HomeMy WebLinkAboutSavonne Caughey Pet Industry Joint Advisory Council 8.17.21
1615 Duke Street, Suite 100
Alexandria, VA 22314
t: 202.452.1525 pijac.org
COMMENTS OF
PET INDUSTRY JOINT ADVISORY COUNCIL
ON RECOMMENDATIONS TO ESTABLISH RETAIL PET SALE REGULATIONS
August 17, 2021
The Pet Industry Joint Advisory Council (PIJAC) appreciates the opportunity to offer our
views and expertise on agenda item #D-194: Retail Pet Sales.
As the advocacy voice of the responsible pet care community, PIJAC represents the interests and
expertise of retailers, companion animal suppliers, manufacturers, distributors, pet owners and
others involved in the many aspects of pet care throughout the state of Washington and across
the United States. Our association works to promote animal well-being and responsible pet
ownership, foster environmental stewardship, and ensure the availability of healthy pets through
our work at the state and federal levels—including the United States Department of Agriculture,
U.S. Fish and Wildlife Service, and the Centers for Disease Control and Prevention. PIJAC
routinely advocates on legislative and regulatory proposals to advance the public interest
of protecting public health and the safety, health and availability of companion animals.
All of us in the responsible pet care community don’t just care about animals, we provide care
for them on a daily basis—and are dedicated to ensuring that appropriate care of animals is the
primary focus of any law or regulation. As such, we offer an unmatched depth and breadth of
experience on legislative efforts to verify and certify the health and well-being of pets from the
time they are born all the way until they are taken home and made a part of families.
Respectfully, PIJAC requests that you reject the staff recommendation that “For stores
selling dogs, all dogs must be obtained directly from a breeder located in Washington State
who maintains compliance with RCW 16.52.310.”
As you may know, the U.S. Department of Agriculture oversees the enforcement of the Animal
Welfare Act, including the licensing of breeders and brokers. As such, pet stores should be able
to source dogs from federally licensed breeders that are located outside of Washington State.
Unfortunately, if this recommendation is adopted, the City of Renton would be effectively
implementing a pet sale ban. Everyone agrees that bad breeders who mistreat or neglect animals
need to be put out of business. However, those who seek to stop bad breeders by
targeting responsible pet stores with retail pet sale bans are misinformed.
While well-intentioned, retail pet sale bans will not stop bad breeders who are unregulated,
unlicensed, and are not held accountable to any animal care standards. What bans will do is harm
highly-regulated pet stores, eliminating the most transparent source of pets that provides
purchasers with legal protections, and driving prospective pet owners to unregulated, unlicensed
and potentially unscrupulous pet-sellers.
PIJAC | 1615 Duke Street, Suite 100, Alexandria, VA 22314 | 202.452.1525 | pijac.org
The fact is that pet stores and the licensed breeders they work with are a highly-regulated, best-
in-class source of pets that are inspected regularly, provide veterinary exams, and keep detailed
records of the condition and care of their animals:
• The U.S. Department of Agriculture (USDA) Animal and Plant Health Inspection Service
(APHIS) established and enforces humane care standards under the federal government’s
Animal Welfare Act that regulate the transportation, purchase, sale, housing, care,
handling and treatment of animals for use as pets.
• Breeders with five or more breeding females that are not USDA-licensed are prohibited
from selling to pet stores.
• USDA-licensed breeders are routinely inspected to ensure they are complying with
humane standards for veterinary care, shelter, food, and clean water.
• Pet stores are also regulated by state laws regarding animal care and warranties and are
required to keep records related to the health, veterinary care and source of the animals
they sell.
Beyond the legal requirements, our members feel a responsibility to the animals themselves.
They work with families to find the ideal pets for their individual situations because that is the
single best way to ensure successful lifelong pet relationships, and keep pets from being
surrendered to shelters and rescues. Pet stores also have a significant incentive to adhere to the
highest standards of care and sourcing because they depend on their reputation, and positive
word of mouth to stay in business.
Pet stores are a valuable and transparent option for prospective pet owners. They provide
the peace-of-mind and the opportunity for families to personally interact with and choose a pet
that will be the best fit for their circumstances that was raised under federal and state care
standards, has a detailed medical history, and in many cases, is protected by a consumer
warranty1.
The best option for pet ownership for some families are the pure- or purpose-bred
puppies offered by pet stores. They may need a specific breed due to health considerations – 30
percent of Americans suffer from pet allergies2. Or, with young children, they may not be able to
take on the behavior risks of bringing a dog with an unknown history into their home – 47
percent of rehomed dogs are relinquished because of pet problems, including aggressive
behaviors3. If a future pet owner needs or wants a specific breed due to such common
circumstances, their options will be severely limited without pet stores.
A pet sale ban will also boost the unregulated black market for pets. Without pet stores to
personally interact with and select their new pet, families may turn to online sources, where they
could fall victim to the “puppy scams” that have surged in recent years—tricked into sending
unrecoverable money for a nonexistent dog. While there are reputable and responsible online
sellers, the Better Business Bureau has stated that fake online puppy sellers and puppy scams
have dramatically increased by 39 percent since 20174, and up to 80 percent of sponsored online
1 American Veterinary Medical Association. https://www.avma.org/advocacy/state-local-issues/resource-guidance-pet-purchase-protection-laws
2 Asthma and Allergy Foundation of America. https://www.aafa.org/pet-dog-cat-allergies/
3 ASPCA, National Rehoming Survey (2015). https://www.aspca.org/helping-people-pets/shelter-intake-and-surrender/pet-statistics 4 BBB Alert: Beware of Puppy Scams This Holiday Season – Findings by BBB Reveal a Surge in Complaints and Scam Reports. (n.d.).
https://www.bbb.org/article/scams/18964-scam-alert-beware-of-puppy-scams-this-holiday-season
PIJAC | 1615 Duke Street, Suite 100, Alexandria, VA 22314 | 202.452.1525 | pijac.org
ads for puppies may be fake5. Victims of these puppy scams often have no legal recourse because
they purchased from a source without regulatory oversight and without a purchase warranty to
protect them.
With a pet sale ban, future pet owners could also fall victim to bad breeders who don’t adhere to
care standards and sell puppies with diseases or genetic defects. Without the legal recourse of a
warranty, such as those offered by many pet stores and required in many states, families are left
with huge veterinary bills. In California, for example, veterinarians saw an increase in consumers
purchasing sick dogs from unregulated sources shortly after the state implemented a ban on the
sale of dogs, cats and rabbits at pet stores in 20196.
We respectfully urge the City Planning Commission to reject efforts to pass a pet sale ban
in Renton. This proposal would not impact bad actors, but it will punish law-abiding pet stores,
often small, local businesses that depend on establishing life-long relationships with pet owners
to sustain their businesses because they can’t compete with the volume pricing that online or big-
box retailers are able to offer. These local businesses are committed to the health, safety, and
wellbeing of the animals they provide to Washington families.
Rather than penalizing law-abiding and responsible pet store owners, the way to put bad breeders
out of business is to evaluate, improve, and increase enforcement of federal and state animal care
laws, including setting and enforcing strong and uniform standards of care and applying them to
pet sources including stores, licensed breeders, shelters and rescues.
PIJAC also recommends that the state of Washington enact consumer protections in the form of
pet warranty laws. According to the American Veterinary Medical Association, 21 states in the
country provide legal recourse to people who purchase animals from pet stores which are later
found to have an illness or medical condition. These protections often include replacement of the
animal, a refund of the purchase price, and/or reimbursement of veterinary expenses, generally
up to the purchase price of the animal. In this way, pet stores are further incentivized to work
with quality breeders to ensure that the dogs they offer are healthy and well-bred.
We appreciate your consideration and would welcome the opportunity to work with the City of
Renton to find ways to meaningfully address bad breeders. By working together, we can make
sure that citizens in the Evergreen State continue to have access to healthy animals to love as
pets now and in the future.
Sincerely,
Savonne Caughey
Senior Director of Government Affairs
Pet Industry Joint Advisory Council
5 Puppy Scams: How to Protect Yourself from Fake Online Pet Sellers. (2017, November). https://www.bbb.org/article/scams/14213-puppy-
scams-how-to-protect-yourself-from-fake-online-pet-sellers 6 ABC 10 San Diego https://www.10news.com/news/team-10/puppy-dies-four-hours-after-sd-family-buys-it-vets-say-new-law-may-be-part-of-
the-problem