HomeMy WebLinkAboutJolyn Noethe 8.24.211
Danielle Marshall
From:Jolyn Noethe <jakspuppies09@gmail.com>
Sent:Tuesday, August 24, 2021 12:13 PM
To:Danielle Marshall
Cc:kayla@puppylandwa.com; justin@puppylandwa.com; JAKSPUPPIES09@GMAIL.COM
Subject:Testimony Against the Proposed Rule Changes Regarding Retail Pet Sales
Chair Matson and Commissioners,
Thank you for taking the time to hear my concerns about the proposed rules and regulations regarding puppy stores in
your great city of Renton. Justin and Kayla Kerr, the owners of Puppyland in Renton, asked me to reach out to you to
hopefully give you some more insight as you embark on the path of adjusting the rules and regulations for your pet
stores.
I wanted to share with you the public testimony that I put forth back in February when HB 1424 was being proposed, in
case any of you have yet to read it. It details out many of the concerns that were had with the original bill, before
Chairman Kirby’s amendments were adopted and enacted. I would specifically like to draw attention to the section in
red below. These two sections are directly related to the City of Renton’s proposed rule changes, regarding sourcing
from breeders with fewer than 50 dogs and requiring all sources to abide by the WA State rules and regulations
regarding commercial dog breeding. I ask that you consider why Kirby and his fellow committee members didn’t pass
HB 1424 as written with the very rules that the City of Renton is considering adopting. I believe that Kirby and his fellow
committee members realized that adopting HB 1424 with these 2 clauses was not in the best interest of their
constituents, their businesses, or the State of Washington.
If I can help provide you with any other documentation to support my testimony please feel free to reach out! I am
happy to put you in touch with several professors (Candace Croney, PhD, Purdue University), veterinarians (Brandon
Sinn, DVM), researchers (Patti Strand, NAIA), etc. that can provide you with researchable, scientific data to help guide
you through what is best for animals, your city, and your constituents.
Again, thank you for the time to hear my concerns.
Jolyn Noethe
J.A.K.’s Puppies, Inc.
Britt, IA 50423
---------- Original Message ----------
From: Jolyn Noethe <jakspuppies09@gmail.com>
To: steve.kirby@leg.wa.gov, amy.walen@leg.wa.gov, brandon.vick@leg.wa.gov,
jeremie.dufault@leg.wa.gov, chris.corry@leg.wa.gov, cindy.ryu@leg.wa.gov,
sharontomiko.santos@leg.wa.gov
Date: February 11, 2021 5:28 AM
Subject: J.A.K.'s Puppies, Inc. Testimony to Oppose WA HB 1424
Chairman Kirby and Committee Members,
CAUTION: This email originated from outside the City of Renton. Do not click links, reply or open attachments unless
you know the content is safe.
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Thank you for taking the time to read my written testimony regarding HB 1424. My name is Jolyn Noethe.
I am the President and co-founder of J.A.K.’s Puppies, Inc., a USDA and State of Iowa licensed
wholesale distributor of puppies (aka “broker”). I strongly oppose this bill as I believe it is based on
inaccurate information being given to you by animal rights activists. It will directly affect close personal
friends of mine, who are also clients, that own Puppyland – Justin and Kayla Kerr. Due to the length of
my testimony, I thought it best to submit it directly to each of you via email.
Animal rights activists are becoming much more aggressive in targeting members of the pet
industry. They don’t understand what, how, or why we do what we do. Instead of trying to work with
members of the pet industry to better the health and quality of the animals being offered to consumers
across the United States, they believe that no one (except people of their own liking) should be able to
raise animals for profit. In the past, members of our industry have kept their heads down and mouths
closed (myself included), knowing that no matter what we did it was never good enough. If we speak
publicly or catch the public’s eye, our words and actions are twisted to fit the activist’s agenda. The fear
of being physically and verbally harassed, attacked, and tormented is a constant, as is the case for the
Kerr’s and myself. Gone are the days where breeders, brokers, and pet stores can be silent. Now, we
must stand up as an industry and show everyone that we believe in what we do, why we are great at what
we do, and why what we do is necessary for consumers across the United States, specifically, in this
case, the consumers of the State of Washington.
Many industry professionals have been rallied to testify against this bill, with verbal and/or written
testimony. I ask that you acknowledge that each of them, including myself, are doing so knowing we
could be risking our personal and professional safety, since the probability of being harassed by activists
is high. You will hear from veterinarians, virologists, breeders, brokers, kennel clubs, pet stores, industry
workers, and other industry affiliates in the quest to help detail to you what the pet industry is truly
about. Some of those testifying are affiliated with J.A.K.’s and some are just industry
professionals. Every one of them are extremely passionate about their role in this industry, as am I.
I am aware that this isn’t the first time that J.A.K.’s has been thrust at you and I will try to be as brief and
clear as I can to discuss some of the myths that have been told to you in regards to J.A.K.’s and give you
the facts as I know them to be:
1. First, I’d like to address the Humane Society of the United States’ (HSUS) “Horrible 100” list. I
urge you to realize this is a simple piece of negative propaganda that activists compile yearly in
an attempt to shine the pet industry in a negative light. There is no science or methodology to
determine who gets a “spot on the list.” It is compiled by HSUS and I believe it is based on
emotion and hatred for those that do not share their views. That being said you are being shown
that in 2019, my company made the list for the first time since its inception in 2009. Although I
personally put zero merit in this so called “Horrible 100” list, I will say that historically the title
holders have been those that have been found to be in violation, of either state or federal
regulations, in regards to animal welfare. HSUS uses their own discretion to determine is one
breeder, and not the next, with the same infractions, will make the list. My entry on the list had
absolutely nothing to do with infractions pertaining to the welfare or care of any animals, but
instead J.A.K.’s was placed on the list due to animal rights driven, non-animal related, litigation
between the State of Iowa and J.A.K.’s Puppies, Inc.
2. To briefly touch on the aforementioned controversial lawsuit, I want to clarify that J.A.K.’s, past
and present, has not been found guilty of any crime or of any of the allegations made by the State
of Iowa. In fact, we maintain that the allegations made were unfounded. The lawsuit ended in a
consent judgment, as J.A.K.’s worked out an agreement with the State. The agreement included
a prohibition against certain activities which we maintain we were not previously doing, and thus,
were agreeable to continue refraining from doing them. It included more transparency for the
State – something about which we did not previously object. A lump sum payment to the
Consumer Education & Litigation Fund (CELF) was also included in the settlement, but is/was not
classified as a “fine.” Between paying our attorneys and fighting the State in what could be
endless litigation, the payment to the CELF was deemed more economical for J.A.K.’s. It was
decided that the resources J.A.K.’s would have used in litigating this lawsuit would be better used
to promote and improve the welfare of animals instead. The consent judgment was agreeable
and maintainable for J.A.K.’s and each provision has been and will be upheld.
3. Activists have accused J.A.K.’s of being a “puppy mill” broker, with myself and our breeders being
inhumane. Not only is the “puppy mill” term highly offensive and derogative, it’s an out-right lie.
That term is used freely by animal rights activists to stir up emotions and anger. J.A.K.’s has held
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a violation free USDA license since November of 2009. We are subjected to unannounced
inspections, a minimum of once a year, but typically more frequently than that. J.A.K.’s has
always adhered to, and in many cases surpasses, all aspects of the Animal Welfare Act (AWA)
and all of its amendments. Not only is J.A.K.’s licensed by Iowa Department of Agriculture And
Land Stewardship (IDALS), we are also licensed in the following states: Pennsylvania, Ohio,
Illinois, Wisconsin, Missouri, and Kansas. No regulatory agency has ever found J.A.K.’s in
violation of their regulations. J.A.K.’s sets very high standards for our breeders, and we are
selective in who we will buy from. We work with our breeders to ensure they are in compliance
with all of their governing agencies, as well as help them meet all of our standards. The Kerrs
and I are happy to discuss with any member of this committee these standards and show you, if
you have the time, several of our breeders facilities (please watch the video of some of J.A.K.’s
breeder facilities that was submitted on behalf of Puppyland by their lobbyist). The pictures and
videos the activists like to claim are breeders that source to J.A.K.’s are either outdated (and no
longer depict the current circumstances) or are not a breeder of J.A.K.’s. The pictures of animals
shoved in filthy, stacked cages they show you are not of J.A.K.’s breeder’s facilities. Many
professions evolve and adapt and improve with the times and new technology. Activists desire
that you believe that professional, commercial kennels and the pet industry have not evolved, and
such assertions are false. The professional commercial kennels and small hobby breeders that
J.A.K.’s sources animals from have evolved and strive to excel in their craft and profession.
4. The activists claim that the commercially bred puppies that J.A.K.’s places in pet stores are over
vaccinated, over wormed or full of worms (claims that are inconsistent on their face), unhealthy,
and “ripped” from their mothers before they are 8 weeks old. These are absurd accusations. To
wean puppies too early from their mothers (which I assume is what the activists are referring to
by using the term “ripped”) would be careless and of zero benefit to the big picture. Not to
mention, J.A.K.’s cannot obtain any animal under the age of 56 days, which is usually 1-2 weeks
after they are fully weaned off of their mothers. If a breeder feels that a specific puppy is not
ready to be in its new home yet, they hold that puppy in their facility until it is ready to be
transferred. As for over or under vaccinating & deworming, in order for a breeder to source
puppies to J.A.K.’s, they must follow a very strict vaccination and deworming protocol developed
by the veterinarians and virologists at NeoTech Industries, a leading vaccine developer and
manufacturer. J.A.K.’s also follows a protocol for their facility that was established by those at
NeoTech, and approved by our attending veterinarian. Not only do I and J.A.K.’s employees
confer and consult regularly with our attending vet (who is available to us 24/7 as needed), we
work closely with numerous other veterinarians for different consulting purposes. Our facility
protocols were and are created and approved by veterinarians. The same holds true for each of
our breeders individually.
5. Another false claim the activists make regarding J.A.K.’s is that we “cram underage puppies into
semi’s & truck them coast to coast.” Again, please note that a licensed USDA transporter or
dealer cannot take possession of any animal until it is 56 days old, which discredits their
accusations of them being underage. By the time our puppies are transported to pet stores, they
are very close to 9 weeks of age or older. Also, J.A.K.’s has never owned a semi or used a
transporter that utilizes semi’s to transport animals. J.A.K.’s uses an independent transporter that
is also USDA licensed and inspected. The transporter uses climate controlled Transit vans that
have unfettered access from the cab of the van to the rear of the van. Each van is equipped with
everything necessary to get each puppy to its predetermined location. All drivers are properly
trained in the care of the animals during transit and the regulations for transporting animals. No
more than 4 animals can be placed in enclosures for transport, and each animal in that enclosure
must be able to stand up, lie down, and move around freely. Cramping animals in cages would
be a violation of the laws and regulations regarding the transportation of animals set in the AWA,
and the transporter J.A.K.’s uses has never been in violation. The AWA requires enclosures to
be cleaned daily, animals must be checked on every 4 hours, and offered feed & water every 12
hours. Our transporter cleans its enclosures several times each trip; the drivers have access to
the puppies at all times but do thorough checks of all animals at a minimum of every four hours
(usually more frequently and it is documented when done). All puppies have food and water at
their disposal at all times during transit to the pet stores. J.A.K.’s is located in the Midwest – no
animal is in transit typically for more than 40 hours (start to finish) to its final destination, with
exception of rare mechanical and nature delays. We do not transport animals coast to
coast. The transporter owns and operates several vans weekly to get the puppies to their
predetermined pet stores. The company that we use has vans and drivers used to exclusively
transport J.A.K.’s. animals to Washington, greatly reducing the undue burden of added stress and
external contaminants.
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6. The claim that our industry is very secretive and J.A.K.’s is cloak and dagger is also
false. J.A.K.’s offers full transparency with all of our breeders and pet stores and facilitates the
transparency between breeders and pet stores. All of our pet stores have access to our facility
and to each of our breeders facilities as well. Our breeders know that when sourcing puppies to
J.A.K.’s we will be bringing stores to tour their facilities. The Kerrs routinely come to and travel
with us across the Midwest to visit J.A.K.’s and our breeders. They were just here last week and
we visited 6 different facilities. Attending continuing education seminars that J.A.K.’s holds for
our breeders and helping facilitate OFA health testing clinics that we routinely hold for our
breeders is another thing the Kerrs are active in. They are very hands on in helping set and hold
the standards for our breeders. The insight the Kerrs offer not only J.A.K.’s, but our breeders
when visiting with them, helps us all be progressive. When pet stores visit with our breeders, it
helps all of us see the others point of view & to see the passion each of us have in what we
do. This makes us all strive to do better and be the best at what we do!
7. The claim that breeders serial breed with no regard to the health of their animals is also an
absurd claim, as is the claim that breeders euthanize the animal once it no longer produces. All
of J.A.K.’s breeders have rehoming resources and practices for placing their retired
adults. J.A.K.’s also works with our breeders to help facilitate rehoming their retirees if needed.
8. If a puppy is found to be unfit it is NOT automatically euthanized as the activists claim. If an
animal cannot be sold, our breeders have people they work with to adopt out those puppies, as
does J.A.K.’s All animals find homes, unless otherwise recommended by a licensed
veterinarian. The activists also lay claim that we just dispose of puppies that can’t be sold – fit or
unfit. Again, J.A.K.’s and all of our professional breeders find homes for EVERY puppy unless a
veterinarian recommends differently! There is no such thing as unwanted puppies – they all find
their homes.
9. Activists state there is a pet overpopulation problem in the U.S. There will surely be other
testimony to give you researchable data to refute this and show you that puppies purchased in
pet stores are a very small, minuscule percentage of the animals that end up in shelters. If there
is an overpopulation problem (which I do not personally believe there is or has ever been),
commercial breeders, brokers, and pet stores are not the source of that problem. If this were
true, in 11 years, I would have been contacted by at least one person that obtained one of our
puppies from a shelter or rescue. However, I have not.
I think that I have touched base on most of the myths versus facts that the activists claim about J.A.K.’s
and other brokers, professional breeders, and pet stores. If there is any of the points above I can help
add more clarity to please feel free to ask and I will do my best to provide you with any additional
information (facts) that I can.
I would like now turn your attention to my views on some of the aspects of HB 1424.
Requiring a pet store to source their animals direct from the breeder, eliminating the use of a
broker.
1. A breeder’s primary duties are to raise healthy, quality, socialized puppies, and to maintain
the health of their animals, as well as improve their facilities/practices as needed. At a
minimum brokers offer the following for breeders:
a. Markets and sells their puppies
b. Allows them to focus only on their primary duties
c. Ensures that all their paperwork is in order
d. Facilitates the safe transport of their puppies
e. Helps make sure the animals are fit for sale before getting to a pet store
f. Acts as the liaison between the breeder and pet store
g. Handles any future questions/issues regarding each of their puppies
h. Offers help and advice to maintain compliance with the AWA
i. J.A.K.’s specifically offers the following additionally: Rehoming facilitation, continuing
education seminars, OFA clinics, updating breeders on cutting edge practices,
updating breeders of current events, the list goes on
2. A pet store’s primary job is to create a safe place for each puppy and customer to find their
perfect match. At a minimum, brokers offer the following for pet stores:
a. The same as for breeders b, c, d, and f above
b. Helps stores procure healthy, propose bred pets for their stores needed to fill the
demands of its customers from professional breeders
c. Screens all breeders for compliance prior to pet store purchasing them
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d. Screens the health of each puppy for a minimum of 24 hours as set forth in the AWA
after the animal arrives at their facility prior to departing for the pet store (for J.A.K.’s
the screening period is a bare minimum of 3 days prior to shipment, but typically 5
days).
e. If an issue does arise, ensures that the health guarantee that accompanies each
animal is honored
f. Offers advice, support, and helpful hints for caring for animals (an additional resource
for pet stores)
g. Additionally J.A.K.’s specifically offers the following to our pet stores, when
applicable: pedigrees, OFA certification of the puppies parents, parent pictures,
parent weights, facility pictures and breeder profiles, routine tours of J.A.K.’s & our
breeders facilities, transparency, invitation to seminars held by J.A.K.’s and other
organizations for continued education, the list goes on
3. A brokers job is to ensure that all puppies they source from breeders arrive in a pet store
legally, safely, and healthy, ready to find their forever home. J.A.K.’s specifically strives to be
one of the best. We feel we source from some of the best professional commercial facilities
that produce some of the best purpose bred pets available and we source to some of the
most humane, ethical pet stores (the Kerrs on top of the list). This isn’t just business to our
breeders, our stores, and ourselves. It’s family. It’s team work. It’s a network of
knowledge. It’s our life.
Breeders that pet stores source from can have no more than 50 intact breeding animals.
I believe that there is ZERO scientific proof that a breeder with more than 50 animals doesn’t do
as good, or better, of a job than a breeder with fewer than 50 animals. Several of the testimonies
being submitted to you by some of the industry’s leading veterinarians and professional,
commercial breeders will attest to this belief as well. In fact, it is common that larger facilities
have full-time staffs, while many breeders with fewer than 50 animals often have full or part time
jobs elsewhere as well. Professional, commercial breeders, regardless of size, all strive to
maintain the health of their animals and offer them clean, sanitary living conditions.
All breeders, regardless of in state or out of state, must follow the Washington State regulations
for dog breeding.
I think this is going to open the State of Washington up to an enforcement headache. The
activists will make it their mission to act as an enforcement liaison for Washington, and that is an
entire different issue in itself. Not to mention the Washington regulations may directly contradict
the state of origin’s regulations.
In summary, many aspects of this bill are bad for the consumers and businesses of
Washington. Puppyland and J.A.K.’s agree that legislation should be written and passed that helps offer
more transparency and protection for their consumers, but to carefully not eliminate the consumers right
to choose where their pet comes from or harming any current or future businesses in the State of
Washington. Thank you for taking the time to read my testimony and if I can be of any further assistance
please let me know.
Jolyn Noethe, President
J.A.K.’s Puppies, Inc.
P.O. Box 245
Britt, IA 50423
PH: (641) 843-3103
Cell: (319) 239-4455
Fax: (641) 843-3107
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Email: jakspuppies@jakspuppies.com