Protest APHIS Hiring of AKC Breeder

Puppy Mill RescueThe Animal Plant Health Inspection Service or APHIS, the agency within the U.S. Department of Agriculture responsible for enforcing Animal Welfare Act regulations against dog breeders has named Julian Prager as “Citizen Program Advisor”. Prager is an English bulldog breeder who was formerly “legislative coordinator and legal analyst” as well as Board member for the National Animal Interest Alliance or NAIA, an advocacy group for the interests of breeders and animal production industries; Legislative Chair and Second Vide President for the Pennsylvania Federation of Dog Clubs, and an AKC Delegate. Prager explained his new job in a September 8, 2014 email to AKC Delegate Group and AKC Legislative Liaisons:

“I wanted to be sure that Delegates who were not at the meeting today and all club legislative liaisons received word of the announcement I made at today’s meeting. Small hobby and show breeders have all been concerned about the implications of the revision to the “Retail Pet Store Rule” by APHIS and the implication for that group. APHIS has heard your concerns. At last year’s NAIA conference the APHIS Deputy Administrator met with about 20 of us after the session to discuss our concerns and issues. He committed to work with us to work to resolve these issues. Two weeks ago, I was hired by Animal Care within APHIS as part of it central policy staff. My position, Canine Program Advisor, was advertised to bring in someone who would facilitate communication among APHIS, the breeder community, rescue groups and related animal interest groups. I will be providing APHIS staff with technical guidance on dog issues, assist in training their field staff, participate in developing program information material, conduct outreach and education and, most significantly, work on developing related policies and rules.”

The focus of Prager’s email was advising AKC breeders on obtaining exemptions from licensing and other Animal Welfare Act regulations under the Secretary’s authority to grant certain exemptions depending on the effect on interstate commerce and the animals’ welfare.

Just a year ago, new USDA/APHIS rules went into effect that promised more protection for dogs held by breeders.APHIS appears to have abandoned the training of its field staff, outreach and education, and policy making to the breeders.

Bill Smith, Mainline Animal Rescue, was quick to express the outrage felt by many. He wrote to David Sacks, APHIS spokesperson: “em>Julian Prager hired by APHIS to train their field staff? He’s going to represent the rescue community? A member of the AKC? … The AKC has a long history of fighting legislation designed to improve conditions for dogs in commercial breeding facilities. I believe Julian Prager personally opposed many of the changes we fought for in Pennsylvania. At best, on a good day. your efforts to help these dogs can be described as wretched. It is unbelievable that you would hire a representative of the AKC (an organization that continues to collect registration fees from some of the worst puppy mills in the country) to set policy within your Animal Care Division.”

Carole Raphaelle Davis, West Coast Director, Companion Animal Protection Society, wrote David Sacks: “We oppose any past or present representative of the AKC in APHIS as it is a clear conflict of interest and an egregious betrayal to animals. We have investigated the AKC’s nefarious role in the factory-farming of dogs and this memo by Mr. Prager demonstrates the complicity of APHIS in the routine mistreatment of dogs for the lucrative dog dealing business.

“It is not APHIS’ job to protect interstate commerce–that is the job of an entirely different government agency. We are deeply disappointed to see this memo and will take action. Please advise Mr. Prager of what his responsibilities ARE and send the information up the chain of command. The USDA needs to do a much better job of protecting dogs in commercial breeding facilities and everyone knows it.”

Animal Law Coalition has also written David Sacks to protest the hiring of Julian Prager for this position in APHIS: “Julian Prager’s appointment is another example of this administration’s willingness to abandon government protection and oversight to the very industry it is supposed to regulate. Was anyone from the animal welfare advocacy community named a “Canine Program Advisor”? Or just the AKC representative, Julian Prager? Mr. Prager actually still self identifies as part of the AKC as you can see from his September 8, 2014 email to the AKC. According to Mr. Prager’s email, he now appears to be running APHIS when it comes to dog breeder “regulation”. This AKC representative who opposed most if not all animal welfare regulation in the past, will inform and train your field staff? Your staff is already well versed in ignoring the well being of dogs kept 24/7 in cages and forced to breed over and over until they are dead. APHIS has always erred on the side of the dog breeder, preferring to support the industry with lip service to very minimal standards if that is even a word that can be used to describe the “guidelines” as AKC has called your regulations. Now Mr. Prager appears to plan to create more exemptions or at least train your staff to consider more breeders exempt? I don’t see anywhere in here a warning to AKC about improving the welfare of dogs. His entire focus is on helping AKC obtain exemptions from licensing and other regulation under the Secretary’s authority to grant certain exemptions depending on the effect on interstate commerce and the animals’ welfare.

“And Mr. Prager is handling outreach, education and policy making for APHIS as well? Will he offer information to the public to make them aware of the cruelty of the puppy mill industry and that, for example, 25% or more of animals produced by this miserable system end up in kill shelters? Will he promote adoption over buying dogs from puppy mills? Not likely. Mr. Prager’s appointment will mean use of government resources, the very resources that are supposed to be used to protect dogs, to market, promote and support puppy mills and their retail outlets, pet stores.

“With this appointment of Mr. Prager, you have undermined any good for the dogs that may have come from the retail pet store rules. APHIS’ record of enforcement has long been abysmal. Now as APHIS and AKC virtually become one on the matter of dog breeders, enforcement will be non-existent. This from an administration elected on the promise of ending puppy mills. Outrage is the only word to describe it.”


Call David Sacks at (301) 734-5271 or email him at and urge Mr. Sacks to protest the hiring of Julian Prager or any dog breeder for the Citizen Program Advisor position and at least add as a Citizen Program Advisor an advocate for the dogs.