Warning letter to Agriculture Minister, 12 April 2013
To the attention of:
Prof. Ivan Stankov
Minister of Agriculture and Food
55, Hristo Botev Blvd.
In recent days, media announced your intentions to intervene in the country's animal control. News releases mentioned a revision of the Government's Ordinance No 41/2008 on pet animals handling facilities requirements that has been already undertaken after relevant requests is being made by Sofia Mayor Jordanka Fandykova; and agreement with a Dutch company on construction of two animal shelters - in Stara Zagora and Sofia - as construction in Stara Zagora is already started.
This letter notifies you of the misleading claims about the pet population management performed nationwide and particularly in the capital city of Sofia.
The uninspected animal shelter operations include unreported disposition of impounded animals that is of tremendous concern from an animal welfare perspective. In general, animal shelter system is suspectedly involved in schemes of pet theft, pound seizure, and pet trafficking. Cases of reuniting lost dogs were never reported in Sofia, while in Calgary, Canada, such presents about 80 per cent of the total animal shelter exit (see http://en.animalprograms.org/uploads/8/3/8/8/8388532/a_strategic_report_on_animal_shelter_operations_in_bulgaria.pdf). The "catch-neuter-release" trial performed by Sofia Municipality resulted in a total of 31,370 roaming dogs reported as caught between September 2006 and December 2012. It is unclear what actually happen to most of the impounded animals. In fact, the term "catch-neuter-release" is used as an obvious euphemism when there is no evidence of enough identifiable individual animals that present a properly managed roaming dog population living outside.
I would like to ask you about your personal understanding of role of animal shelter system. It should be noted that animal shelter system is intended primarily to hold roaming animals removed from public spaces, lost included; and not to deal with pet population dynamics, i.e. to perform a major approach to animal birth control in a cost effective manner. Sofia currently has four operating animal control facilities whose total capacity is about 1900 dogs. Dog removal industry Bulgarian style remain the major approach preferred by corrupt officials, while animal birth control measures are performed sporadically. So, the more roaming animals, the more holding facilities and public funding. For instance, the total spending on Sofia animal control projects and programmes for the period 2007-2013 exceeded 12 million leva, but new generations of unwanted dogs continue to repopulate streets.
The above is not intended to be an all-inclusive list of violations. I would suggest you to oppose the overall fraudulent animal control model boosted by corrupt authority, instead of satisfying Mayor Fandykova's ungrounded claims. High pet-population-dynamics rates kept in Bulgaria require providing the right measures - from establishing easily and widely accessible neutering services, and appointing animal control officers (i.e. educational and law-enforcement bodies), to collecting standard annual reports on animal shelters intake and disposition. Amendments to Ordinance 41 shall include provisions for mandatory reporting of animal shelter operations that were already proposed to the previous government (see http://en.animalprograms.org/uploads/8/3/8/8/8388532/a_strategic_report_on_animal_shelter_operations_in_bulgaria.pdf).
As a senior person who got engaged in pet population management, you are responsible for ensuring that your overall actions and the animal control you must inspect are in compliance with the law, national obligations under European Convention for the Protection of Pet Animals, and best practices. You should take prompt action to correct the violations described in this letter and to establish procedures to ensure that these violations do not recur. Please notify me of the steps you would take to bring your ministry into compliance with the law, national obligations under European Convention for the Protection of Pet Animals, and best practices.
Also, I would like to inform you that I expect to be invited to join the working group designed to amend the Ordinance as a stakeholder representing animal welfare advocacy. I am sure you would agree that animal welfare advocacy and animal control services are not the same, indeed. Year ago, a dozen of striking amendments of this ordinance were made swiftly with the compliance of the representatives of Vier Pfoten Bulgaria and Animal Rescue Sofia. These are non government organizations involved in joint animal control operations in Sofia. In the late 2012, the crooked ordinance was ultimately suspended by the Supreme Administrative Court because of threatened animal welfare standards.
I tried to contact your office on Monday, 8 April 2013, by calling all publicly available phone numbers of the Public Relations and Protocol Directorate. The unsuccessful attempts continued from 10:10 AM to 10:45 AM with no person on the other end. So, I am expecting your urgent response via foundation email address above.
Emil D. Kuzmanov
Bulgarian Animal Programs Foundation
Cc: Marin Rajkov
Cc: Sotir Tsatsarov
Cc: Sonia Alfano