Associated Dog Clubs of
New York State
AKC response to residential breeder bill
It was a pleasure to meet you in Rochester! I want to thank you for your patience in allowing us the time to review S.7600. I wanted to reiterate to you some thoughts we shared with Wanda a few months ago on an earlier draft of this proposal, and provide you with AKC’s position on this version.
We share ADCNYS’s frustration that home-based breeders are often included in local proposals and understand your desire to make sure they are not subject to laws designed for higher-volume breeders.
We also think that the minimum standards of care in the bill are very reasonable and fair for all breeders, and I know much of it is taken from current law. One of the suggestions we have made is that you require the complaints to be substantiated prior to an inspection. This would cut down on harassment, which has been a concern with inspections in other jurisdictions. We have some suggested language from other states on this if you would like us to provide it to you.
As we spoke about briefly in Rochester, AKC does remain concerned that while this bill may accomplish many good things in the short term for “residential breeders” as defined, it may also prove a hindrance in some circumstances, and could potentially open the door for further revisions and regulations on both the state and local levels in the longer term.
We applaud the local preemption language in the bill, but we are concerned that anti-breeder groups can still target the concept, change the term, and continue to push for new regulations at the local level, as we’ve seen happen with those defined as “pet dealers”.
We also believe that many of the pet dealer bills introduced on the local level are not good for any pet breeders or sellers – be they hobbyists or commercial. As such, we want to be careful about supporting an exemption that may give the appearance that we are not concerned about the interests of all responsible breeders/dealers. I see that page 2, line 51 says that this shall supercede any local law, rule, regulation or ordinance regulating or licensing breeders, but we are unclear if this applies to all breeder/dealers, or just to residential breeders as defined in this proposal. We are concerned that given the anti-breeder pressures in the State, this could actually undermine the rights and freedoms of long-term responsible purebred breeding and ownership if localities are permitted to continue to overregulate breeders who are not considered “residential”.
This is why the AKC has not taken a position on this bill. As we said, there are many things in this bill to applaud, and we support your efforts and your goal. It is our understanding that the legislature is expected to adjourn very soon. We’d love to work with you over the interim to address these questions and come up with some effective solutions.
Please let us know if you have any questions, and let us know how we can continue to work with you and ADCNYS to help protect responsible owners and breeders in New York. Thanks for all you do!
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