_________________________________________________________________________

Cc (English):
Mr. Terry Davis, Secretary General of the Council of Europe
Mr. Jose' Manuel Barroso, President of the European Commission
Mr. Bernard Piotr Wojciechowski, MEP
Dr. Caroline Lucas, MEP
Mr. David Hammerstein Mintz, MEP
Mr. Robert Evans, MEP
Animal People News
Animals Voice
Eurogroup for Animal Welfare
Friends of Animals
Humane Society International
IFAW, International Headquarters
In Defence of Animals
OIPA International
PETA Europe
SHowing Animals Respect and Kindness/SHARK
WSPA, International Headquarters




Emil Kuzmanov
18 Yanko Sofiiski Voivoda str.
1164 Sofia, Bulgaria
e-mail: pet-AT-animalprograms.org
animalprograms-AT-abv.bg
+359 (0)2 8655623


To:
Mr. Boris Veltchev
Supreme Prosecutor of the Republic of Bulgaria



Subject: Illegal collection and traffic of cats and dogs in Bulgaria



Dear Supreme Prosecutor,

Concerning my letter, sent to you on 18 July 2006, and a letter from the Supreme Administrative Prosecutor’s office, addressed to me, I find it necessary to emphasize with this letter, the circumstances connected with the responsibilities of the competent officials for the illegal control over the populations of cats and dogs.

In violation of the old Veterinary Act (from 1999) and the new Veterinary Act (from 2005), the officials from the National Veterinary–Medical Service heave taken no effective measures for education of the owners, also effective control over owners, breeders and dealers of such animals. As a result of this lack of preventive activities, the pet lovers and whole the society remained ignorant and deluded, the widespread amateur breeding in Sofia remained unrestricted, and the market of these animals remained uncontrolled. The count of the bred animals constantly exceeds the capability of finding reliable/permanent owners. And thus the amount of the unwanted healthy animals is constantly recovered.

Here I point out a second case, connected with the control of the movement of the unwanted, stolen and illegally caught animals including stray cats. In Sofia there is no real legal control – most of the left and lost animals, including cats and pure bred dogs do not go to the Municipality shelter. Despite of that, some form of collection and reduction, already exists - these animals do not stay in the streets for a long time, there is no concentration of different generations in the streets and yards, the old, sick, starving and dead animals are rare in recent years. So the obvious conclusion is that the missing legal control is replaced by unofficial, criminal activities, leading to the real reduction of the growing populations by collection and traffic of huge amount of animals. These activities obviously have wide institutional and political protection. The officials from the Ministry of Interior and Ministry of Finance, competent in the fight against the organized crime and money laundering, are tolerant to the illegal collection and traffic of great number of healthy animals.

Taking in to account the previously presented information, I insist for starting of investigation of the participation of officials, politicians and enterpreneurs in this scheme since 1999.



Sofia, August 11 2006


Yours sincerely,

Emil Kuzmanov


--------------------------------------------------



The Animal Programs Foundation (Bulgaria)


To:
Mr. Georgi Pirinski,
Chairman of the National Assembly of the Republic of Bulgaria
(Bulgarian, English)

Cc (English):
Mr. Terry Davis, Secretary General of the Council of Europe
Mr. Jose' Manuel Barroso, President of the European Commission
Mr. Bernard Piotr Wojciechowski, MEP
Dr. Caroline Lucas, MEP
Mr. David Hammerstein Mintz, MEP
Mr. Robert Evans, MEP
Animal People News
Animals Voice
Eurogroup for Animal Welfare
Friends of Animals
Humane Society International
IFAW, International Headquarters
In Defence of Animals
OIPA International
PETA Europe
Showing Animals Respect and Kindness/SHARK
WSPA, International Headquarters



Subject: National policy on increasing pet populations



Dear Chairman,

I quote paragraphs of the Veterinary Law, which was actual from 1999 till 2006:
Art.5 (2) The National Veterinary-Medical Service (NVMS) supports system for operative veterinary-medical information.
Art.7 (1) (Correction from 2003) To the Ministry of the Agriculture and Forestry a Supreme Veterinary-Medical Council is created as an expert body.
(2) The Supreme Veterinary-Medical Council gives opinion on the main directions and priorities of the veterinary-medical activities.
Art.66. Animals should be bred and used in a manner, corresponding to their development and purpose, according to their physiological needs and ecological requirements.
Art.67. The owners, who possess animals permanently or temporarily, are obligated to register them, not to abandon them, to take care of their health and prevent them from pain and suffering.

Here I point out some requirements from Regulation for the Implication of the Veterinary Act (2000):
Art.110. NVMS realises control over observation of the rules for protection and humanely treatment of the animals.
Art.111. The control according to the Article 110 should be realized by veterinary-medical specialists by: 1. acomplishment of periodic inspections of the places where animals are kept and sheltered and the places where products of animal origin are obtained; ... 3. accomplishment of inspections upon signals for violations of the rules for protection and humanely treatment of the animals.
Art.122 (1) Owners of the dogs, which are 6 months of age or older, should register them in the regional veterinary-medical service (RVMS) or in the office of a licensed veterinary doctor.
Art.126 (1) Physical and juridical persons, who breed companion animals with comercial purpose or run shelters for animals, should declare their activities inthe respective RVMS. ...
(4) Every RVMS shold have a register of the objects, which contains the data from paragraph 2.
Art.127. The Body of the NVMS exersize periodic control over activities of the persons under paragraph 1 from Art.126 and if any violations of the rules for protection and humanely treatment of the companion animals are found, undertakes all the mesures provided in the law.

Here I point out some requirements from the Veterinary Act, acting from 1 May 2006:
Art.7 (1) The National Veterinary-Medical service realizes:...4. Control over adherence to the rules for protection and humane treatment of the animals.
(2) In NVMS are kept public registers of: 1. Animal breeding objects; 2. Animal dealers;...
(3) The registers mentioned in the paragraph 2 are published in the website of the Ministry of the agriculture and forest.
(4) The National Veterinary-Medical Service supports computerized system for veterinary-medical information and publishes bulletins.
Art.137 (1) The owners of animal breeding objects hand in an application to the director of the RVMS, accompanied by document for paid tax.
Art.149 (1) Animals should be bred and used in a manner, corresponding to their development and purpose, according to their physiological needs and ecological requirements.

In violation of the old Veterinary Act (from 1999) and the new Veterinary Act (from 2005), the officials from the National Veterinary–Medical Service heave taken no effective measures for education of the pet owners, also effective control over owners, breeders and dealers of such animals. As a result of this lack of preventive activities, the pet owners and whole the society remained ignorant and deluded, the widespread amateur breeding in Sofia remained unrestricted, and the market of these animals remained uncontrolled. In Sofia there is massive uncontrolled amateur breeding of unregistered cats and dogs. Almost every owner of female animal becomes an unregistered breeder. It is demonstrated in numerous ads placed allover town and media in seeking for a match, offering offspring or giving away for secondary adoption unregistered, grown ones. On the other side in the yards owned and neighbourhood cats are reproducing freely. Also the dogs living in the construction fields and business yards are reproducing freely.

The count of the bred animals constantly exceeds the capability of finding reliable/permanent owners. Despite of that, during the last seven years, the official institutions obviously have no intention to answer the main questions in this area: WHO ARE THE BREEDERS, HOW MANY ANIMALS ARE REPRODUCED EVERY YEAR, HOW MANY ANIMALS HAVE BEEN LEFT, WHAT IS THEIR DESTINY, AND ALSO STRAY ANIMAL’S DESTINY?

The peculiarity of both populations in Sofia (and Bulgaria) is their striking inconstancy. Their makeup shifts very dynamically and the animal’s average lifespan is relatively low. The already unregistered grownups on a large-scale are quietly disappearing. Meantime the amount of the unwanted healthy animals is constantly recovered.

Here a second case emerges, connected with the movement of the left, lost and born as homeless cats and dogs. In Sofia there is no real official control over these animals - despite of their prevalence, pure bred dogs rarely go the Municipality shelter and cats almost never go to the shelter. Despite of that, some form of collection and reduction, already exists - these animals do not stay in the streets for a long time, there is no concentration of different generations in the streets and yards, the old, sick, starving and dead animals are rare in recent years. In Sofia the activities of so called "nature-defenders" collecting grown up dogs with promises for their re-homing in Switzerland, has been also well known for years. The practice of theft of animals is common - dogs, lost by their owners are rarely returned. Out-going, owned cats and neighbourhoods also frequently disappear. So the obvious conclusion is that the missing legal control is replaced by unofficial, criminal activities, leading to the real reduction of the growing populations by collection and traffic of huge amount of animals. These activities obviously have wide institutional and political protection. The officials from the Ministry of Interior and Ministry of Finance, competent in the fight against the organized crime and money laundering, are tolerant to the illegal collection and traffic of great number of healthy animals.

In December 2003 and March 2004 we sent written suggestions to the Minister of Agriculture and Minister of Finance (which controls the Service of Financial Investigation) for construction of a program for restriction of the breeding and black market of such animals. Ministers refused to take any concrete steps. The later circumstance means conduction of unofficial national policy in this area.

It is well known world wide, that Bulgaria supports the dirty industry of exploitation of the great amount of growing unregistered cats and dogs. On 18 December 2005 The Sunday Telegraph announced information about the industrial production in Bulgaria of furs of skinned alive pet animals, including German Shepherds and Golden Retrievers.

Based on the presented facts and conclusions we insist for your engagement with the immediate change of the national policy in this area. We are expecting your activities for implication of parliamentary control over adherence to the Law from the competent Ministers.



Sofia, August 31 2006


Yours sincerely,

Emil Kuzmanov, founder

18 Yanko Sofiiski Voivoda str.
1164 Sofia, Bulgaria
e-mail: pet-AT-animalprograms.org
animalprograms-AT-abv.bg
+359 (0)2 8655623


_________________________________________________________________________