Referring to recent amendments to the PCA Act: "...the amendments don't attempt to introduce any new standards for animal care. All they're intended to do is help the SPCA enforce standards that exist already -- if they exist at all. Because often, as in the case of, say, puppy mills they don't."

Why would the SPCA refuse all these years to write standards for puppy breeders? Standards aren't law it's true, but they can strengthen and complement laws, and if a court sees that the standards were distributed to all breeders and were readily available and so breeders had no excuse to claim they didn't know what "neglect" was, standards would help the courts to convict.

But standards can have other effects. Before November 2003, when the SPCA hired Craig Daniell and started to use puppymill seizures as a way of raising money, the vagueness of the PCA Act was used to explain why the SPCA "couldn't" seize animals. "The Act is inadequate" was the constant refrain when the SPCA was asked why it was letting animals starve to death, as the Surrey SPCA did in 1992 with horses in a nearby field.

After the hiring of Daniell, the Act's vagueness was used to permit the SPCA to seize almost any damned animal it pleased. The trick was to get judges to believe that the SPCA had no reason to say animals were being neglected so badly that they had to be seized if it weren't true. Judges did believe the SPCA.

Written standards would, in the first instance, have made it hard for the SPCA to go on avoiding enforcement. Written standards in the second place would have made it too cut and dried in court as to what exactly is and is not neglect. The SPCA has used the vagueness of the PCA Act very successfully, to make donation-generating seizures of healthy animals, many of which it sickened and killed, thereby being more guilty of cruelty than are the people they seized the animals from.

With apologies to the animal world: will the SPCA kill the goose that is laying the golden eggs? Will the SPCA kill the cash cow it is milking? Will it write breeders' standards so that everyone can go about their business without fear of the arrival of a gang of SPCA employees, armed police, vets and the media, and watch helplessly as their animals are carted off to secret locations never to be seen again - or come home and find their animals all taken while they were away?