Letter to James Gray MP

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.

Dear James Gray,

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.