The  Staffordshire Bull Terrier Club of America ,a licensed member club with the America Kennel Club,  opposes H.R.835/S.707 the Puppy Uniform Protection and Safety Act (PUPS) for the following reasons:

Our breeder club members take their responsibilities as breeders seriously and provide the necessary care and socialization for the dogs that they breed to ensure that the public is obtaining a healthy well socialized puppy.

While this act may intend to regulate high volume or internet sales of dogs or 
puppies, the bill as currently written will affect breeders who may co-own a number of dogs that may produce fifty (50) or more puppies in a year under existing USDA dog dealer regulations.  Many breeders sell puppies on a co-ownership basis for many reasons which may include show purposes or to ensure that the puppy purchasers live up to their obligations in the care and socialization of the puppies.

The definition of a “high volume retail breeder” would include those breeders who routinely sell puppies on a co-ownership basis regardless of the fact that many of the dogs may be in other states and not on the breeders’ premises. The home hobby breeder would be hurt by the regulations designed for high-volume commercial kennels.  Our member breeders have few dogs in their homes and certainly do not have fifty or more dogs in their possession.

Home hobby breeders simply could not meet the engineering standards  designated for large commercial kennels because of zoning , land requirements or expense. The StaffordshireBull Terrier does best when in a home setting and Stafford breeders know this to be true. This bill as written will decrease the number of quality purpose bred puppies available to the American public.

Requiring hobby breeders to provide a certain amount of exercise and dictate this is beyond the ability of the home hobby breeder.  The home hobby breeder will engage their dogs in a variety of activities and training such as obedience and agility but these activities will not count toward the exercise requirement in this bill as  written . The home hobby breeder will allow puppies play on what looks like mini agility equipment and playing in a variety of settings designed to stimulate puppy minds and bodies.  The playtime of these happy puppies would not qualify as the exercise requirement under the bill as written. There is no scientific proof that the exercise requirements in this bill are necessary.

A four month old puppy is not capable of being bred and should not be counted as a breeding female.  The Staffordshire Bull Terrier Club of America recommends that a female not be bred unless she has obtained a conformation championship or some working titles. That means two to four years may pass before a dog may be bred

A Department of Agriculture May 2010 audit by the USDA  Inspector General indicated that the current exiting program funding is insufficient to carry out all the inspections required  under current law.  The audit further detailed problems with commercial breeders who were licensed under AWA or should have been licensed under AWA. It would seem that the USDA should use APHIS funding to investigate those known substandard breeders rather than include many thousands of additional breeders under this bill.

Respectfully Submitted

Judith A. Brecka

Legislative Liaison

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