Our response to the information provided by the Central Oklahoma Humane Society (COHS).

You might ask why this is important or for that matter even here on this site. Well...

One of the members of the Oklahoma State Board of Commerical Pet Breeders who wrote the rules is Christy Counts, President/Executive Director of the Central Oklahoma Humane Society. Seems like the fox in the hen house to me.

Please take a moment and read the comments from Central Oklahoma Humane Society, You will find our comments in red.

First things first. "Puppy Mills" is not a legal term. No legislator seems to be able to define that for us. The proper way to address this is sub-standard kennel. It is however a social economic term that should no longer be used. Think about it, you will get it.

From the COHS site: Oklahoma's laws protecting our dogs and cats have not kept pace with what has become a $1 billion pet industry.

So, even they admit that the economic impact of the pet industry is huge.

From the COHS site: The American Pet Product Manufacturers Association estimates the public and industry will spend $1 billion annually buying dogs (no estimates available for cats.) This is a large industry and Oklahoma contains the second largest number of commercial pet breeders among our 50 states. In 2008, there were 475 USDA registered breeders in Oklahoma, and an estimated 600 to 1,000 unregistered breeders. The growth of unregistered breeders is much faster than the registered breeders because USDA licensing is not required for direct public sales.

According to Oklahoma State Representative Renegar (District 17), we now have about 1,000 registered USDA breeders (as of 2010). Humm... do you wonder why they don't tell you that?

From the COHS site: Unscrupulous commercial breeders come to Oklahoma to operate puppy mills to avoid laws and policing that would shut them down in 25 other states.

The number of commercial breeders moving to Oklahoma from other states continues to grow because there is no state agency responsible for insuring standards of care and compliance or even handle complaints like most other states. USDA laws apply to only about one third of the commercial pet breeders, and provide for very few enforcement or penalty provisions. This is why over half of the states in the country have enacted laws regulating commercial dog and cat breeders, with many more states following.

For example, the HSUS spent over 4 million dollars in Missouri to get Prop B passed. Guess where that money come from? Your contributions to them! You think your saving a pet while they are putting good breeders out of business with your money. Don't believe me, go back to the menu and read the research on Wayne Pacelle. 

From the COHS site: State leaders receive hundreds of out of state phone calls every year from disgruntled purchasers of puppies from Oklahoma. (The Commercial Breeding of dogs and cats is not made into a criminal act by this bill. It is made consistent with other businesses regulated by the state.)

Guess what folks, this bill and the rules will not do anything to stop the sub-standard kennels. They are not going to step up to be licensed. It will only put good, licensed breeders out of business and increase the price of that registered puppy you want.

From the COHS site: Unscrupulous breeders:

Neglect and abuse of our dogs and cats.

Hundreds of puppy mills, with the dogs living in abysmal conditions, have been discovered in Oklahoma over the years, usually too late to save. If commercial breeders had done a better job of self policing, then regulation would not be necessary.

Oklahoma Pet Professionals came out publicly with condemnation of the sub-standard kennel and do turn them in when they find them. If the Oklahoma Veterinary Board would only check on the location the puppies came from when there is complaints, wouldn't the animal cruelty laws already on the books take care of it? HSUS has millions to spend in every state to change the law. What if they spent that money to help enforce the law that already exists?

From the COHS site: The puppy mill problem in Oklahoma is a national embarrassment, already having been the subject of a special series on the Oprah Winfrey Show.

I watched that show as well. It was a HSUS propaganda stunt, just like the commercials they show you on TV. Guess who crowds those dogs into little cages? Look closely next time. In one of the pictures the cages are in the back of a pickup. They are being hauled away. Yes, the dogs more than likely needed rescued. I say BRAVO to that. However, using that picture to tell you, the public, they live like that is abysmal!

From the COHS site: Over breeding contributed to more than 60,000 dogs being euthanized in Oklahoma in 2009 alone.

Look folks, what they are not telling you here is this: how many of those dogs are strays, or the product of a privately owned pet that got bred accidentally. Yes, that is right; that number encompasses, stray, abandoned and unwanted pets too. Looks a bit different if you take that into consideration, doesn't it?

From the COHS site: Over 60,000 dogs were euthanized in Oklahoma last year. The State and your cities pay for the catching, sheltering and euthanizing services at an estimated cost of $133 per dog. The cost to the state is about $8 million dollars annually. Since these consequences are not incurred by the commercial breeders, the breeders continue to over-supply the market. No data is available on cats, but the number euthanized is estimated to be very high as well.

Again, did the breeders cause all of the problems?

From the COHS site: Currently, Oklahomans lose $140 million* over 5 years because of nonexistent or ineffective licensing and inspections regulating our commercial dog and cat breeders.

(*annual uncollected sales tax – $20 million; and, annual euthanizing services – $8 million)

Guess what ~ The reason most USDA breeders do not collect sales tax is they sell wholesale.  Wholesale = no tax collected or due! The tax should be collected at the retail level. Good breeders do pay sales tax on the retail sales of pets and claim the income on their tax returns. If they are licensed, they have too. Those not paying the taxes are also not going to step up to be licensed. We still don't know who or where they are. This bill and the new rules to go with it are not going to change that.

Would a State wide license fee for every pet, of say $1.00 a pet, not fund a few more humane officers and off set the costs to Oklahoma?

From the COHS site: Commercial sales in Oklahoma are estimated between $75 million to $200 million annually. If state sales and income taxes were collected, the Oklahoma Tax commission would collect between $7.5 million to $20 million annually. Without regulation, the state has no method for determining the taxes due.

Regulations are not going to bring the sub-standard kennel to the table. Breeders that are licensed and doing it right don't want them out there either. Hey, look at it from the reputable breeders stand point. Sub-standard breeders are giving good breeders a black eye by flooding the market with sick puppies, and selling these puppies for less than a good breeder can, as they have a lower cost of production. The reputable breeders want them gone as well. However, all that the proposed regulations are going to do is punish those people that do it right. This is not the answer!

This is another law we cannot afford. Guess who has to foot the bill. That is right folks, the licenced breeders. The cost of becoming licensed under these new rules will drive some good breeders out of business. The cost of a good puppy will skyrocket if they keep picking breeders off state by state. We will end up with 2 types of puppies available: the cheap puppy from questionable sources, and $2,000 or up puppies, from the few that are forced to rebuild a whole kennel to meet the rules requirements, or go out of business. Since the HSUS wants "NO MORE PETS", doesn't this play right into their hands? Just saying....