We respectfully petition for the removal of the sled dog kennel waiver that allows tethering as a primary method of confinement under the Pet Animal Care and Facilities Act (PACFA), 8 CCR 1202-15.
 
Background
Colorado’s PACFA regulations prohibit the use of dog houses with chains (tethering) as an enclosure, recognizing that long-term chaining poses serious risks to animal welfare, including physical injury, psychological stress, and deprivation of normal social and environmental enrichment.

However, an exemption currently exists that allows sled dog kennels to apply for a waiver permitting tethering as a primary method of confinement. This creates an unequal standard of care based solely on a dog’s use or industry classification, rather than the animal’s welfare needs.

Why This Exemption Must Be Removed
Animal welfare should not depend on a dog’s job. Dogs used in sled sports experience the same physical, emotional, and behavioral needs as all other dogs regulated under PACFA. Allowing long-term tethering for one category of dogs undermines the fundamental purpose of animal welfare regulation.

Long-term tethering is widely recognized as harmful. Modern animal welfare science—and Colorado’s own regulations—acknowledge that tethering as primary confinement increases risks of injury, aggression, stereotypic behaviors, and social deprivation.

The exemption creates unequal enforcement and accountability. PACFA was designed to establish uniform minimum standards of care. Allowing waivers for one industry erodes consistency, complicates enforcement, and weakens public trust in the regulatory system.

Sled dog care has evolved—and regulation should reflect that. Many sled dog kennels across North America and internationally already house dogs using humane, non-tethered systems such as secure runs, pens, and enriched group housing. Removing the exemption does not ban sled dog sports—it simply aligns their care standards with modern best practices.

Colorado should lead, not lag, on humane standards. As public awareness of animal welfare grows, exemptions that permit practices already prohibited elsewhere in the same regulatory framework appear outdated and indefensible.
 
What We Are Asking For
We call on the PACFA Commissioner and the State of Colorado to:

• Eliminate the sled dog kennel waiver allowing tethering as a primary method of confinement
• Apply PACFA’s anti-tethering standards equally to all dogs, regardless of use
• Ensure that sled dog kennels meet humane housing standards consistent with current animal welfare science

Our Position
This petition is not an attack on sled dog sports, mushing culture, or responsible kennel operators. It is a call for equal protection, humane standards, and regulatory consistency. Responsible operations will continue to thrive under fair and modern rules—while dogs receive the dignity and care they deserve.

Conclusion
No dog should be excluded from basic welfare protections because of an industry exception. Colorado’s PACFA regulations already recognize that tethering is not an acceptable primary housing method. It is time to close this loophole and ensure that all dogs in Colorado are protected under the same humane standards.

We urge the State of Colorado to act now.