Virginia Department of Game and Inland Fisheries Attn. Policy Analyst and Regulatory Coordinator 4016 West Broad Street Richmond, Virginia 23230 To whom it concerns, The Virginia Department of Game and Inland Fisheries (VDGIF) is proposing to amend state regulations on penning. However, the proposed regulations would not ban the practice outright, but merely establish standards that will allow much of the cruelty to continue unabated—and can even be waived at the discretion of the VDGIF director, should they be deemed too 'onerous' for a penning facility operator. Please ban penning outright, or--at minimum--put forth regulations that do not allow these minimal requirements to be waived for any operators. Coyote and fox penning is barbaric and inhumane and parallels dog fighting. At least 3,600 fox have died in pens across Virginia in the last three years alone. In many cases, the wild canids are mauled to death by the dogs. Penning facilities transmit diseases between wild canids and domestic animals, including rabies and parasites. Wild animals sold into these facilities are often transported from out of state without regulation or inspection. Virginia lacks the resources to enforce the proposed regulations. There are too few conservation police officers to properly oversee that penning facilities follow the regulations. By allowing for penning operators to waive out of minimal requirements, such as providing food and water to the foxes who live in these pens, the proposed regulation (4VAC15-290-160) effectively leaves penning operations unregulated. Sincerely, NAME STATE COUNTRY
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