Gary J. Patronek, in The Problem of Animal Hoarding, Municipal Lawyer 6 (2001), stated that pet limitation ordinances are “wildly unpopular, difficult to enforce, and likely to be opposed by a broad coalition of pet fanciers, breeders, rescue groups, and animal protection organizations.” While a hoarding specific ordinance, like Alto, prohibits keeping numerous animals in conditions that are harmful to the animals’ health, pet limitation ordinances simply prohibit keeping more than a certain number of animals regardless of the level of care provided to the animals.