The following is a letter to my local MP. It is not an endorsement or condemnation of the MP or the political party he represents. This is not a political blog, and political rants or comments either promoting or denigrating any particular political party or politician will not be tolerated. I have been asked by other breeders or concerned persons if they may copy my letter in order to write to their own MP, and the answer is yes, you may copy and modify this letter. Please write to your MP if you are concerned about new legislation. Find who your MP is here.
I write to you
concerning the recent and forthcoming changes in legislation
surrounding dog breeding.
I am supportive of
the new moves to ban the third-party sales of puppies and was
supportive in reforming the licensing legislation with some
reservations. I have some concerns about how this is being
implemented and would like to bring to your attention some aspects of
dog breeding the government may not be aware of.
I am a conservation
breeder of Poodle (standard). I suspect many people, and probably the
government going by what has been written in the new guidelines, do
not understand what it is that conservation and other small-scale
breeders do. We breed in order to keep dogs for ourselves to continue
a bloodline, to preserve an historic breed and prevent loss of
genetic diversity, which if attention is not paid to it could result
in that breed’s population becoming unviable and the breed
ultimately becoming extinct. Some people breed in order to compete in
the traditional sport of conformation showing or in other sports such
as agility and working trials. Each breeder’s dogs (in addition to
being beloved family members) and bloodline represents a significant
investment of time and research in choosing the best combinations of
dogs to mate together and careful selection of puppies to keep and
found subsequent generations upon, sometimes for many generations over the breeder's life or even longer. The objective of breeding in this
way is not to sell puppies to make money, although as dogs are born
in litters the ones that are not kept are sold as pets to carefully
vetted persons and the proceeds used to help pay for the costs of
running the breeding programme.
I am also a member
of the Kennel Club’s Assured Breeder scheme. I joined this
voluntary scheme as it is more accommodating of small-scale breeders
than council licensing. I was pleasantly surprised that the inspector
who came to my premises when I joined was herself a dog breeder with
real experience of the issues and what makes a good dog breeder, and
not just a bureaucrat.
Small-scale breeders
probably account for a tiny minority of puppies that are sold in the
UK, but they are almost certainly the best source of a puppy
available. The advantages are the lifetime support owners receive
from the breeder, the careful selection to develop a fit-for-purpose
bloodline meaning that buyers choosing a breeder who specialises in
the purpose they want the dog for getting a superior animal, and the
enormous time investment small breeders are able to put into
socialising their puppies as they have no more than two litters a
year and the dogs live in the house.
Firstly, I very much
support moves to ban the third-party sale of puppies. Puppies should
only be bought from breeders where the buyer can see the dam and the
environment the puppy has been brought up in, and the puppy’s owner
should be able to benefit from lifetime support from the person who
bred the puppy. It is also extremely important to breeders that they
are in touch with the owners of their puppies and can be informed if
there is a potential genetic issue with one of them so they can take
careful steps to reduce the risk moving forward in their breeding
programme.
Secondly, I would
like to draw your attention to something that the recent legislation
seems to have completely ignored, an issue which I can only describe
as ‘dog pimping’. Responsible breeders of course are likely to
own male dogs and use them for breeding, and breeders tend to allow
other breeders they trust to sparingly use their stud dogs by private
treaty, and this is necessary so breeders can access unrelated
breeding stock. However, some people actively advertise dogs at
public stud to anyone. There is a website called ‘pets4homes’
where male dogs are publicly advertised in a disgraceful manner,
often with the adverts suggesting the dog is to be made available to
any bitch of any breed, particularly to fuel a current fad to produce
novelty mix-breed puppies. Unlike Kennel Club registered dogs of a
known breed, mixed-breed puppies are not registered and there is no
paper trail, and many of these advertisers are likely doing lucrative
business under the HMRC’s radar in this way, and it is extremely
unlikely they have any interest in breed conservation. It is also a
potential biosecurity risk and contributes to ‘popular sire
syndrome’ and gene pool collapse. Yet the new legislation seems to
completely overlook this issue. I would like to see the pimping of
dogs on commercial websites and similar banned, or at least people
who advertise this kind of business required to have a licence and to
conform to basic standards.
Thirdly, there are
several issues I have with the legislation and guidelines that have
been issued by DEFRA “
Guidance notes for conditions for breeding dogs” that will be coming into force in October that have been
published. I will attempt to detail them below:
The ‘Business
test’ implies that if a person makes a profit of more than £1,000
in a year from dogs, they will need a licence. However, it is more
complicated than this in practice. I have not so far made a profit
from breeding dogs, but someone might make more than this amount in
one year if everything goes well yet in all other years make a loss.
People are likely to feel pressured to either increase their breeding
if they are forced to pay for a licence year after year, which is not
in the interests of the dogs, or to scale down as to avoid having
profits.
The way the
guidelines are written is aimed at businesses that treat their
animals as livestock, and some of the requirements are nonsensical or
difficult to achieve for small breeders. For example, it is a
requirement that whelping boxes ‘be raised off the ground’. It is
totally unclear why this should be. I sleep on the floor next to my
whelping box when my puppies are born, and if the box is raised off
the floor, it would be harder to check the puppies and the dam. Also
it would not be safe if I stood or knelt in such a whelping box when
helping my bitch tend to her pups or give birth. The guidelines also
stipulate that a particular kind of mesh has to be used for fencing
of outdoor areas the dogs use, that ‘each weaned dog has to be
provided with a non-slip water bowl’ (I have 6 dogs at present and
one of them is a puppy who likes to try to go swimming in the water
bowl).
Most concerning to
me is the requirement that dogs be vaccinated for leptospirosis.
Leptospirosis is a non-core vaccine as defined by the
World Small Animal Veterinary Association, which means that dogs should only be
vaccinated with this vaccine if their circumstances mean they are at
risk of this disease. The protection provided by the vaccine is
short-lived and dogs who need it have to be revaccinated annually and
there appears to be a high rate of adverse reactions. Many people,
myself included, do not use this vaccine and instead only use the
core vaccines recommended by the WSAVA (distemper, hepatitis, parvo)
and elect instead to keep dogs away from areas that may prevent a
lepto risk such as stagnant water and places rats may have urinated.
It makes no sense why a non-core vaccination should be a requirement.
"Where any other activity involving animals is undertaken on the premises, it
must be kept entirely separate from the area where the activity of breeding
dogs takes place." Many dog breeders keep pets other than dogs, meaning they cannot conform with this requirement.
“A bitch must not
be bred from if they (sic) have had one caesarean.” This is a
recommendation and not a requirement, but I am concerned about the
direction this is going. The decision to perform a caesarian section,
an invasive surgery, on a bitch is taken by the owner of the bitch
and her vet and weighs up the welfare and risks to both the bitch and
any born or unborn puppies. There are a great many different reasons
why a whelping might go wrong and a surgical delivery may become
necessary. If the bitch is automatically written off as a breeding
animal if she is subjected to this procedure, it adds an unsavoury
third consideration. There is a risk that a caesarian section will be
seen as a last resort only if a bitch’s life is in danger and the
bitch left to struggle when the surgery would have been in her
interests and those of the pups, and there is also a risk that people
will rush to do the surgery with the first suggestion of something
not going quite right in fear that if the bitch loses the litter and
needs the surgery after she will be written off and the breeder will
lose the bloodline, when with a little more patience the bitch might
have had her pups naturally. Furthermore the rationale for this is
completely obscure. The rationale for not allowing a bitch who has
had two caesarian sections to be bred again is because of the damage
done to the uterus by two surgeries of this sort and the risk to the
bitch in subsequent pregnancies. In this case, if one surgery is
required, the breeder will know the reason and be able to plan
another litter and how to reduce risks taking this into account.
“No bitch will be
intentionally mated when the Coefficient of Inbreeding of the
puppies would exceed
the breed average or 12.5% if no breed average exists as
measured from a
minimum five generation pedigree.” This is a nonsensical line in
the sand. A COI of 12.5% is the equivalent of half-siblings being
bred together, or a grandfather to a grand-daughter. Most people
would consider this an unacceptable cut-off. What if the breed
average is 0.1% – a completely insignificant relationship, and
breeding a COI of 0.2% carries virtually no risk? What if the breed
average is 25%, the same as full siblings and not acceptable to any
reasonable person? In practice, cousin matings (6.25%) are generally
considered to be the closest linebreeding that is acceptable. COIs
vary depending on how they are calculated, and accurate COIs
generated from deep pedigree analysis tend to come out higher, but
are the most reliable.
It is a concern to
me that the government is trying to force small breeders into a
bureaucratic licence system developed for commercial breeders. Small
high-welfare breeders who do not make much money from breeding to pay
for a licence fee will not be able to compete against businesses that
exist to sell dogs for money, particularly if they have to also
invest in upgrading their house to be like a commercial puppy manufactory
and vaccinate their dogs with vaccines that are unwanted, unnecessary, and
ineffective. The government is effectively promoting large-scale dog
farming and pushing out small breeders.
Thank you for your
consideration,
Dr R.