Letter to Agriculture Minister
The Animal Programs Foundation of Bulgaria
18 Yanko Sofiiski Voivoda Str, 1164 Sofia; E-mail: email@example.com
Mr Nihat Kabil
Minister of Agriculture and Food Supply
55 Hristo Botev Blvd
Sofia, February 11, 2008
Conflicts of interests in the adopted Animal Protection Act
On January 24, 2008 the National Assembly was adopted the Animal Protection Act at it's final
stage. About the dog and cat populations that law is not different actually from the original drafts, also by their joint version. The false thesis - that the overpopulation of unwanted animals presents a posterity of unowned animals, i. e. a separate population, which is dependent on separate control - is still leading.
The faults of the Act can be aspected in the next items:
1. It was not assured a serious restricting massive reproduction of the owned dogs and cats. This is the basic problem of the both populations, because it is leading at massive abandonment and roam of animals.
2. There is not guaranteed right of a public access to the Animal Register (Registers).
3. There are not provided clear rules of catching and transporting dogs and cats.
4. The Act predicts inhumane treating of the annual sum of unwanted animals.
5. There is not statuted obligations of the National Government for taking control over the field activities, i. e. catching, transporting, collecting and release of dogs and cats outside.
Generally, so painfull legislation will not reduce the population overreproductivity, the animal roam and uncontrolled collecting, the traffic and abusive treatment of dogs and cats. It will not be possible counting of actual information, nor right analyzing the real situation in order to improving it. The interest of the community and of the animals will stay disregarded. Will be guaranteed only the untransparency and private interest. Using the stated order of above noted faults, I am writing below the exact articles, which must be revized and ammended.
1. Art. 4. must be revized in accordance with Art. 14 by the European Council's Convention for the Protection of Pet Animals. Must be enacted launching Information-Educational Programmes in order to discourage the irresponsible acquisition and breeding of pet animals. The present text says "nurture of love and humane treatment of animals".
In Art. 36. must be provided a text in accordance of Art. 12. of the European Convention. That obligues government to organize and promote sterilization of dogs and cats in order to reduce the unplanned pet breeding.
2. In Art. 38. must be enacted right for the public access to the Animal Register.
3. In Art. 42. must be statuted a clear order for organized loading and transportation of roaming dogs and cats; a personal right for doing that activity; an acceptable hour time for acting it; and responsibility of the Mayors for sheltering new arrived dogs in time.
4. Art. 47. must be re-made. Must be postulated a humane decision for the faith of the constantly appearing abandoned animals, which are being stay unwanted. That text enacts funding a massive sterilization of unwanted animals; and collecting them in life-long shelters "out of the places" or releasing them backward. In the first case forthcoming massive shelter intake will cause suffering and distress for the animals. In the second case, as at the present, population pressure will lead to an unavoidable massive animal abuse.
Art. 51. must be re-made by the above mentioned circumstances. That order suspends euthanasia of unwanted animals.
5. Art. 59. must contain texts, which are determining obligations of National Veterinary Service and Ministry of Interior about control over the dog and cat catching, transporting and collecting; also obligations of NVS about control over the release of animals.
Insistently I am begging for your proposal to the Parliament about these conflict texts. I am waiting for the considering anew and ammending Animal Protection Act.
Emil Kuzmanov, founder
C. c.: Dr Bernard Vallat
C. c.: Dr Marc Danzon
Enclosure: copy of the Humane Dog Population Management Guidance (International Companion Animal Management Coalition, November 2007).