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Attn: Members of the European Parliament



Dear Sir/Madam,

I would like to bring to your attention the following urgent matter of importance for Bulgaria's European integration.

Bulgaria, the most corrupt European Union member country, is remarkable with its ongoing humanity's top problem. It is the very high mortality rate within the population of approximately 2,000,000 owned dogs and cats ever predicted by the common pet overbreeding. Local and national decision makers and a common set of close NGOs constantly demonstrate a peculiar amalgam of inability and unwilling to define any comprehensible task and to propose adequate strategy to deal with pet overpopulation. All proclaimed initiatives actually are not affecting the sustainable trend towards large-scale dog catching followed by a believed mass animal abuse. Regardless of allowing thousands of individuals outside for some period under the people's care and feeding, most of the strays become ultimately a subject of routine impounding and disposition by the animal control services with no record and report on ones involved; moreover, lost dogs too. The official claims to justify dog catching in any municipality is "carrying out neuter-release program in accordance to the law".

Recently Bulgarian authorities and inner NGOs agreed on unacceptably low standards for animal shelter openings under the Government's Ordinance № 41/2008 on pet animals handling facilities requirements. It was done in just two days - April 24-25, 2012 - by a very restricted working group created by Prime Minister Bojko Borisov. The changed requirements were swiftly promulgated April 27, 2012.

Since January 25, 2011, Article 47, paragraph 4 of the Animal Protection Act allows opening "temporary animal shelters outside places". The new Paragraphs 128 F, 128 G, 128 H, and 128 I of the Ordinance 41 treat of a new concept - "temporary sites" - that may also refer to it or may not. Temporary sites shall cover very few requirements including "enclosing with a fence" and having "cooking nook", "medical commode", "awning to protect animals from adverse climate conditions", and "pallet container for carcasses". Unlike the rest two types of animal shelters treated of, namely these having solid buildings or individual kennels (named "open-air type"), temporary sites are not required expressly to provide public access, returning an animal to the owner, adoption, feeding, cleaning, medical care, appropriate separation of probably hundreds of animals by numbers and/or types; even to have a standard floor.

Sofia Mayor Jordanka Fandykova has emerged as a key proponent of the looming large-scale animal shelter openings model. He made a next brief step on May 10 by gaining City Council approval for its 2012-2016 stray dog control program. The major features of the program are: increasing the number of dog catchers teams to "not less than 10"; constructing new dog pounds; and giving out land plots to "the animal protection organizations matching municipality's goals" in order to build their own animal shelters. During her past partial term in office between 2007 and 2011, Fandykova just did nothing to curb local dog population dynamics. In recent months, he reiterated repeatedly her intentions to "reduce street dog population mainly through opening extra animal shelters, and registering owned dogs". At the present, there are four dog pounds working officially (gross capacity 1000 dogs), and six dog catcher teams.

A document entitled "A Strategic Report on Animal Shelter Operations in Bulgaria" issued by the Bulgarian Animal Programs Foundation (BAPF) and sent to Prime Minister Bojko Borisov revealed a bleak business in Sofia - at least 43,000 unwanted, abandoned and lost dogs really have been caught by the Sofia municipal enterprise "Ecoravnovesie" from September 2006 to December 2010, while impounded animals reported by the officials were two times less.

On the other hand, an inexplicably high numbers of strays are claimed by officials or contractors as neutered and released outside. Media statements indicate a total of 19,000 dogs released in Sofia (1.3 M) from September 2006 to December 2011; 14,020 releases in Varna (330,000) (2000-2010); 5200 in Dobrich (95,000) (2002-2010); 4000 in Shumen (99,000) (2003-2010). But claimed numbers are not seen. According to the law, all released animals must be identifiable and traceable through enrollment in a municipal register. In fact, the last homeless dogs in Sofia wearing collars with ID tags number were seen ca. 2008 (case reports:  http://www.indymediascotland.org/node/3971 ;  http://sofiaecho.com/2008/04/18/659938_to-the-editor-sofia-fails-against-theft-and-poaching-of-roaming-animals). So no logic or evidence indicating mass release as the stated by officials. The logic and evidence dictate that most of the man's best friends are routinely sold out to private entrepreneurs, rather than neutered and released outdoors to perish in just a few months.

The BAPF's report pointed out the opportunity to dispose of unknown numbers of roaming animals as the crucial factor in failing to solve dog overpopulation problem across Bulgaria. On this ground, the government was proposed a special legislation on animal shelter accountability. Best available examples with a compulsory shelter reporting from Northern Ireland, Michigan, and Virginia were provided (although there were included dozens of examples with voluntary reporting). But there was no response from PM's team.

Behind the most recent agreement on enhancing dog pound capacity implicitly, it can be seen the next monstrous malice in favor of the ongoing for-profit trend. The amassing strays ("dog farming") is likely set to be removed from public places to remote fenced facilities. Indeed, the intentions to develop unaccountable animal sheltering industry to new stage, and improving the general welfare of pet populations are not the same.

During the last decade, I am confronting the simple dog removal policy forced intentionally instead of a comprehensive pet population management, but so far I remain the sole person on the front line here in Bulgaria. Furthermore, facile NGOs really represent the stray animal control services (often funded by municipalities and/or using municipal property) rather than some kind of independent animal welfare advocacy movement. So both institutionalized animal abuse and necessity to prioritize the pet population dynamics issue remain underrated by the general public opinion. That is why I invoke representatives of intergovernmental bodies such as European Parliament and European Commission to speak out against worse policies in this area of concern promoted by Bulgarian government.

EU officials should ask Prime Minister Bojko Borisov personally on what actually happened to tens of thousands dogs impounded every year by Bulgarian-style animal control. PM shall be also asked to explain the total incompliancy with the animal welfare status sought by the EU's Lisbon Treaty. He must be convinced to suspend crooked Ordinance 41.

And last but not least, European bodies shall also urge Bulgarian Prime Minister to undertake in creating a multi-stakeholder committee including international expertise (e.g. ICAM Coalition) to draft a special Dog and Cat Management Act based on world's best experience. This new legislation must provide the following:

- Enforcing standards in publicly available animal shelter reporting on intake and disposition of animals;

- Appointing animal control officers ("dog wardens") charged with duties to enforce responsible dog ownership, particularly in cases of latch-key dogs that are commonly allowed to roam and give birth;

- Establishing easily accessible low-cost neutering services for both owned cats and dogs funded by government/municipalities;

- Taking appropriate measures to reduce deliberate/commercial pet breeding and supply.



You can write to the PM at the following address:

1, Dondoukov Blvd.
1000 Sofia, Bulgaria

Email the Prime Minister’s Office at  primeminister@government.bg

You can fax the Prime Minister on +359(0)29802056



For the animals,

Emil



Emil D. Kuzmanov
Bulgarian Animal Programs Foundation (BAPF)
18 Janko Sofijski Vojvoda Str.
1164 Sofia, Bulgaria
 http://animalprograms.org
 pet@animalprograms.org,  animalprograms@abv.bg

BAPF is Bulgaria's first and sole entity to promote comprehensive companion animal management. Its efforts are focused on two key factors - both authority's responsibility to deal humanely and effectively with pet overpopulation, and people's beliefs on pet breeding, supply and demand.
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