Madame Chairman:
Obviously, I and probably other members of this Advisory Board are not in a position to express opinions about the proposed regulations having only received them last week. However, I would like to briefly describe the principals that will guide me, and that I believe should guide all of us, in evaluating these proposals.
I am a member of the Harrisburg Kennel Club and serve as their volunteer Delegate to the American Kennel Club. The American Kennel Club is a not for profit dog registry. Therefore, my perspective on governmental regulation of persons dealing commercially in dogs is heavily influenced by my association with the American Kennel Club. More than a decade ago, the American Kennel Club established minimum care and condition standards for what we call "high volume" breeders and dog dealers. Cooperation with these mandatory kennel inspections and compliance with the care and condition standards is required of all high volume breeders and dealers who register dogs with the American Kennel Club. For Pennsylvania in 2005, the American Kennel Club inspected 141 kennels and 10 pet shops. In addition, there were 280 households that registered seven or more litters with the American Kennel Club, and thus were also inspected. I am sorry to report that over the nearly 15 years that the American Kennel Club has had a care and condition standard, more than 2000 high volume breeders nationwide have left the American Kennel Club non-profit registry rather than submit to its requirement. Many of those persons are now registering dogs with self started for-profit dog registries that did not exist prior to the American Kennel Club's instituting its kennel inspection program, DNA and care and condition standards.
I support the work of this Board, the Bureau of Dog Law Enforcement, and the objectives of Pennsylvania's dog laws, and I believe that periodic review of these laws and regulations and their effectiveness are appropriate. I support the existence of reasonable dog laws to assure responsible dog ownership and to assure that those engaged in commercial activities involving dogs comply with reasonable standards assuring the humane treatment of dogs. Many of us believe that there are still instances in Pennsylvania where persons who deal commercially in dogs do not engage in acceptable standards for the humane care and treatment of the animals in their care. However, it could be that many of the worse offenders are probably also unlicensed. With that in mind, I will examine the proposed regulations carefully and with intense interest.
The process of determining whether and how to appropriately address the problem of inhumane treatment of dogs must begin with an examination of the problem. Specifically, we need first to determine the extent to which continuing instances of inhumane treatment of dogs in the Commonwealth by persons who deal commercially in dogs are occurring, and, if so, the extent to which this is a result of inadequacies in the existing dog law, inadequacies in the regulations declared under the law, or inadequacies in the enforcement of the existing law and regulations. My first criteria in evaluating the proposed regulatory amendments, and any changes that may be proposed, will be to determine to what extent the need for them is backed up by solid analysis that demonstrates that the problems with inhumane treatment of dogs is resulting from inadequacies in existing laws or regulations, and whether the current proposals address these specific inadequacies.
In this regard, I have to say that my current impression is that most of the problems I have heard and seen cited by the media would seem to arise from inadequacies in the enforcement of the current existing regulations, not from inadequacies in the regulations themselves. Inadequate enforcement of the current regulations will not be solved by additional regulations. This will only create additional hardships for those that are already complying with the law. In fact, if we are not careful, we could worsen the problems of enforcement by writing yet more unenforceable regulations. Therefore, I want to ensure that "those" who have drafted these regulations have established a direct connection between a specific problem and its specific, appropriate solution.
Secondly, I believe laws and regulations need to be based on facts and science, not on emotion. This is not easy in the area of regulating a persons' activities with respect to dogs, because for many of us, our dogs are an extremely important part of our lives, and we are very emotionally attached to them. But in writing laws and regulations pertaining to the humane treatment of dogs for persons engaged in commercial activities with dogs, we need to be guided by facts and science and not our emotion.
Thank you for the opportunity to make this statement. I look forward to evaluating the proposed regulations, and to make suggestions for their improvement, as well as identifying other areas in which regulatory changes may be appropriate, so that this committee can make reasonable recommendations prior to the presentation of this proposal to the public.
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