Last week, the Iowa Department of Agriculture and Land Stewardship (IDALS) posted new proposed regulations regarding animal welfare and is seeking public comment until October 30.
IDALS is seeking public input and has indicated to the American Kennel Club that they want to hear from Iowa breeders and hobbyists. AKC greatly appreciates that IDALS continues to communicate with the AKC throughout this process and seek out input.
AKC Government Relations (AKC GR) encourages all concerned Iowa residents who may be impacted by this proposal to review the entire proposal, and provide comment to the Department on how the proposal may in appropriately impact them. Please scroll down to learn more.
ABOUT THE PROPOSAL:
This comprehensive proposal will replace the current regulations on animal welfare and in part address kennels, rescues, and shelters, as well as care for animals in facilities licensed in Iowa and regulated in Iowa Code. The regulations will impact many hobbyists, as current Iowa law defines a commercial breeder as anyone who has more than three breeding dogs (male or female) and sells or exchanges even one dog in exchange for any consideration (Please note: This definition cannot be changed in these regulations, as it is part of Iowa Code).
MAJOR PROPOSED CHANGES INCLUDE:
- Defines “In-home facility” as an individual required to be licensed as a boarding kennel, commercial breeder, commercial kennel, or dealer who maintains or harbors animals within the individual’s residence. Like current regulations, such individuals are limited to having six adult animals in an individual’s residence. Many fancier and enthusiast breeders who qualify under the statutory definition of commercial breeder maintain in-home facilities and will be subject to this limitation. However, the proposal fails to explicitly define what an adult animal is. The AKC believes this will disparately impact many breeders who “grow out” promising dogs to at least 24 months of age before determining whether they will have a show career or be worthy of breeding.
In our view, maintaining an intact adult dog that physically could be bred does not demonstrate the intention to breed. Additionally, dog show hobbyists may keep a number of intact dogs because this is a requisite to show in AKC breed conformation dog shows or compete in certain performance events. These events are intended to identify the best breeding stock to ensure that future animals are healthy and capable of performing the tasks for which the breed was intended. Often, breeders must wait until an intact dog is a minimum of 1-2 years old before determining whether it would qualify to be breeding stock. In many cases, key health tests for breeding stock cannot be accurately conducted until the animal is two years old. Moreover, recent scientific studies demonstrate that intact females have better health; likewise, premature sterilization may cause a variety of health, longevity and/or house-training issues.
The AKC believes that limits on licensees should be determined on a case-by-case basis using the criteria proposed in Sec. 67.3(1)(o). In the alternative, the Department should amend proposed section 67.14(1) to read as follows: “An in-home facility may not maintain or harbor more than six adult animals breeding male or females, as defined in Sec. 67.1, including both breeding dogs or cats and surgically sterilized dogs or cats, in the individual’s residence.”
- Clarifies that titers will not be accepted as a form of vaccination verification. In contrast, licensed breeders concerned with overvaccination often use antibody titers as an alternative to ensure that dogs are protected against infectious diseases. We recommend that the proposal allow breeder licensees to provide evidence of protection against parvovirus and distemper virus by titer.
- Requires dealers, including resident and nonresident rescues and in-state foster care homes, to be licensed; comply with state importation rules; and adhere to significant oversight requirements, including inspections by rescue managers.
Public health and safety concerns are increasingly presented by interstate dog trafficking that supplies retail shelters and rescues. Diseases recently identified in imported dogs include canine brucellosis, a highly contagious bacterial infection that develops in the reproductive system, or as a sexually transmitted disease.
The American Kennel Club supports policies that seek to provide reasonable oversight of animal shelters and rescues.
The current regulations may also be viewed on the Iowa Legislature’s website.
HOW TO COMMENT ON THE PROPOSAL:
Again, IDALS is seeking public input and has indicated to the American Kennel Club that they want to hear from Iowa breeders and hobbyists. AKC greatly appreciates that IDALS continues to communicate with the AKC throughout this process and seek out input.
AKC Government Relations (AKC GR) encourages all concerned Iowa residents who may be impacted by this proposal to review the entire proposal, and provide comment to the Department on how the proposal may in appropriately impact them. Please feel free to use the bullet points, above, as comments.
There are multiple ways to provide comments:
1) Comment online – The proposal may be viewed on the Iowa Administrative Rules website. Comments may be made by clicking a specific section in the document itself or by clicking the “Comment Now” button on the right side of the page.
2) Attend the October 30 public hearing – A public hearing will be held where you may provide comments orally or in writing. The details are as follows:
IDALS Regulations Public Hearing
Wednesday, October 30, 2019
Second Floor Conference Room
Wallace State Office Building
Des Moines, Iowa
AKC GR will publish a copy of its formal comment to IDALS once completed.