A regulatory panel criticized the state agriculture department's proposed overhaul of Pennsylvania's dog law, saying it "significantly understated" the cost to breeders and failed to take into account the diverse types of kennels in the state.

The costs of renovating kennels and adding staff "are expected to far exceed what could be recovered by increasing purchase prices or adoption fees for puppies or dogs," the Independent Regulatory Review Commission said in written comments Monday.

Gov. Ed Rendell has recommended changes aimed at toughening health and safety standards for Pennsylvania's 2,400 licensed kennels. The agriculture department has estimated that the cost of complying with the regulations would range from $5,000 to $20,000 per kennel.

The proposed changes reflect a "one-size-fits-all" approach to regulating facilities that range from small, home-based breeders to large commercial operations, the commission said.

Agriculture department spokesman Chris Ryder said officials were just beginning to review the review commission's comments and had no immediate reaction to them.

Among other things, his department's proposal would require larger cages and 20 minutes of daily exercise for dogs, and force operators to keep records of exercise, sanitation and feeding.

The commission's comments came more than a month after a legislative hearing on the proposed regulations, which were introduced in December. Groups representing dog breeders and animal-rescue operations testified that the new rules could be costly and burdensome for law-abiding businesses.

Nina Schaefer, president of the Pennsylvania Federation of Dog Clubs, said her organization would urge the department to withdraw the proposed regulations and concentrate on enforcing the current law.

The agriculture department has two years to submit a final version of the regulations for review by the House and Senate agriculture committees and by the regulatory review commission.