We have had the CRA Materials reviewed and there is some misunderstanding about what the CRA materials mean. Below are some points that I hope will be helpful in clarifying the CRA materials and the nature of the response they are asking for from animal welfare groups:
· Although the message in red refers to new “regulations” governing animal charities, the CRA Materials are NOT discussing are new “regulations” (i.e., new legislation) at all. The CRA Materials are simply a “guidance document” that provides guidance to charities with respect to what the state of the law currently is already. The CRA is NOT proposing to change the law, here, but rather issued a document describing the existing law and simply asking us if it’s readable, whether the guidance document makes sense, whether there are other questions that should be answered, etc.
· At the beginning of the CRA Document, it says: “We would like to receive comments about whether these guidelines cover all relevant issues, how easy they are to understand, and any other aspects of the proposed guidelines. In addition, we welcome questions that could be used to build a list of Questions and Answers to supplement the guidelines.” (emphasis added)
In short, all the CRA is asking us to do is read these guidelines and tell them if these are helpful in understanding the law as it currently stands.
CRA is not asking animal welfare groups to comment on any proposed changes in the law, because no changes are proposed.
We may think that the law as it is described in this document is not adequate protection for animals, but commenting on this particular document is not the way to go about changing the law. That would be an entirely different discussion altogether.