Anfc' mg [
[email protected]] Tuesday, October 20, 2009 9:14 AM Cc:
Subject:
A OH OAAO Polly Britton; Adam Harris PA Leg; Andrew Dinniman PA Leg; Carl Metzgar PA Leg; Chris Ross PA Leg; "Daily Times Delaware County"
J3
B Good Afternoon, 'Attached' and 'as follows' is an amendment to my previously submitted public comments. Respectfully, Michael Glass, America's Pet Registry, Inc.
Amendment to Public Comments: Proposed Regulations and Standards for Commercial Kennels Regulation ID # 2-170 #(2785) ******************************************************* To:
Canine Health Board c/o Department of Dog Law
:S
ill
2301 North Cameron Street Harrisburg, PA 17110 ****************************************************
Submitted By: Michael Glass
America's Pet Registry, Inc. 118 Mulberry Court # Collegeville # Pennsylvania 19426 484-880-7962 mg@aprpets.org October 20, 2009 ****************************$**********$*****$******* In light of the recent testimony offered at the Canine Health Board hearing October 16,2009,1 offer the following amendment to my public comments. First and foremost, I would like to clarify that opposition to the proposed regulations as written does not in any way suggest that we are not amicable to accepting and embracing proposed regulations that will benefit the health and well being of dogs; as ACT 119 dictates within certain limitations. We oppose accusations from supporters of the proposed regulations as written that the regulated community objects to appropriate standards. We suggest that the supporters of the current proposed regulations are making comments out of context in the interest to discredit the viewpoints of the regulated community. Our primary concerns have been compounded with the new information that the CHB maintains that their comments are in fact within the limitations of the law and their charge. The excessive passion of a select few members of the CHB does not reflect their charge. Just as is the same limitations of any law officer with duties...although heroic..the CHB must stay within the boundaries of the law. ****************
"These are the most complete set of regulations for pet dogs ever written," one CHB board member states. The charge was not to offer a 'complete set'.
The CHB was not developed as a regulations board with an open ended agenda for defining and developing the needs for the health and well being of a dog. This is a board of Veterinarians dictated by law to complete a simple task.
The Canine Health Board shall determine auxiliary ventilation to be provided if the ambient air temperature is 85 degrees F or higher. The relative humidity must be maintained at a level that ensures the health and well-being of the dogs housed therein. The appropriate ventilation, humidity and ammonia ranges shall be determined by the Canine Health Board. (8) Housing facilities for dogs must be lighted well enough to permit routine inspection and cleaning of the facility and observation of the dogs. Animal areas must be provided a regular diurnal lighting cycle of either natural or artificial light. Lighting must be uniformly diffused throughout housing facilities and provide sufficient illumination to aid in maintaining good housekeeping practices, adequate cleaning and observation of animals at any time and for the wellbeing of the animals. Primary enclosures must be placed so as to protect the dogs from excessive light. The appropriate lighting ranges shall be determined by the Canine Health Board. (5) The Canine Health Board established in section 221 may, upon a request from a kennel owner, provide on a case-bycase basis for an alternative means of allowing clearance from a primary enclosure to the exercise area or exercise that is required 1391 in paragraphs (4) and (6)(i) if the kennel owner presents the board with a plan that the board determines is verifiable, enforceable and provides for exercise equal to or greater than that which the dogs would receive under paragraphs (4) and (6)(i). The board shall meet within 60 days of a request submitted or sooner if necessary, (iii) Additional flooring options that meet the provisions of subparagraph (i) may be approved by the Canine Health
As the public demands the commercial dog breeders abide by the law ... we request the CHB do the same. We will support regulations that are 1. Written within the specific guidelines of the law. 2. Based on the needs of ALL dogs. 3. Allow for the variable needs of ALL dogs. 4. Allow for the variable weather conditions that may exist. 5. Not based on conjecture. 6. Based on collected date...not arbitrarily enacted to collect data. 7. Realistic in needs considering expense. 8. Do not show a hidden agenda of prejudice. 9. Do not overwrite current legislation. 10. Include input, experience and data derived from within the regulated community. ****************
In addition, I would like to address the issue of the PVMA with regards to the dissension of current PVMA members that reside on the Canine Health Board and their disapproval of the proposed regulations. Please reconsider that these comments are supported by the attendance of the author and associates having observed all of the Canine Health Board meetings in person.
My original comments did not include direct comments transcribed from notes taken at the meeting. Initially, I dismissed these notes as accepted in the capacity for brainstorming.
"If you want people to succeed you have to give them a way of doing it,./
"...just make guidelines...not how to do it..."
"...might it be better to talk with agriculture companies..."
"...we need to talk to groups that are more familiar with what we are dealing with..."
"...we need to regulate for minimum standards..."
"...there is not a...(expletive)... thing we can do about (the slated flooring)..."
"...way way way to detailed of a level... (than what our charge is)..."
"... (there is) 50 years of positive history here...we need to establish parameters ... and who cares HOW they meet it..."
"...you are going down the wrong path...a pig in not a dog...etc..."
"...there is no real standard...9
"...this answer is a 100% guess..."
"We do not need experience we need data". (Regarding the request for commercial
dog breeders to offer information.)
We observe that there is a curiosity as to how proposed regulations were voted on by the CHB to 'agree'. When now members of the CHB have expressed a difference of opinion. We ask the CHB and the IRRC consider the position of the PVMA and their reasoning for this. Again, I would like to clarify that opposition to the proposed regulations as written does not in any way suggest that we are not amicable to accepting and embracing proposed regulations that will benefit the health and well being of dogs; as ACT 119 dictates within certain limitations. Respectfully Submitted, Michael Glass, America's Pet Registry, Inc cc: IRRC, Pa Dept of Ag Bureau of Dog Law, Interested Parties
