The English Springer Spaniel Field Trial Association
Position Statement on Senate Bill 1139/House Bill 2669 (PAWS)

The English Springer Spaniel Field Trial Association (“ESSFTA”), the parent club for the breed, strongly opposes S1139 (PAWS), legislation which is objectionable on a number of counts.

First, the ESSFTA seconds the concerns previously expressed by SAOVA and the American Brittany Club, Inc. with regard to singling out hunting breeds for exposure to licensing in two areas of the Animal Welfare Act (AWA) provisions.  The only possible reason for such attention is opposition by the bill’s sponsors to the activity of hunting itself.  This is a backdoor attack on an already thoroughly regulated and legal activity.

Secondly, the ESSFTA opposes the expansion of USDA responsibilities to an area already well covered by state and local dog and anti-cruelty laws.  The USDA should devote its current resources to protecting our nation’s food supply.  Congress has many, more urgent places to spend our tax dollars, and need look no further than Senator William Frist, M.D.’s “Manhattan Project for the 21^st Century” (http://www.realclearpolitics.com/Commentary/com-6_25_05_SWF.html) for a good example.

Thirdly, the ESSFTA opposes the concept of numerical limits as a means of identifying those who might be subject to the AWA.  Much rhetoric has been floated as regards “high volume internet sellers” and the threat of large-scale puppy importations.  It would seem that the former class must still have one or more physical locations somewhere that would be subject to existing law per point two above.  If large scale imports are indeed a concern, that would seem an appropriate subject for separate regulation.  In any case, there seems to be a shortage of factual examples to demonstrate the supposed abuses that are not already subject to the jurisdiction of appropriate local authorities.  If abuses are truly so clear cut, it is hard to believe that clearer language to eradicate such specific abuses could not be drafted than the double negatives and multiple confusions offered by S1139.

Fourth, the ESSFTA believes that S1139 poses a significant threat to the activities of many admirable rescue organizations and their volunteers.  Such organizations perform a laudable public service while imposing no burdens on taxpayers.

Simple, clear purpose and principles give rise to complex and intelligent behavior.  Complex rules and regulations give rise to simple and stupid behavior.  Dee Hock, founder of VISA International

We believe that this legislation represents the latter, and the ESSFTA encourages its members and all those who enjoy a purpose-bred dog to contact the members of the Senate Agriculture Committee and their personal representatives in Congress to oppose it.