Oregon’s Animals & Animal Rescues Are Under Imminent Threat. That’s Why We Need Your Help Today
Last Thursday, February 15, 2024, Northwest Animal Companions and the roughly 225 other animal rescue entities in Oregon received devastating news. The Oregon Department of Agriculture (ODA) has proposed sweeping amendments to Oregon Administrative Rules (OAR) 603-015-0080 and 603-015-0085, rules that apply to animal rescues like ours. You can read about those changes here.
Please contact the ODA immediately and tell them why you oppose these changes to OAR 603-015-0080 and 603-015-0085, which will result in immediate and widespread loss of animal life, and closure of beloved animal rescue organizations. We hope that, with enough support from animal lovers like you, we can prevail upon the ODA to dismiss the changes and keep the laws intact.
Click here now to contact them by email; it will take less than a minute. If you have more time to help, we’d love it if you wrote them a custom message.
To learn in detail why the Northwest Animal Companions Board of Directors — and many of our fellow animal rescue and shelter colleagues — oppose these changes, please continue reading our letter to Dr. Ryan Scholz, State Veterinarian at the ODA, which we emailed to his attention today. Sadly, we have just days — until Thursday, February 29, the deadline for public comments — to make our voices heard. Thank you for helping animals!
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Tuesday, February 20, 2024
Dear Dr. Scholz,
The Oregon Department of Agriculture (ODA) has filed a notice of proposed rulemaking affecting Oregon Administrative Rules (OAR) 603-015-0080 and 603-015-0085, laws applicable to animal rescue entities in our state. Northwest Animal Companions is proud to be an ODA-licensed animal rescue entity and 501(c)(3) nonprofit based in Portland, OR. As a foster-based animal rescue, NWAC rescues hundreds of cats and dogs each year, fostering them in our volunteers’ loving homes. These cats and dogs have helped complete thousands of families across our state and beyond.
The goal of the proposed rules, as stated in the filing, is twofold: to raise revenue for the department and protect animals. The impact of the change is that neither of these things will happen; in fact, the proposed rules will have the opposite effect. We have no doubt of the pure intent of the advisory committee to enhance animal well-being, and share their values. We want nothing more than to assure safety and health for every animal — which is why we are so devastated by these amendments and their consequences to animals, and vehemently oppose their adoption.
Here are five reasons why we, the Northwest Animal Companions Board of Directors, oppose the amendments to OAR 603-015-0080 and OAR 603-015-0085:
They make private, volunteer foster homes subject to government inspection. Animal rescues fulfill a vital role in the Oregon animal welfare community. The filing’s revised definition of “foster facility” would have catastrophic effects on foster-based rescues like ours. It would not only force us to reveal our foster volunteers’ private data — their names, addresses, and so forth — to the ODA, it would leave our roughly 100 foster homes open to government inspection and held to shelter facility standards. Private homes are not designed with animal shelter standards — for dog runs, ventilation, lighting, and so forth — in mind. Our foster homes are vetted for safety and comfort by our leadership team, and we stand behind those homes. It’s also inappropriate for foster homes to be held to industrial standards.
What will be the real-world impact of this rule? Foster volunteers will leave Oregon’s 225 animal rescue entities in droves because they won’t want to be subjected to home inspections and held accountable if their homes cause rescues to lose their licenses.
Who will help all these animals? NWAC intakes more than 500 animals a year and we are just one of 225 rescues in the state. If the animals are released outside, who will deal with the subsequent threat to public safety? If animals are brought into shelters and there is no space, what then? Oregonians will have to be prepared for the black body bags to pile up again outside animal shelters.
Legislation often moves slowly and creates long-term ripple effects, yet the changes to OAR 603-015-0080 will result in animals losing their lives immediately. The loss of animal life alone is reason enough to rethink the proposed rule.
They radically increase licensing fees to animal rescues, forcing small nonprofits who run on donations and adoption fees to fund the ODA. These increases will put smaller rescues out of business. One of the ODA’s goals in this amendment is to increase revenue to its department. Animal rescues are often volunteer-run and operate on razor-thin budgets so they can channel their money toward what is most important: medical care, spaying/neutering, grooming, nutrition, and enrichment for animals in need. The licensing fee increases proposed by the amendment will close small rescues, which means they can’t contribute to the ODA’s bottom line or save animals, a double blow.
Under the proposed rules, NWAC’s license fees will increase 546 percent, forcing us to divert funds we would otherwise use to save dozens of animals away from rescue and toward the ODA. Confusingly, the largest animal shelters in Oregon will pay only $100 more each year than us, an all-volunteer nonprofit rescue, for their annual licenses. These proposed fees are not only extraordinary, they are inequitable.
Ultimately, the financial consequences to animal rescues, big or small, will be paid by the animals who lose their lives as a result.
They financially penalize rescues who help desperate county and municipal animal shelters. The change to OAR 603-015-0085 creates a tiered license fee structure for rescues that increases with the number of animal transfers they accept. County and municipal animal shelters are already being crushed under the pressure of animals whose humans have somehow failed them; foster-based animal rescues are the relief valve for those shelters, accepting the pets that shelters cannot or will not admit. Weekly, we receive notices that the shelters are full and they need rescues like ours to help intake. Additionally, many animals fail in kennel/shelter environments. Shelters need rescues like ours to intake animals who are too stressed in the shelter environment or need focused training that understaffed facilities cannot provide.
Where will the animals who don’t fit in the shelter system go? When there are no foster homes and the shelters are full, the animals will be left on the streets. And why is a financial penalty being levied on the rescues who are generous enough to relieve their local shelters?
In 2022, Washington County Animal Shelter (aka Bonnie L. Hays Animal Shelter) in Hillsboro, Oregon, transferred 76 percent of the animals in their care to animal rescues and euthanized 20 percent. They continue to rely on transfers. Agencies such as Multnomah County Animal Services and Marion County Dog Services also rely heavily on transfers to rescues. Without animal rescues like NWAC stepping up to accept transfers, who helps the animals at these shelters? And the other shelters statewide? There is no plan. Animals, again, pay the price.
They rely on vague definitions of how animals are counted, leaving compliance open to interpretation. The new rule says that foster facilities must contain fewer than 10 animals, but doesn’t make it clear whether a foster home’s resident pets would be counted in that number. Additionally, the rule counts a nursing mother and her unweaned offspring as one animal “unit,” while weaned offspring “constitute additional animal units.” The last time an animal nurses is often only clear in hindsight, when days or weeks have passed without the baby seeking milk from its mother. Who defines the precise moment when those babies are weaned, and a mother cat with six kittens turns into seven animal units versus just one? The ODA’s rule is unclear. This leaves interpretation open to individual inspectors, leading to inconsistent, unequal enforcement, as well as confusion in animal rescue organizations who are trying to abide by the rules. Animals will pay the price.
The proposed rulemaking’s fiscal and economic impact statement as well as its cost of compliance statement are inaccurate. ODA procedure rules mandate that these filings contain a statement of the fiscal and economic impact. This filing is required to “identify state agencies [and] members of the public likely to be economically affected by the rules.” Filings are also required to “estimate the number and type of small businesses subject to the rules [and] the cost of professional services, equipment supplies, labor and increased administration required to comply with the rule(s).” This filing does no such thing. It does not mention the 225 licensed small-business nonprofits affected, nor the massive costs we would undertake in order to bring our foster homes up to animal shelter standards. It does not mention the costs that the ODA would incur to pay inspectors to visit foster homes.
The proposed rulemaking merely mentions the increased costs to licensing based on an inequitable tiered system, which are a drop in the bucket compared to the real-world financial consequences of this proposal. The burden is being put on small rescues, not shelters or large nonprofits with multimillion-dollar budgets. Helping animals should continue to be the responsibility of all Oregonians, funded by the legislative budget as it has been. The solution is not to put additional burden on rescues trying to close the gaps state-funded organizations cannot fill.
Additionally, there is no public disclosure available on the makeup of the advisory committee that proposed these rule changes, so we’re left to wonder whether any proper representation for foster-based rescues was included.
Dr. Scholz, Oregon has long afforded sanctuary to animals in transition. If the ODA moves forward to change the rules as proposed, that sanctuary will be destroyed. Unfathomable numbers of animals will suffer, be euthanized, or die neglected. Please save Oregon’s animals and animal rescues by dismissing this filing and maintaining OAR 603-015-0080 and OAR 603-015-0085 as they are.
Sincerely,
The Northwest Animal Companions Board of Directors