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On behalf of the TICA Board of Directors, I’d like to apologize for the tardy communication with our U.S. members regarding the APHIS rule. Our Legislative Committee had asked for time to receive, evaluate and discuss the ruling with others. The document is 91 pages long and there remain many questions unanswered.
At this point, this is what we plan to do. We will update our Legislative webpage with the latest flowcharts, analyzing who is subject and who is exempt from the rule (to the extent we can interpret the rule.) We will also refer you to other information that we are aware of. I will let you know when that information is available. We have been and will stay in contact with other organizations that have a common interest with us in opposing the APHIS rule. At the moment, it is unclear that filing an injunction, as some have suggested, would produce the results we would want. It is very expensive. It is an issue under consideration. While it always seems that having someone else fight the fight is preferable, I can honestly say that an organization, like TICA, has a limited voice. TICA did respond to the proposed rule, as did AKC and CFA and others. What is the MOST effective is when YOU make your wishes known. I know it’s uncomfortable. I know it’s distasteful. BUT, it is what is responded to. So, for now, as before, please contact your congressmen. This is NOT a legislative issue, it is an administrative issue, BUT there is an impact. Bottom line is that TICA remains opposed to the new rule and the potential harm it may cause. Now is not the time to panic. However, due to the complexity of the APHIS rule and accompanying comments, it is extremely important that every breeder and rescue familiarize themselves with the rule to determine how they might be affected by it. Many individuals will find they are exempt or can become exempt from the rule by making just a few modifications to their current practices. Others may find that, given their particular situation, the rule and comments are not enough and actual legal advice regarding APHIS, as well as applicable local and state laws, may be necessary to achieve the level of comfort they desire. For the TICA Board of Directors, Vickie Fisher, President |