While this petition may look good on the surface, similar legislation/regulation called CAPA in Delaware has only resulted in nonstop investigations, lawsuits, and nearly every shelter in Delaware is facing deficits.  While I have no issue with reasonable documentation that is accessible by your agency, we have seen people use CAPA to request information and make complaints 5 or 6 times for the same issue, even after the shelter is cleared the first time.  The costs associated with continually having personnel pull documentation, leadership having constant exchanges with various levels of govt from city, county to statewide is in the end taking funds away from animals in our state and also placing our shelters in a precarious situation financially.  A bankrupt shelter doesn't save animals, and if your agency cares whether your communities continue to have financially viable shelters that will be around in the future, I urge you to deny the petition by No Kill Advocacy Center.

Thank your for your time and attention, and below are some links for your refererence regarding the Delaware situation.

State of Delaware may have to take over dog control across the state because of the mess that CAPA made. 

http://dhss.delaware.gov/dhss/dph/oaw/files/dacrecpt2.pdf

Delaware Animal Welfare Task Force Regarding CAPA - http://legis.delaware.gov/LIS/TaskForces.nsf/6af27240dc8e687185256ff60064c10b/a6a07007145bb71d85257a23004d69ba/$FILE/SCR%2044%20Animal%20Welfare%20Task%20Force%2011-15-12.pdf

Lawsuits - http://delawarecapa.blogspot.com/2013/02/capa-lawyers-best-friend.html

Closed Doors to animals - delawarecapa.blogspot.com/2013/07/capa-closes-shelter-doors-no-kill-open.html

Bankrupted Shelter Doing Dog Control in my county - http://delawarecapa.blogspot.com/2013/09/the-bipolar-roller-coaster.html