Pet Food

 An Open Letter to the Prime Minister of Bulgaria

Concerning: Mass illegal traffic of companion animals

Dear Sir,

The illegal collection, traffic and trade of great amount of dogs and cats in Bulgaria had been concerning not only the area of animal control. These activities had turned into an organized criminal industry, protected by the official Bulgarian institutions.

The false stability of the both populations and the limitation of their quantity are due to the unobstructed traffic of animals. The unlimited home breeding produces hundreds of thousands of healthy pet animals every year. The grownups have been constantly collected by deceit, theft and illegal catching. There is neither excessive increase of the number of owned animals nor serious sheltering; there is no piling of old, fasting, ill animals of different generations in the streets and yards nor many events of dying of such animals outside.

Despite of all these facts, there is obvious lack of will from the ministers from the Bulgarian government and competent directors of the national services for any activities against the illegal traffic of companion animals. Meanwhile there is no statistic data for the breeding, trade, abandoning and stealing of pet animals in Bulgaria. The official institutions totally avoid to discuss this peculiar situation.

The interests of the mafia are supported by the lack of an official national policy in this area. The harmful amateur breeding is still encouraged. The pet lovers and the society as a whole are not informed and mislead about the real purpose of most of the steady bred animals - they are turned into victims of uncontrolled animal testing and source of cheap raw-material.

I turn to you with an urgent request to review the inadequate policy of the Bulgarian Government concerning the criminal traffic of companion animals and to initiate rapid activities for it’s effective restriction.

I also insist that the Bulgarian Government must implement all the measures for legal pet control included in Veterinary Act, European Commission's Regulation No 998/2003 and European Council's Convention for the Protection of Pet Animals.

I would like to thank you in advance and I’ m waiting forward to your fast answer.

Emil Kuzmanov

The Animal Programs Foundation of Bulgaria



An Open Letter to Boyko Borissov, Mayor of Sofia EU

Concerning: Mass farming of stray animals

Dear Sir,

After the 1989, a huge number of unregistered dogs of unknown origin (fertile and sterilized) started to appear constantly in the streets of Sofia. Most of them lived outside for some time, receiving food and water from the people. Some of them disappeared without a trace; other fallen for a short period of time in the Municipal Shelter, where very often they disappeared too. In their place new dogs appeared in the streets and their destiny was the same. More over - most of the owners of lost dogs did not find their pets in the Municipal Shelter.

Since your election for a Mayor of Sofia in 2005, your intentions for saving the life of the stray/neighbourhood dogs are loudly proclaimed. Unfortunately, you haven't taken any effective measures for the restriction of this process. Even you avoid to discuss the World's accepted basic no-kill/low-kill solutions i.e. registration, increasing sterilized ratio of dog population, re-homing, licensing breeders and dealers.

The stray problem is similar to that under the rule of your predecessor Mr Stefan Sofianski (1995-2005). There are no transparency and strict accounting: there are no inspections of the doubtful non-government organizations working with strays; there is no established a register of the neighbourhoods; there is no surveying data about available, appearing and disappearing animals in the districts. The appearance and disappearance of unwanted dogs continued; the disappearance of the lost pets also continued.

Obviously the inadequate policy of the Municipality of Sofia in the area of animal control served to the interest of the criminal industry, using pet animals - they are turned into victims of uncontrolled animal testing and source of cheap raw-material. Sofia was turned into a farm for stray animals.

Because of the listed above reasons, a review and change in the current policy of the Municipality of Sofia in animal control is needed. You must make an urgent effort to restrict the illegal farming of unwanted animals and kidnapping of owned animals.

I would like to thank you in advance and I’ m waiting forward to your fast answer.

Emil Kuzmanov

The Animal Programs Foundation of Bulgaria




Animal Programs Foundation


Mr Nihat Kabil
Minister of Agriculture

Mr Boyko Borissov
Mayor of Sofia

Cc.: Mr Terry Davis
Cc.: Mr Jose Manuel Barroso
Cc.: Mr Neil Parish MEP

Sofia, January 29 2007

Honorable Gentlemen,

A process of mass breeding, offering, roam and disappearance of cats and dogs has been taking place for many years in Bulgaria and particularly in Sofia. Both populations in Sofia remain extremely unstable. The animals became victims of the ignorant amateur interest on one side and of organized criminal traffic on the other.

Till this moment, no effective measures for overcoming of this crisis have been taken. The Veterinary Act and the European Council's Convention for the Protection of Pet Animals has been totally neglected. The mass breeding remains unrestricted; the amount of the bred animals exeeds the possibility for reliable ownership; that constantly creates an overpopulation of unwanted animals. The movement of the animals is also uncontrolled; the reduction of the population number is due to the dissapearance of a great amount of healthy unregistered animals.

Without any delay, a restriction of the breeding and movement of the pet animals must be enforced in Sofia and whole of the country. I turn to you with a request for a personal engagement in the organization, promotion and realization of the following effective measures:

- Enforcement of a permanent registration of the pet animals, according to the Veterinary Act.

- Sanctions for the mass trade with pet animals, according to the Veterinary Act.

- Establishment of control over the activeities connected with collection and transportation of pet animals (shelters et. c.), according to the Veterinary Act.

- Initiation of a campaign for information and education, according to the Convention for the Protection of Pet Animals, in order to discourage the amateur breeding.

- Initiation of a campaign promoting sterilization of the pet animals, according to the Convention for the Protection of Pet Animals, in order to increase the number of the sterilized animals.

- Initiation of a campaign encouraging re-homing of the "second-hand" pets, offered by their previous owners.

I would like to thank you in advance and looking forward to your rapid answer.


Emil Kuzmanov, founder



 Letter to the National Assembly's Agriculture Committee, 2007



The Animal Programs Foundation of Bulgaria
18 Yanko Sofiiski Voivoda Str, 1164 Sofia

Mr Vassil Kalinov
Agriculture and Forestry Committee
National Assembly of the Republic of Bulgaria
2 Narodno Sabranie Sq
1169 Sofia

November 23, 2007

Concerning : Defect of the Animal Protection Bill

Dear Mr Kalinov,

The Animal Protection Bill provides that the municipal funds for pet population control to be used for collection and sterilization of stray animals i.e. for street activity. The authors and promoters of the Bill did not make any provision for the promoting sterilization of owned pet animals. And so paragraph 12.b.II. of the European Council's Convention for the Protection of Pet Animals according to which "paries undertake to consider reducing the unplanned breeding of dogs and cats by promoting the neutering of these animals", remains totally neglected.

The Bill does not provide any mechanism to heighten sterilized ratio of pet populations. This defect casts a shadow of doubt over efficiency of the new Low. Even more, the effort made to keep the taken wrong direction shows intentions to legalize existing pointless practice in this area and spread it in the whole country. The public interest will be damaged in favor of some private and group interests.

The Agriculture and Forestry Committee should make a report including the proposals of MPs for improvement of the Bill. The Bill and the proposals will be offered for final vote in the Parliament. On November 14, 2007 I saw the questions ask by the MPs so far. But there were no proposals dealing with the mentioned problem. Thus the opinion of the international institutions was neglected. On January 10, 2007 the European Parliamentary Intergroup for the Protection of Animals sent letters to the Chairman of National Assembly and the Prime Minister; and insisted that such measures should be included in the Law. The Director General of WSPA ensured us that recently he had highlighted to the Vice Chairmen of Agriculture and Forestry Committee the same necessity.

The worldwide good practice for sterilization of owned pet animals known as "free and low-cost service" remains unused. For the last 30 years in the USA this practice had led to 70 per cent sterilized ratio among the dog population and 90 per cent among the cats. And the number of unwanted animals killed in the shelters was reduced by eight to nine times.

In Bulgaria the drop of dog and cat overreproduction depends on the restriction of the fertility among hundreds of thousands owned pets. Meanwhile many households will have difficulties to sterilize their animals, despite of their good will. So it is necessary to provide help for such owners in the Law.

That is why I insist and beg that the Agriculture and Forestry Committee should include a proposal for additional text in the Animal Protection Act, Chapter IV - "Companion Animals" and so the defect in the Bill to be removed.

Yours sincerely,

Emil Kuzmanov, founder

Cc: Georgi Parvanov
Cc: Neil Parish MEP
Cc: Dr Marc Danzon
Cc: Major General Peter Davies



Animal Programs Foundation


Mr Georgi Parvanov, President of the Republic of Bulgaria
Mrs Lidia Shuleva, Vice Prime Minister
Mr Milen Veltchev, Minister of Finances
Mr Mehmed Dikme, Minister of Agriculture

Legal Control Over All Activities Involving Pet Populations

Dear Lady and Gentlemen,

At present Bulgaria lacks of steady and reliable administrative watch and control over it's dogs and cats inhabitants. So neglected they have became an easy pray for poachers and the black-market industry.

In December 2002, and ever since ANIMAL PROGRAMS undertook the initiative to help resolve this ever-urgent crisis.

In his written rejection to my previous proposition for adapting mandatory measures and steady, firm & reliable control over all activities and commerce involving such animals, Mr. Tsvetan Dimitrov, Head of the Animal-Farming section at the Agriculture Dept., in reality confirmed, that the legal and official control in this direction barely covers/touches only a fraction of the general population of dogs and cats, their reproductive process, and all related activities:

- Identification and registration of pet-dogs reached 6 months.

- Keeping reports and records of licensed & registered thoroughbreds-breeders, and club breeding activities.

- Keeping reports and records on the legal trade with animals for companionship.

In Bulgaria there is not such an up-to-date record or info on this field. Therefore we need to rely upon assumptions and make use of The Great Britain's and US's statistical data, provided to us by the Royal Society for Prevention of Cruelty to Animals (Great Britain) and by the American journal ANIMAL PEOPLE.

The latest conception for control regards both animal species and related human activities as one whole world of system. The main and common problem all over the world with both species are ever-increasing population arising from their uncontrolled reproduction in the urban environment. Therefore the effective control should start with curbing reproducibility and achieving their total control according to human and society's needs. Prevention of unplanned pet birth is well-desired, long expected and ambitious result of constant efforts in few directions:

- Educate and indoctrinate proper and responsible conduct among all cat and dog lovers.

- Discouraging of cat and dog breeding.

- Firm and strict regulation over trade and commerce involving cats and dogs.

- Increasing the number of sterilized females.

- Keeping a single and functional nationwide ID record of all animals, as well as a single record of their keepers and registered owners.

(1) Among the better part of our nation is a widespread traditional love of both species. A Tradition is also the openhearted compassion towards the stray dogs, as well as towards the huge number of free-roaming cats and dogs in residential and industrial yards. On top of all that is a widespread practice of incidental and extravagantly impulsive people to take home pups and kittens. As a result of that is wide spread practice the pets to be offer for adoption or outright stayed thoroughbreds bought and kept for 2-4 years.

(2) During the last few years numerous media, bureaucrats, veterinarians and non-governmental organizations got engaged themselves in a massive phony and hypocritical propaganda aimed towards the trustful and suspicious of nothing Bulgarians. As of today the understanding of the problem is widely believed to be the lack of an "Animal Protection Act" as well as the fate of the stray dogs is treated as a completely isolated and "separate population" case. In a meanwhile the question about the approximate number and estimated increase for both species has been carefully avoided. We have an excessive and steady nationwide reproduction of dog and cat offspring. Not enough owners are restricting their pets of mating, owing it to obscure, subjective and biased motivations. There is widespread false belief, that giving birth is healthy for the animal and that are more then enough potential candidates for their offspring. Many others are breeding them for a hopeful undeclared income of 100-150 Euro/each.

(3) Practically in Bulgaria there are no rules for offering and obtaining cats and dogs. There are no rules for organized illegal activities associated with them as well. Part of this black-market you'll see on the bulletin boards at pet-shops, vet-cabinets, in newspapers or
Internet ( One of the organized activity in Sofia is setting free in different town quarters small groups of 3-4 sterilized dogs with collars, which are constantly and obviously born in private backyards.

(4) The fertility among all females practically is kept in tact. Two non-governmental organizations were announcing the sterilization total of about 6,000 male and female dogs during the last 10-12 years.

(5) There is no systematic ongoing ID record kept in Bulgaria and a single registration of the animals, their owners and keepers as well. We can approximate the density of cats and dogs corresponding to humans using Great Britain's 2001 statistics (the number of cats and dogs is at about 20% of the number of the human population: 8,000,000 cats 6,500,000 dogs).

We can conclude that in Bulgaria the two popionulats are consisted of tame animals, classified by WSPA as "dependant, semi-restricted" and "semi-dependant, non-restricted". Their encouraged and tolerated mating leads to an overpopulation. For yearly picture of probable overpopulation we take North Carolina's 80's statistics, when was officially reported an annual average of 238,000 cats and dogs caught and killed per 1,000,000 people. In Bulgaria the better part of the overpopulation is made of tame, "yard" animals, which has a good living conditions for up to 7-8 month of age. Another big part of the overpopulation is constituted of the unregistered pets which were been offered on steady bases by their owners. Obviously their number well exceeds the possibilities of finding a home.

The lack of prevention in our country necessitates the need of pet-population reduction. The only data to my knowledge of such an activity is, that back in May 2000 the deputy-mayor of Sofia announced in the press that about 13,000-14,000 stray dogs were killed at The City's shelter for 16 mo. period. On occasion I was a witness that tame dogs caught by The City's dog-catchers were not checked in The City's shelter. In March 2000 Mr. Pavel Atanasov shot a video of inhumane activities in the same City-shelter, included witnessing the loading to a truck of few dozens alive and drugged-down dogs and taking them to unknown destination. Popular in Sofia are the non-governmental organizations which always collect tame dogs with promises of theirs adoption in Switzerland. The cats kept outdoor always disappeared due to poachers.

We have to conclude that here, besides the formal, there is a "hidden" overpopulation. The commercial interest and the possibility of improper conduct towards the total increase are on focus of the black-market industry, which in turn obtain inexpensive raw-material from animals and from offered pet-companions alike. It's world known, that Far East exports about 2,000,000 pieces of leather yearly, yielded by domestic dogs. During the 90's West Europe and US were flooded with leather goods made out of animals (cats and dogs). Just because of that USA in 2000 and Italy in 2001 had to adapt special restrictive import laws.

Animal Programs Foundation is awaiting the registration by Sofia City Court on case №12496/2003. Meanwhile myself personally am involved in bringing the problem to light (as much as being allowed) and to indoctrinate proper and responsible conduct among all animal lovers. Also I'm ready and willing to seek and use help to organize nationwide sterilization program.

At the same time is extremely necessary for government to introduce measures of special commercial control (similar to that of alcohol & tobacco ):

- Keeping a single and functional nationwide ID record of all animals, as well as a single record of their keepers and registered owners (our goal is to legalize all that shady market dealing with such "goods").

- Collecting sizable amount of tax for keeping females fertile (an effectively applied measure abroad to discourage the non-planed breeding).

- Control by licensing and registration of all activities involving cats and dogs defined as commerce.

Dear Sirs, Ladies and Gentlemen, I'm appealing to you to review, assess and appraise impartiality fairly and unbiased all arguments herewith and to render help and support our
public initiative.

Sofia, March 11 2004

Yours sincerely,

Emil Kuzmanov, founder