Sunday, March 04, 2007

Money, Politics and Deception

A Tangled Fluffy Web
Money, Politics and Deception

Sorry for the delay boys and girls. Our spider has been busy and this is that time of year when webs are spun faster than cotton candy at the state fair -- Legislation Time. One web leads to another, we're told, but we needed Spidey back in Pennsylvania for some updates, so he rushed back in his Ferrari L430 Spider packed full of facts.

Have you been writing letters to the new Bureau of Dog Law Enforcement and letting your voices be heard about the overly restrictive proposed rules and regulations? The "Pennsylvania Puppy Mill Campaign" worked long and hard to bring this about. A hoard of animal rights organizations screeched loud and long and finally got the attention of the governor and other politicians, who were more than happy to accommodate the public misconceptions about dog breeding in Pennsylvania.

Their names are legion: United Against Puppy Mills, Save-A-Dog, Main Line Rescue, Keystone Golden Retriever Rescue, NJ Consumers Against Pet Shop Abuse (NJCAPSA) - Bob Baker and Libby Williams - Libby is related to one of the Main Line Rescue directors and she personally attended more than 35 zoning hearings in Lancaster County, Pennsylvania, to hear testimony and offer comments regarding applications of new puppy mills. Several applications were denied. We would hope so. Whoever heard of applying for a PUPPY MILL LICENSE ? - Save Ardmore Coalition, Prisoners of Greed, Stop Puppy Mills, Last Resort Animal Rescue, to name a few. They never let common sense or truth get in the way of stirring up public opinion against animal owners and breeders.

We know that our readers support animal welfare 100%. Proper animal husbandry and care for our animals is a given. We protest the hot-button phrase "puppy mill" because it was created by an anti-animal ownership faction. These groups ultimately do not support animal ownership, period, unless, of course, you abide by their rules, have the monetary status to own and keep an animal the way that THEY prescribe. There was a more productive way to deal with sub-standard kennel operations, but where is the publicity and money in that?


Herein lies the problem. No matter how they try, the state cannot legislate human behavior. A few sour apples will taint the lives of decent, tax-paying, law abiding citizens. In an ideal world, the laws would be applied fairly and everyone would own a DisneyWorld kennel. However, in this world, good people are victims of legislators and law enforcement officials gone wild. Even the best managed kennels are not 100% pristine 24/7. There are more shelters closed because of 'disease outbreaks' than there are commercial and private kennels closed for that reason. Here are just a couple recent articles for you to review regarding shelter disease outbreaks and OVERCROWDING. Click here and here to read these very recent articles.

Because the proposed rules and regulations are too broad and have the potential to be unfairly enforced for the slightest infraction, will Pa. create more of a problem than what exists? We believe that to be the case and so do responsible breeders. Read the proposed regulations again-but take your meds first! We cannot trust the State to guard our Constitutional rights or our private property.

The New Dog Law Advisory Board - Not in the Best Interests of Dog Owners ...... OR ... How Can You Regulate What You Cannot Define ?????

Somewhere along the way, Jesse Smith commented that the Department was not looking for the small hobby breeder, but those that were breeding large numbers of dogs. What is a "large breeding" operation? According to the proposed regulations, failure to obtain a kennel license prior to operating any establishment that keeps, harbors, boards, shelters, sells, gives away or in any way transfers a cumulative total of 26 or more dogs of any age during 1 calendar year may result in violations. Is a large breeding operation one that has more than 26 dogs per year? Surely that cannot be correct. The regulations do not define small hobby breeders in any other manner that our researchers can find. There are also no definitions of "puppy mill" that we could find except on those web sites that claim they know what a "puppy mill" is.
One explanation, found on the Prisoners of Greed website is this:

'There is no definition of a puppymill. In our opinion anyone who breeds dog with profit as the main motivation and without consideration for the health and well being of the dogs and puppies is guilty of ethical crimes.
There are two kinds of these people - backyard breeders and puppy millers. They should both be driven out of business.
Anyone who has so little concern for the well being of the puppies that they have caused to be brought into the world that they sell them to someone else who will resell them qualifies as a mill in our opinion.'

By their own admission, THEY don't have a definition of a "puppy mill" - only an opinion and we all know about opinions. (As a matter of fact, we received a picture of an "opinion", via an anonymous sender, that originated from Main Line Rescue, apparently to one of our readers, who wanted us to see what type of mentality they were dealing with. We chose not to publish such a blatant display of ignorance.)

One thing is for sure, using their "opinion" of a "puppy mill" - those small breeders that breed for quality and those that show their dogs - cannot be considered a "puppy mill" and therefore, should not be subject to these regulations. But, the definitions and the regulations are still much too vague. A puppy mill could be anything the Advisory Board claims them to be, based solely on an OPINION. Same with a hobby breeder, a backyard breeder, or a commercial breeder. People must know what the proposed rule is stating in regards to specific definitions, otherwise it is ambiguous, arbitrary and capricious.

ARBITRARY AND CAPRICIOUS - Absence of a rational connection between the facts found and the choice made. A clear error of judgment; an action not based upon consideration of relevant factors and so is arbitrary, capricious, an abuse of discretion or otherwise not in accordance with law or if it was taken without observance of procedure required by law. 5 USC. 706(2)(A) (1988). When a judge makes a decision without reasonable grounds or adequate consideration of the circumstances, it is said to be arbitrary and capricious and can be invalidated by an appellate court on that ground. There is, however, no set standard for what constitutes an arbitrary and capricious decision; what appears arbitrary to one judge may seem perfectly reasonable to another.

The Cauldron

The way the new rules are written puts everybody into the proverbial cauldron in this witch hunt...and you know it. Telling people not to worry certainly did not go very far in the dog world. We all know that there are some that don't apply good husbandry policies, but just which of the above named categories is the faltering faction in the Pennsylvania dog world? How many constitutional rights are needed for the witch's brew ?

Additional Restrictions & Money BUT Not For Everybody !!!

Adding restrictions regarding the separation of puppies, larger crate/pen sizes, slope degree are all unnecessary to responsible dog owners. In more than several of the above mentioned websites, it is proclaimed that "these poor puppy mill dogs have never felt the grass under their feet." Bad news for all of those organizations. If these new regulations pass, they STILL won't feel the grass under their feet, will they? But hold on !!! None of these regulations pertain to the organizations that will house confiscated animals. Discriminatory? Yes, absolutely!
There is no reason that facilities that house animals for adoption and euthanasia, or that act as a holding facility for confiscated animals should not abide by the same rules. Why would you take a dog from a home where it had free run of the yard or house and put it in a concrete block space not large enough for it? Humane treatment? Where's the green grass? What about “lateral recumbence?” The new dog laws proposed by state officials to crack down on the “puppy mill” problem have a provision governing the size of “primary enclosures” for kennels. They are, according to the proposed rule, to be big enough so that a dog may lie in a “lateral recumbence” — on its side or back with legs fully extended — without any part of its body, tail, feet or head touching any side of the enclosure. Dogs that are placed into shelters don't get out and are subjected to being in "an enclosure" that does not provide "lateral recumbence." You ask the breeders in Pennsylvania to adhere to rules that you don't follow yourself. If the state wishes to teach "husbandry" to its breeders, then the state should set the example and the example is NOT in a shelter environment.

Overcrowding Shelters ??? or is it really ..... Hoarding for Profit !!!

Let's talk overcrowding or perhaps a better terminology would be "hoarding for profit." Shelters complain about overcrowding all the time. Could it be because they are not required to adhere to proper space allotments for particular animals? Do such cramped quarters constitute "humane welfare"? Will you start to pay people to foster like the state does with children? (Oops, pardon us - there are more stringent laws for DOGS than there are for the safety and welfare of children in Pa. !!) How long will you keep these dogs cramped in a rescue/shelter situation never being allowed to feel the "grass under their feet?" What about those dogs that are never adopted - they live their entire life in a SHELTER? .... for LIFE? You call that humane? We don't. If the intent is to be "fair", as stated, shelters should be included in the regulations as well. If you really think about it, "Shelter Hoarding for Profit" is not much different from what the regulations claim they are intended to stop.

Hopping Along the Money Trail

Who's who in this sad tale of wagging the dog? *Governor Rendell has powerful friends and supporters who helped finance his election campaign. Marsha Perelman (and other members of the Perelman clan) are at the top of the list. She sits on many of the same boards with him, socializes with him AND she is also a member of the new Dog Advisory Board. Perelman is also a valuable resource as a director of Main Line Rescue. Money talks and Rendell listens.

Click here to see the slideshow of who's who in the PA elite crowd. Perelmans, Hamiltons and Rendell and then let's talk about the 'handpicked Rendell committee' or better yet, click here for a cozy picture that speaks for itself.
Those of you that want to be a little adventurous, just Google Perelman and Rendell or "Marsha Perelman" for more information.

Perelman is also on the board of the ASPCA. (Bob Baker in an investigator for the ASPCA) Main Line Rescue admits that it has worked with the New York City ASPCA for years. In fact, they wrote that over half of MLR's dogs and cats come from other rescue orgs and SPCAs. The Spring 2004 issue of their newsletter stated that they received dogs from shelters in Delaware County, Baltimore, Maryland, NYC and St. Croix in the Virgin Islands.

Another new DLAB member is Mary Remer, a MLR dog trainer, owner of What a Good Dog in Villanova, and First Vice President of the Bull Terrier Club of America.
She and friend Carolyn Garson, plan to build a $6 million, state of the art pet care facility that will soon be opened in Chester County. There is no money in professional and responsible breeding, however, there is money in sheltering. *Note: Though Remer married into the DuPont dynasty we have been told that she also had money - perhaps more than her husband. A few people have informed A & N that Mary Remer is an advocate for professional and responsible dog breeders.

We mustn't leave out Joe Trippi. He is the media guru for the Best Friends Animal Society. He orchestrated the questionable BSL conference to the tune of German marching music. That is to say that Best Friends wants to use Germany's dog laws as a model for our "dangerous dog" laws right here in the land of the free. Trippi also has friends in PA's high places and he could easily become Mayor of Philly and Rendell's right hand man! WHAT NEXT??? If you don't believe us, maybe you'd like to take a look at what you missed ! Joe Trippi's - Democracy, the Internet and the Overthrow of Everything !!

You might want to also check out this article about Rendell's magic at raking in contributions! Just click here !

This is just one example of PA politicking. Wayne Huizenga of Florida donated $50,000 to Rendell in 2006. He owns Waste Management (WMI). Penn State is one of the most corporate-controlled universities in the U.S. - where tons of corporate and military research is done with no citizen right-to-know. For years, Penn State has promoted things that support Waste Management's operations in Pennsylvania, including the land-application of toxic sewage sludge and the site of a nuclear waste dump! But, those things aren't near as health threatening as "dog feces and worms," are they?

Wayne Huizenga is the only person in history to build three Fortune 1000 companies practically from scratch: Waste Management, Blockbuster Entertainment and AutoNation. He also owns the Miami Dolphins and is previous owner of the Florida Marlins baseball team and the Panthers hockey team. Blockbuster sold to Viacom for $8.4 billion in stock. He also re-entered the waste management field with the creation of Republic Services, which grew to be the third-largest waste management company in the U.S. before merging with Huizenga's first company, WMI. But Huizenga is not without his detractors. A 1994 article in the Miami New Times dug up a pile of dirt (both actual and alleged), including an early assault case in which he had roughed up a sales prospect who refused to do business with him (Huizenga lost the civil suit climbing his way to success at the expense of others; ties with organized crime; physical and emotional abuse of his wife; unfair competition practices; illegal political contributions; and disregard of environmental laws.

FYI - Several years ago, the Florida AR crowd began a campaign about hog crates. They created a PAC, chaired by Wayne Huizenga’s daughter, Pamela. Most of the PAC money came in six-figure chunks from the Farm Sanctuary, an animal shelter and former Animal Liberation Front “spokesgroup” based in New York and California. The web covers every coast and every border.
Smoke, Mirrors and Fire OR Is It Smoke, Mirrors and Photos ?

Back to the beginning. Save-A-Dog published "the Shame of Pennsylvania" website that featured a 6 year old Maltese, named Hope, that allegedly came from a puppymill. The dog appeared to be in terrible condition and was sure to stir the public's emotions and loosen their pocketbooks. In fact, Hope was a driving force behind the "puppy mill" campaign that eventually resulted in the new dog advisory board and the horrendous regulations that have been proposed.

This web page is published via, a group that MLR also networks with. ( is registered under Discovery Communications, Inc. which also is responsible for Animal Planet Media which is also a H$U$ partner). Main Line Rescue recently revamped its website and added pictures of another similar looking "Maltese" they named Shrimp.

The kennel in the photo posted to the Save-A-Dog site claimed that it was licensed in PA and that it had been inspected twice with no action by inspectors. They credited the reprint with permission of this information to Hearts United for Animals in Nebraska that has no contact name on the website.

An article from the Sept/Oct 2005 issue of the Best Friends magazine featured an article about Pennsylvania Amish puppy mills written by Julie Richard. Page 45 tells the story about a sick Maltese that was supposedly registered with the ACA - American Canine Association.

MLR recently emailed pictures and a story about Shrimp. They stated that he came from a PA kennel which was licensed and inspected 3 times without violations. MLR claimed the dog had been registered with the AKC and they sent this information to Governor Rendell and the new Dog Advisory Board in support of the strict proposals that may soon be law.

Though MLR is well connected, they leave a bit to be desired in the human relations department - and in credibility. These "maltese" stories share many similarities. Could this same story be recycled over and over? The claims are so similar - a very malnourished dog, from a licensed PA kennel that was inspected two or three times with no violations. Could such pictures be altered via a software program to create hideous and heartbreaking photos that would guarantee outrage, sympathy and donations? It has been known to happen.

The Great Wide Web

New Jersey has some of the, if not the most restrictive, animal legislation in the country with New York following close behind. We suppose they feel it their duty to see Pennsylvania become just as bad. Walter Hargis pushed the PA Puppy Mill Awareness day in the Long Island newspapers. Turns out that his wife, Kathy, is an active rescuer of animals that specializes in "unsocialized puppymill" dogs. She is also credited with being a founding member of Puppymill Awareness Day and is a certified Animal Control Officer.

By the way, that website also features the pathetic MLR Shrimp dog and a link to Last Chance for Animals, headquartered in Los Angeles. (President Chris DeRose )

NJCAPSA eagerly joined the PA puppymill bashing party and reputable dog breeders took some hard punches and low blows. Libby Williams is the founder of this organization. She learned her craft as a volunteer for the Fund for Animals which led to her stint as a cruelty investigator for the Humane Society of Huron Valley in Ann Arbor, Michigan.

Also speaking at this puppy mill rally was ASPCA Humane Law Enforcement Officer Annemarie Lucas, investigator for the NY SPCA, who is well known from the popular Animal Planet series, Animal Precinct. Bob Baker (former HSUS animal investigator now with the ASPCA) is also on the advisory board of NJCAPSA. (There is more about him on previous postings on this blog & easy for you to access.) During Animal Planet segments, ASPCA Humane Law Enforcement (HLE) officers can be classified as Special Agent or Special Investigator. Some HLE officers are spoken of only by initial (ex. Agent X, Y or Z) with their faces blurred when on-camera as a way to protect their identities so that they can do undercover work for the ASPCA.
Imagine that. Undercover agents for animals. Maybe in their free time, they should go and do some undercover work for abused children.

You know, the ones that never feel the grass under their feet, are black & blue, broken bones, no medical treatment, no clean clothes or bedding, no food or water, locked up and not permitted lateral recumbance. But, there's not much reward in that.
AND THE REWARD IS..............

Boys and girls, ladies and gents, we now show you the reward... !!!

A & N Research - bringing you the facts !!

Amazing how one picture is worth a million words !

Stay tuned for MUCH more !!

Thursday, January 18, 2007

Commentary on PA Proposed Dog Law Enforcement

A Commentary on Pennsylvania's Proposed Dog Law Enforcement
Proposed Rules and Regulations

Department of Agriculture
7 PA. Code Chapters 21, 23, 25 and 27
36 Pa.B. 7596
To Implement and Amend

For many years now, the animal rights and animal welfare groups have been telling the entire nation that Pennsylvania is the "Puppy Mill" capital of the east. I have always been suspicious of this emotionally charged, hot button term. The phrase was introduced in the 1980s and the HSUS has used it at every opportunity since. Perhaps the phrase was first used to describe genuine, sub standard kennels - but it has since morphed into a catch all term that has been used to demonize even the most reputable of breeders.

There is no doubt that large, sub-standard kennels exist in Pennsylvania. Laws were in place that should have regulated such kennels, but they were not strictly enforced. Because the animal rights activists tend to cry "puppy mill" even when there are none, we must question their motives and credibility. We cannot allow these ridiculously stringent regulations to pass into law.

Laws are made to cull out the bad apples. Unfortunately, the bad apples usually do not adhere to the law. Many have already shut down their operations entirely or moved them to another state. These proposed regulations will become a burden on those who have always maintained professional kennels. The honest person is being punished for the misdeeds of those that the regulations were written for.

What is so onerous about these regulations is that they are nearly impossible to follow unless you are fortunate enough to have a full time staff. They are time consuming and will incur great expense to kennel owners. The potential for the regulations to be subjectively enforced is of extreme concern and must be taken into consideration.

Ironically, reputable breeders joined the animal welfarists in the crusade to clean up or shut down unprofessional breeders. Unfortunately the line between hard core animal rights and genuine animal welfare is very blurred, and often the former merely poses as the latter. I warned readers many years ago that animal rights people do not compromise - they see things in black and white (i.e. all breeders are bad). They can't be trusted and the newly appointed dog law advisory board and their proposed regulations are proof positive.

The PA Department of Agriculture admits they have relied on and borrowed from provisions set forth in the Animal Welfare Act (AWA) and in the Military Dog Training Manual. Both of these documents were created by and operated by the federal government which has ample funds to adhere to them. The U.S. military certainly has the budget to maintain a state-of-the art kennel. It is not reasonable to place those same standards upon a private citizen.

Taxpayer money will be used to purchase equipment necessary for measuring lighting and ventilation. It is estimated that $15,000 per warden will be allotted the first year and $5,000 for the next four years, or $35,000 per each warden. The information I have has 79 dog wardens listed - there could be more. 79 x $35,000 = $2,765,000, nearly $3 million dollars.

The proposed amendments to the regulations will impose additional costs on those regulated. Licensed kennels will need to comply with very restrictive specifications regarding lighting, ventilation, space requirements, sanitation, housing requirements and record keeping. "Temporary homes" will also have to comply with these regulations. The new dog advisory board estimates the costs for each person and kennel to come into compliance with these proposed regulations will range from $5,000 to $20,000. That is excessive and unacceptable.

Dog owners of every type need to make their voices heard NOW. We cannot afford to hide our heads in the sand any longer. If we do, we will deserve the regulations that will be imposed on us. Please be sure to send copies of your letters and comments to your State representatives (both houses), a copy to your federal representatives (both houses) and to Governor Rendell. They need to know what the Pennsylvania dog-owning taxpayers have to say about these proposed regulations.

Comment letters should be sent on or before February 10, 2007 to assure receipt by the comment deadline. Please also send copies of your letter to your State Senator and State Assemblyman and to the Pennsylvania Federation of Dog Clubs. Names and addresses are available on the website at Pennsylvania Federation of Dog Clubs

Bureau of Dog Law Enforcement
Attn: Ms. Mary Bender
Pennsylvania Department of Agriculture
2301 North Cameron Street
Harrisburg, PA 17110-9408
717-772-4352 (FAX)

Governor Edward G. Rendell's Office

225 Main Capitol Building; Harrisburg, Pennsylvania 17120
To telephone the Governor call:(717) 787-2500

If you have not read these regulations yet, you need to do so. The link to them is at the top of this article. The first time I read them, my head was spinning. These should be guidelines for an ideal kennel; not law.

The 26 Dog Rule
Any *establishment that keeps, harbors, boards, shelters, sells, gives away or in any way transfers a cumulative total of 26 or more dogs of any age during 1 calendar year must obtain a license. Those which do not fall under this definition shall obtain individual, rather than kennel, licenses.

K-1 kennels are currently described by PA law as those with 26-50 dogs. These are small operations that will most likely choose not to renew their kennel license if they are subjected to the restrictive and expensive regulations that are being proposed. Large corporations, such as the Hunte Corporation, can afford to buy puppies from smaller breeders while maintaining facilities that meet all the proposed requirements. These regulations encourage such factory farms, that will in turn, sell puppies to pet shops across the east coast!

The below example illustrates how detailed the proposed regulations are.

*(An establishment includes the home, homestead, place of business or operation of any individual or person, including a dealer, which includes all of the land, property, housing facilities or any combination thereof, on, in or through which any dog is kept, bred, harbored, boarded, sheltered, maintained, sold, given away, exchanged or in any way transferred. Establishment shall encompass all of the individuals or persons residing thereon. It may be public or private and includes an individual, person, organization, business or operation, which utilizes offsite or temporary homes to keep, maintain, breed, train, harbor, board, shelter, sell, give away, adopt, exchange, or in any way transfer dogs. A housing facility includes any land, premises, shed, barn, building, house, trailer or other structure or area housing or intended to house dogs for any period of time.)

Obviously the new, improved PA Dog Enforcement team wants to be able to legally access an establishment owner's entire premise and be able to inspect everything which they own. Buying a kennel or dog license conveys an obligation attached to ownership rights which puts one under obligation to abide by the governing laws, rules and regulations. The potential to violate Constitutional rights is just too much to risk in my opinion.

Of course, each time the Department decides a regulation has been broken they can file an injunction against the kennel and may also impose a fine of not less than $100 nor more than $500 for every day the kennel operates in violation of the act or regulations. (For instance, operating a kennel without a license, operating with a revoked license, suspension of a license, selling dogs without an out-of-state dealer license )

Seizure of dogs. The Department may seize, impound and direct forfeiture proceedings of dog(s) for the following reasons: Revocation, suspension or denial of a kennel license or an out-of-State dealer license. The owner shall pay for transportation costs, care and feeding of the dog(s) even though they are not in his possession.

These new regulations provide similar penalties that are used in alleged animal cruelty cases where animals have been seized. A person is judged guilty until proven broke. Remember, violation of any of these rules and regulations could theoretically result in punitive actions against a dog owner or kennel. There are procedures to appeal an ACO or dog warden's decision, but they are time consuming and expensive. Few people are able to retrieve their property (their dogs) once they have been forfeited. The holding fees are quite steep and unreasonable. Some of the animals die while in the care of a third party; some become diseased and others are sold or adopted out.

This is Administrative Law. The Dog Advisory Board not only writes and incorporates new rules and regulations into the statutes, it is also responsible for administering and enforcing them as well as judging whether they have been broken! It is difficult to fight such a system.

Extensive records on each dog kept at a licensed kennel must be maintained for at least 2 years. The records must be legible and be open to inspection and may be copied by any employee of the Department (with or without notice). All records must include the minimum information: the breed, color, markings, sex and age of each dog; the date on which each dog entered the kennel, and where the dog came from. Other information may be required depending on the type of kennel license one owns. The PA kennel license number or out-of-state dealer license is necessary for dogs that enter a kennel along with the name and address of the individual breeder or former keeper. Similar records are kept for dogs leaving the kennel including detailed vet records about the dog. (spayed, neutered, vaccinations etc etc)

Similarly, the housing requirements are quite detailed. Temperature control, safe housing, space requirements, protection from the elements, strict sanitation protocols, and even lighting specifications are set out in great detail for both indoor and outdoor facilities.

The following are just a few of the details covered. Outdoor dog shelters must be raised off the ground and built to be draft free, and yet must be well ventilated. They must have clean and dry bedding at all times. There must be a wind and rain break at the entrance and a mud free area with no standing or pooled water nearby. It must be easy to clean and sanitize. Dogs may not be housed in drums or barrel houses.

Shade must be provided by a permanent fixture; not a tarp. The shade area must allow for air movement in excessive heat and protect the dogs from the direct rays of the sun. The shade areas must adhere to strict space requirements.

Both indoor and outdoor facilities must be equipped with waste disposal and drainage systems built on a slope and in the best possible manner to wash away animal waste and allow for quick runoff. (At least 1/8" per foot) Outdoor kennel runs must be sloped to a gutter outside of the end fence of each run. Drains and gutters shall be sanitized daily then flushed with water.

The exercise run associated with each dog box must be at least five times the length of the largest dog in that run and two times as wide as the length of the largest dog in that run. Outdoor runs and exercise areas may be constructed of concrete, gravel or stone. Again, the regulations set for very definite specifications. Outdoor facilities, including runs and exercise areas shall be kept free of grass and weeds. Grass and weeds shall be cut back from the sides of runs and exercise areas to a distance of 5 feet to help prevent tick, flea and other parasite infestation.

Each dog shall receive 20 minutes of exercise per day. Dogs shall be walked on a leash by a handler or put in an exercise area. The exercise area must be fenced, shall be kept in good repair, and equipped to protect dogs from becoming wet, matted or muddy during their exercise. Outdoor facilities must be fenced and be constructed to minimize or prevent vermin, animal, insect and pest infestation and other vectors of disease.

Records shall be kept regarding dates and times:
When the housing facility was cleaned.
When the housing facility was sanitized.
When each individual cage, dog box or primary enclosure was cleaned.
When each food and water bowl was sanitized.
When new food and potable water was provided each dog.

Every keeper of a kennel shall keep a record of the following for each dog housed in the facility:
The date, time and detail of daily feedings, cleaning of kennel, and changing and refreshing potable water.
The date, time and detail of exercise activity of the dog.
The date, time and detail of any medication administered to a dog.
Any accident or incident in which the dog is injured.
The date and time of any veterinary care administered.
Records of veterinary care for each dog.
Any veterinary ordered or voluntary protocol for vaccination, medication or other recommendation for medical treatment of the dogs.

Tethering rules are set forth for dogs that are outside. Accessible hot and cold water, sinks, showers, towels and soap are mandated for animal caretakers. Dogs housed in indoor and sheltered kennel facilities shall be provided a regular diurnal lighting cycle. Primary enclosures must be placed to protect the dogs from excessive light. A minimum of 10-foot candles for kennel building and primary enclosures; 20-foot candles for bathing, grooming and toilet areas and 70-foot candles for food preparation and storage areas are required. Electrical systems in wash down areas must have ground fault circuit interrupters and all others must be the all-weather type with a spring cover.

Dogs not acclimated to current weather conditions shall be kept indoors Puppies not born in the receiving kennel facility shall be quarantined for a minimum of 14 days. Adult dogs entering the kennel from another place shall be quarantined. Dogs must be separated according to sex, size and temperament during prescribed daily exercise times.

Detailed provisions regarding dangerous dogs are described. Dangerous dogs must be registered, restrained and under strict supervision. Liability insurance is required. Violations may result in misdemeanors, confiscation of the dog and its euthanization.

We have very briefly touched on the main subjects covered in these extremely oppressive regulations. The regulators need our input. These proposed rules must be modified. Left as they are, there is too much room for them to be unfairly enforced and administered. There is too much room for them to be enforced subjectively without common sense. We, who read the news, see this happen each and every. Such ideal guidelines cannot be legally enforced without causing harm to innocent, law abiding citizens.