The words "breed or raise" are an obvious and deliberate attempt to
snare many kennel and dog owners in federal regulations, including
many kennels that do not breed at all. The language is very
ambiguous and could be interpreted to include virtually anyone who
has a lot of dogs.
The term "raise" is not defined in the legislation, but is generally
interpreted to mean a person who keeps, cares for, houses or owns a
dog or dogs.
Most professional trainers and handlers of field trial, show,
obedience or performance dogs would have more than 50 dogs in their
kennels over the course of a year. In fact, many trainers and
handlers who employ helpers would have more than 50 dogs at any
given time, and most do not breed at all.
A boarding kennel, dog daycare service, hound hunt club, hunting
plantation or circus could be included under a definition that
they "raise" more than 50 dogs per year. Even many private field
trialers and show dog people would have more than 50 dogs a year in
their kennels, as they often keep most of the puppies they produce
to evaluate. For field trial dogs, for example, it often takes two
or three years of working with a young dog to determine if it is
worthy to use for competition or breeding.
A favorite tactic of HSUS is to deliberately use ambiguity in model
legislation in order to entrap as many kennels and dogs in the law
as possible, going far beyond the stated purpose. If HSUS and its
elected cronies had wanted to be honest, the legislation simply
would say that it excludes anyone who sells fewer than 50 puppies a
year.