Thank you for this opportunity to comment on puppy store regulations and inspections.

The draft regulations need further enhancement to provide adequate oversight of retail operations run for profit that may not put welfare of the animals at the highest priority. Inspections should address current VA code requirements for signage and consumer protections; unannounced inspections; penalties for non-compliance; loss of permits for cruelty offenses; requirement of veterinary reviews and protocols, including veterinary supervision of medication; separation areas for sick animals; adequate exercise areas and regimes; and regular reporting of the death of animals under the store's care.

Particularly concerning from the consumer aspect is the puppy stores' typical practice of withholding individual animal breeding and health information until the point of sale and often providing only fleeting exposure to such information on a store owned laptop or computer pad, until the sale is final.

The practice of puppy stores to leave young animals, even sick animals, without supervision for long periods of time when the store is closed is concerning. Inspectors should review the time young animals are left alone to determine if the shop is providing "adequate treatment" under VA Code §3.2-6500 when animals are alone for more than a few hours.

Puppy store systems/methods for providing water should be reviewed to determine if the standard of providing 24 hour water access "in a manner suitable to the species" as required by current VA code is being met. Harvard and MIT published studies [Transport in Canis familiars", Royal Society Journal Biology Letter, 2011; httsp://doi.org/10.1098/rsbl.2011.0336] which reveal the natural drinking method is not possible for puppies provided only a cage bottle, providing neither the "suitable manner" or "suffienceint volume" required under VA code.

The cage bottle method is problematic for other reasons. Nozzle heads are not reliable.  With inactivity they tend to dry and stick, stopping the siphon actin required and preventing water from flowing at all.  Staff attention generally is not sufficient to ascertain lack of water flow, which is not obvious, and may well lead to hydration problems for the animals.  Further, if water is not changed frequently, the nozzle can become slimy and bacteria develop. While puppy stores likely see an advantage in not having to freshen the water frequently as with a bowl, operational expediency comes at the expense of the animals.  Multiple puppies housed in the same cage, sharing the same water bottle, concentrate the sharing of saliva on the nozzle and increase the chances of contamination and transfer of diseases, which are frequently seen in puppy mill puppies at pet stores.  It is  not possible to inspect such a system at a particular point of time and deem the method adequate since its reliability is subject to frequent failure.  Rather VDACS should deem the method inappropriate for animals which depend on siphon action (canines) or friction touch (felines) to drink.