breed (or type or lines within a breed) they want.
And this doesn't just affect people in remote, sparsely populated areas. Even though I live in a major city, I was unable to find a local breeder from whom I would wish to buy a cat of the breed and type I wanted.

I am a long time fancier of Siamese cats. I love them for their intelligence, energy and interactive, human-oriented personality. I feel it is important to preserve lines of the original type (that are now shown in TICA as "Thai") and I wanted this type of Siamese. There are actually quite a few cats being sold as purported "Traditional Siamese" etc. and if I weren't as selective about authenticity and responsibility and being in it for the right reasons, I could have bought locally. But I wanted to support a breeder I considered to be ethical/ responsible and preserving authentic Siamese of the older, moderately oriental type.
Some years previously I had found the website of a breed club whose knowledgeable articles, goals, code of ethics, international cooperation and emphasis on health I liked, and I decided that when I was ready to buy a pedigreed cat I should choose a breeder through this club. However, it turned out there were no breeders listed within a 10 hour drive from me. So I ended up having a cat shipped "sight unseen".

Buying pets remotely is NOT something new. It doesn't make sense to say that this rule change bring things in line with the original intent of the Animal Welfare Act because long before the AWA, pets were being sold without buyers coming to the breeder. One can see in old dog magazines advertisements from breeders who sold some of the puppies long distance. One could even buy puppies via mail order catalogs like Montgomery Ward. My aunt told how her Persian had come as a kitten in a basket on the train in the 1950s.

It's true the Internet has made it easier for people to find remote breeders and that includes not only the good ones but some bad ones. but actually the Internet and other modern technology has made it much easier for buyers to become informed about what to look for in a breeder and about individual breeders.

In the example I was telling about, I could see photos, pedigrees , contract, I spoke with 2 of the breeders' mentors; the breeder offered to give me a tour via Skype, I was able to look online to see if there were any complaints , to verify what the breeder had said about showing, etc etc.

I got a wonderful cat. Smart, active, funny, talkative, attention-loving -- a cat who had been raised in a home, around other animals from the time he was about 2 months. (the AWA says kittens under 4 months can't be around other kittens or other adult cats except their mother). And also a wonderful example of the breed: I showed him in the Alter Class to a Supreme Grand Champion Alter title and Regional Winner award.
My other experiences with buying remotely from a breeder or rescue have also been positive.

If the more serious breeders are prevented from ever selling to someone who does not come to their home, it creates a big problem for breeders who exchange breeding animals with breeders across the country and abroad to broaden their gene pool. This is not good for the health of the breeds -- and the health of the individual puppies and kittens starts with the health of the breed.

Like other readers, I will be interested to see if you will blog about it again after reading the informative comments that people have left. I'm surprised that you haven't commented yet.

apparently not.. looks like the blogger still thinks this travesty is a good idea... and prefers to blog about other subjects.. what a shame. Makes it look like she lives in the pocket of the animal rights groups .. HSUS/ASPCA/PETA that have written and promoted this debacle for the pet and people of our country