Questions
Consultation
Response Form

Name: Mrs Heidi Anderson
Organisation: Chancepixies Animal Rescue. Reg No: 1129742
E-mail/telephone number: enquiries@chancepixies.com / 01304 203311
Your address: Chancepixies Animal Rescue, c/o The Pines, Gravel Lane, West Hougham, Kent, CT15 7AG

Question 1: Do you consider that the definition and requirements of a licence
holder in the proposed licence conditions is clear? If not, please give your
reasons in detail.
Definitions and requirements clear, but shouldn’t be applicable, please see responses to questions 4 and 5

Question 2: Do you think the scope of the definition of a licence holder is
adequate? If not, please give your reasons in detail.
Scope of a license holder is inadequate. Please see responses to questions 4 and 5

Question 3: Do you consider that the proposed Guidance is sufficiently
detailed enough to enable both enforcement officers and dog breeders to
understand the standards to be met at a licensed dog breeding establishment?
If not, please give your reasons in detail.
Please see responses to questions 4 and 5

Question 4: Do you consider that the standards set in the proposed Guidance
for a dog’s environment, diet, behaviour, companion and health needs are
suitable? If not, please give your reasons in detail.
The standards set in the proposed Guidance do not cover what should be considered suitable.

The dogs bred in puppy farms are not allowed ‘to exhibit normal behaviour patterns’ (Animal Welfare Act 2006). Dogs are a domestic pet and a social animal bred specifically by people to be a companion and ally and need to be cared for and raised in a social, domestic environment – not a farm – dogs are pets, not farm animals.
Section Accommodation and Environment, 1.11 “In kennels or sheds or other types of outbuildings, a specific area should be set aside that is suitable for the socialisation of all litters e.g. in mimicking environmental conditions in home environments”. You cannot mimic a domestic environment in a shed/kennel or barn. To have a secure, social puppy, they need to be raised in a home around the usual home sights (people moving around, lights going on and off, other dogs/pets etc), sounds (washing machine, hoover, pots and pans, children etc) and smells (cooking, cleaning, other animals etc), this needs to merely be part of their environment, not have a specific area or time slot where the puppy is bombarded with sights, sounds and smells that are not part of their daily routine. The puppy will be scared, stressed and at high risk of getting ill.
There are no requirements in your Guidance to state that dogs that are to be bred from should have any health tests and that the results should be of a satisfactory standard prior to being bred. Not doing this will allow the continuation of sub-standard, unhealthy dogs being not only sold as family pets, but also the next generation of breeding stock.
Section 3. Normal Behaviour 3.1 – “Dogs over 6 weeks old should have at
least 30 minutes of exercise a day”. At a minimum, dogs should have at least 60 minutes every day with a person known to them so that they can play, exercise and interact with those persons. In the case of puppies, this time should include a brief walk across different terrains i.e. concrete, tiles, carpet, gravel, grass etc this should be done as a litter following the person. This is best done just before a feed (which should be 4 times a day, at 5 hour intervals, for a 6 week old puppy) whereby the person sits in with the puppies and plays with and stimulates them before carrying their food and going for a wander (5 minutes at 6 weeks), returning to put their feed down and removing themselves from the situation to allow the puppies to focus on eating. On finishing or losing interest, the bowl should then be removed and cleaned.
30 minutes of exercise a day for adult dogs is not acceptable. This will lead to the dog being confined for the remaining 23 ½ hours a day, every day for up to 7-8 years. Please note: even this 30 minutes a day level, is not allowed for in your Guidance, if one person was to exercise 20 dogs for 30 minutes each, this would equate to 10 hours a day, 70 hours a week, not the suggested 37 hours a week in your guidance, to do every aspect, not merely exercise.
Your guidance does not allow suitable companionship time with the dog. The dog is a domestic, social animal that needs human interaction and stimulation. It has been scientifically proven that within 6 generations(1) (6 years if a female was bred at one year and a puppy retained and so on), you can completely change the phenotype (character) of the dog. So if someone kept a dog in a kennel without the necessary interaction and socialising with people, bred from it, kept one of the puppies, continued not to meet the social and interaction needs, bred from that dog etc, within 6 generations you would have dogs that would only be suitable to live away from people, at best, certainly not what most people would class as a family pet. Many breeds were bred solely to be human companions and not to allow them the natural behaviour to be around humans for the vast majority of a day, is not meeting their welfare needs under The Animal Welfare Act 2006 Section 9(2)(c).

Question 5: Do you agree that the minimum staff: dog ratio of 1 full-time
attendant per 20 dogs and 1 attendant to 10 dogs for a part-time attendant is
appropriate? If not, please give your reasons in detail.
Not appropriate.
One person on a 37 hour week cannot give 20 dogs the care, interaction and attention that they need and crave. This ratio, when broken down to 7 days and divided by 20 dogs, allows about 15 minutes per day, per dog to clean, feed, exercise and interact, this also does not take into account the time it takes to travel from one dog to the next. Even if it were said that just 1 hour was to be spent with each dog per day, this would result in 20 hours a day. N.B. If someone came to us saying that they would only be willing to spend 1 hour a day with their dog (rescue or puppy) they would NOT get a dog/puppy from us. A companion animal needs companionship.
This staff to dog ratio also contradicts your own Guidance, section 3.1. it states that every dog should be given at least 30 minutes of exercise per day, this would for 20 dogs equate to 10 hours a day for one person, purely to exercise each dog, this does not take into account any cleaning, feeding, grooming etc.

Question 6: At present, the draft Regulations only require a record for all
unneutered females and puppies born after the Regulations come into force.
Do you agree? If not, please give your reasons in detail.
Every dog should be on a national database. For further information please see our own proposals (attached).

Question 7: At present, the Regulations only require unneutered females and
puppies born after the Regulations to be microchipped. Should there be a
requirement to extend this to all dogs kept at a breeding establishment? If not,
please give your reasons in detail.
Every dog should be properly identified (DNA alongside microchip and/or tattoo). For further information please see our own proposals (attached).

Question 8: Do you agree that all puppies should be microchipped before it is
56 days old or before it leaves the premises, whichever is the later? If not,
please give your reasons in detail.
All puppies should be registered and properly identified before leaving the breeder. For more information, please see our proposals (attached).

Question 9: Do you agree that the first registration of a puppy should be to the
licensed breeder? If not, please give your reasons in detail.
All puppies should be able to be traced back to the breeder at any time throughout their life. For more information, please see our proposals (attached).

Question 10: Are there any premises such as sanctuaries, hunt kennels and
licensed boarding kennels that should be exempt from the requirement
outlines? If so, why? Please give your reasons in detail?
Every dog and puppy should be subject to proper legislation regardless of where it was bred within the UK. For more information, please see our proposals (attached).

Question 11: Do you agree that as currently drafted, the Regulations require
that puppies cannot leave the breed premises until they are at least 56 days
old? (Previous legislation allowed puppies to be moved off the breed premises
earlier as long as it was direct to a pet shop owner). If not, give your reasons in
detail please.
Puppies should be sold directly to their new owners from the breeder at 7 – 8 weeks and not be sold through pet shops, as the Dam or Sire of the puppies will not be there to be seen and a pet shop will have no history on the puppies and will be unlikely to help if required beyond the point of sale

Question 12: Do you agree that as currently drafted, dog breeding licenses
should be issued for a period of up to 3 years, subject to a local authority
considering the frequency of inspections and risk, and be renewed as
appropriate? If not, please give your reasons in detail.
If dog breeding licenses were issued in order to inspect premises etc. this should be done annually in line with dog boarding establishments, but would not be necessary in all cases under our proposed guidelines, as each and every mating and resulting litter would be recorded and subject to scrutiny.

Question 13: These proposals might incur costs to bring dog breeders up to
the required animal welfare standards. Please provide appropriate evidence
based information.
Dog breeders should be guardians of their breed/dogs and as such, it is not a financially viable business (please see break downs in response to Question 14). The vast majority or our own proposals are already acted upon by responsible breeders so any extra costs incurred would be minimal and welcomed by responsible breeders, but to ‘farm’ dogs legitimately and make a profit will not be possible.

Question 14: We have asked a number of specific questions. If you have any
related issues which we have not specifically addressed, please use this space
to report them:
Breeding of dogs is not a legitimate business. There are thousands of dogs unwanted in rescue centres and thousands more being killed every year – all for want of a responsible home.
Puppy farms are purely in the ‘business’ of making money – selling to irresponsible owners and pet shops – fuelling the escalating problem of Britain’s unwanted dog population.

Please find below our financial breakdown taking into account just 1 hour per day, per dog:

At the current minimum wage of £5.93 per hour x 20 hours = £118.60 per day x 7 days = £830.20 x 52 weeks = £43,170.40 a year in wages.
As an average, it will cost £10 a week to feed each dog. 20 x £10 = £200 per week x 52 = £10,400 + in wages = £53,570.40 a year basic costs (this figure does not include food, vet bills etc)
Also in the Animal Welfare Act 2006 it states that:
• (f)that bitches are not mated if they are less than one year old;
• (g)that bitches do not give birth to more than six litters of puppies each;
• (h)that bitches do not give birth to puppies before the end of the period of twelve months beginning with the day on which they last gave birth to puppies;
Given this, and if these laws are obeyed, then the most a ‘farmer’ can expect to make from each bitch is: 6 puppies (average litter) x £500 (average cost per puppy) = £3000 x 20 (bitches) = £60,000 a year.
From this figure you need to take away the year one set up costs, which include breeding stock i.e. £500 x 20 = £10,000. The first year of feed and care with no income (before they can be bred from beyond 12 months of age) these figures are: £43,170.40 a year in wages and £10,400 in feed for 20 dogs, gives a total loss of £63,570.40 for year one. In addition to this are vet, license fee, rates, utilities, rent/mortgage, depreciation etc. Even on a purely financial level, this is not a legitimate business if done according to the laws. In years 2 – 6 the cost of bitch purchases is replaced by stud fees for 20 bitches 20 x £500 = £10,000.
Bearing in mind all the above, and according to the laws as they currently stand, the finances are (for 20 bitches);

Year 1 = £63,570.40 loss
Year 2 = £3,570.40 loss
Year 3 = £3,570.40 loss
Year 4 = £3,570.40 loss
Year 5 = £3,570.40 loss
Year 6 = £3,570.40 loss
Year 7 = £3,570.40 loss

Total = £84,998.80 loss
Divided by 7 years
Total loss per annum = £12,142.69

At the end of the useful life span of a bitch (7 years), it would be unviable to keep 20 dogs for a further 3 – 7 years, and a ‘farmer’ will need to buy new stock. These 7 year old dogs can either be killed or rehomed. Bearing in mind that they have never been in a home environment, never really been shown human kindness and been used purely as breeding machines – not quite the image of a beloved family pet.

Puppy farming cannot be seen as a legitimate business, not on an ethical level nor a financial one, even on your proposed recommendations, let alone sensible, responsible ones with the bitch and puppies welfare at heart.

Your guidance does not consider the time involved in whelping and rearing a litter of puppies. As a quick summary; a bitch is usually pregnant for an average of 63 days, in labour for 12 hours, giving birth for a further 12 hours. The time involved over the next 4 weeks where the bitch will (hopefully) be doing all the feeding of the puppies, is quite considerable as the mother should be fed a minimum of every 8 hours to ensure her best health, and also should be monitored and observed at regular intervals, usually on an hourly basis, to ensure the best health of both her and the new born puppies.

If this was to be staffed properly this would entail a member of staff 24 hours a day for 28 days equalling 672 hours, which at today’s minimum wage of £5.93 per hour would be a cost of £3,984.96 for the time alone.

Puppies are generally weaned between 4 and 5 weeks and from then on should be on four feeds a day at 5 - 6 hour intervals (in line with their digestive system), as well as their area being constantly cleaned and the puppies socialised. Again, this is a time consuming period with approximately 14 hours a day needing to be staffed until they are 7-8 weeks and should be going to their new homes. These hours would equal 392 hours (14 x 28) at £5.93 = £2,324.56.

On top of these costs would be the puppy food, vet bills, wormer etc, a recent survey we conducted had costs of around £150 per puppy for this 8 week period.

Dogs, and the breeding of dogs, is not, and should not, be classed as agriculture and although this could be done as a ‘hobby’ and so cut the cost of staffing it, the person should take all of these requirements on board (health, character, conformation and ID). They should also bear in mind that if the dog does not produce progeny of the desired standard, that dog/bitch should not be bred again. They should also be prepared to offer a life time guarantee of help, advice and support should it be needed, and to take back any dogs that they have bred if, for whatever reason, the owners felt unable to keep them. This is part of being a responsible breeder and would result in the dramatic reduction of dogs in rescue centres and dogs being dumped in Council pounds.

All these issues together would not make for a viable business proposition, so we are not sure how this could be classed as a legitimate business.

On reading through your proposed regulations, and hearing many reports, it seems that smaller breeders have already come up with avoidance tactics to circumvent your proposed regulations (by registering friends and family as breeders of individual litters and therefore not required to register). However, if you are truly looking to tackle the problems that are present in Wales (and indeed across the rest of the UK), we have included with this letter outlines of our proposed legislation that, unlike others, does not penalise the responsible breeder (as most will already comply to 90% of our proposals) but does make it unviable for irresponsible breeding (which includes, but is not exclusive to, Puppy Farming) to exist. Should you wish to discuss these proposals further we would be more than willing to consult with you.

We believe your proposed regulations have not in any way taken into account that the dog is a domestic pet. For this reason, the dog is not an animal that can be farmed, puppy farms in any form should be classed as illegal under the Animal Welfare Act 2006 sections:

4 Unnecessary suffering (1) A person commits an offence if—(a) an act of his, or a failure of his to act, causes an animal to suffer. With a social animal being left unattended for up to 16 hours a day, every day for 6 -8 years, that dog is suffering.

9 Duty of person responsible for animal to ensure welfare (2) For the purposes of this Act, an animal's needs shall be taken to include— (c) its need to be able to exhibit normal behaviour patterns. For a social animal bred specifically by humans to be a companion or ally, needs to have interaction with people and/or other dogs to meet these basic requirements. We believe that to farm a dog contravenes the Animal Welfare Act 2006 as these dogs, over the prolonged period of several years, would be unable to display ‘normal behaviour’.

29 Inspection relating to Community obligations
(1)An inspector may carry out an inspection in order to check compliance with regulations under section 12 which implement a Community obligation. 12 Regulations to promote welfare
(1)The appropriate national authority may by regulations make such provision as the authority thinks fit for the purpose of promoting the welfare of animals for which a person is responsible, or the progeny of such animals.) Puppy farms, by way of what they are, produce unwanted , unhealthy and unsocialised animals, that cannot live up to any ‘community obligation’ as they negatively affect any community, by placing an ever increasing burden on the taxpayer to support the local authorities attempts at dealing with the stray/abandoned dog problem that Puppy Farms and other forms of irresponsible breeding fuels.

In conclusion, proposed regulations fail on the following points:
• If the Guidance and the laws as they stand were adhered to, it would not be financially viable for dogs to be bred as a business, so it is clear that the farming of dogs is not a legitimate business.
• Legislation is only effective if it is enforced. To effectively enforce the Guidance, among other responsibilities, Inspectors would have to make unannounced visits to these premises and take action on their findings. There are many laws in existence at the moment that are not enforced. However if legislation like our proposals were to be adopted, because it covers all of the aspects that affect dogs in the UK, it would (as has been proved in other European Countries) be enforceable and effective, not only in raising welfare standards, but would also positively affect the abandonment of dogs, the breeding of dogs and the treatment of companion animals.
• To breed and raise a domestic pet, the pet needs to be born and bred in a domestic environment. To breed an animal suitable for what its’ function is, you cannot break these universal laws without consequence, for the animal or the general public.
• To breed dogs as a business is not a legitimate business on a financial, moral or ethical basis. With over production resulting in over 100,000 dogs being recorded as strays in 2009, and many thousands more unwanted in rescue centres. These official ‘stray’ dogs are also costing the local authorities (the taxpayer) millions of pounds every year.
• We believe these regulations are in contraction to the Animal Welfare Act 2006 sections 4(1)(a), 9(2)(c) and 29(1).
It is on these grounds that we ask you to reconsider your proposals in favour of such proposals that we have attached with this letter.

We look forward to your acknowledgement of these facts and to your future correspondence with us.

Mrs Heidi Anderson
For and on behalf of
Chancepixies Animal Rescue

(1) - Russian geneticist Dimitri Belyaev, Institute of Genetics in Siberia 1950s regarding the Russian silver fox breeding program