I am registered to lobby the Virginia General Assembly on behalf of People for the Ethical Treatment of Animals in Norfolk. I was retained during the 2015 General Assembly with the specific purpose of working on the proposed Senate Bill 1381, and from that point on was involved in all of the discussions and legislative actions.  I have a very different perspective from 2015 and 2016 than the one provided in today's publlc comment period by Senator William Stanley, one aligned with the witness Sharon Adams. 

The purpose of Senate Bill 1381 as introduced was to prohibit euthanasia by private animal shelters, and the original langauge would have accomplished that goal. Stanley said it to me, more than once. The focus was on the Norfolk operation run by my client, but they were an easy target for emotion-driven attacks due to a recent terrible mistake.  Every other private shelter was also a target of the bill and the overwhelming debate the developed around the bill would never have happened had not many other private shelters recognized themselves as targets.  You saw that in the hearing today - this is not just PETA under fire, but any open admission shelter. 

Once opposition to Stanley's bill had gelled, and its prospects in the House of Delegates started to dim, negotiations with Stanley led to a compromise.   The bill did pass overwhelmingly, but only because the compromise version was no longer a prohibition on euthanasia or other outcomes not considered "life saving."  In Virginia legislative intent is not the key issue, but the wording of the bill, and the wording of the bill as passed said private shelters must have a purpose of finding adoptive homes.  PETA has that purpose, does place animals for adoption regularly, and expressed support for the compromise legislation.  Those overwhelming votes on controversial matters only happen after compromise.  It is worth noting that the section of the code in question already talked about shelters being operated to find adoptive homes.  (In other words, as amended the new bill changed very little.)  Read the original bill and the final result for yourselves. 

There was no discussion during the 2015 session about any quota or metric being used in any regulation or enforcement tool.  That appeared out the blue in a draft guidance document within the department, and drew an immediate reaction. The intent of House Bill 340 in 2016 was very simple - kill that guidance document and force an open regulatory process, with all the stakeholders involved.  It was the use of a quota in the guidance document which sparked that reaction.  House Bill 340 was not requested by the "no-kill" movement, but was opposed by it.  

As previously noted, legislative intent carries little weight in Virginia, but to the extent it does the legislature adopted a compromise 2015 bill that did not prohibit or limit euthanasia, and then mandated a re-start on the regulatory process when a proposed quota was about to be adopted.  There is nothing in the record to support a quota system and plenty to indicate legislative skepticism.   

A key point did not receive enough emphasis at today's hearing.  There is a mandate in the proposed regulation, just not a metric.  A public shelter must actually place animals in adoptive homes, and if it places no animals it can lose its license .  That was the intent of the legislature, and my client can and will continue to comply because that is its mission. It is proud of that work, saving as many animals as it can. The problems and distortions that will result if Virginia imposes specific quotas on specific outcomes were well described by others at today's hearing. 

Thank you.