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The Court held that empirical data is not necessary to support the adoption of such an ordinance. The existence of alternative methods for resolving the problem or debates as to what is the best method for resolving the problems will not be a basis for declaring the ordinance unconstitutional. Choosing some number arbitrarily also will not render the ordinance unconstitutional as some number must be selected. Similarly, an ordinance prohibiting the keeping of more than three adult dogs in any residential home in the city's residential districts was upheld because it was rationally related to controlling problems of dog noise and odor as it affects health and general welfare." B. Barking dogs and other noisy animals Barking dog ordinances are often challenged under the vagueness doctrine. The most common problem with barking dog statutes, like other nuisance -like or disturbing the peace type ordinances, is the ordinance usually lacks some objective standard to indicate what is unacceptable barking or noise. These statutes come to depend on the personal threshold of annoyance of the complaining neighbor or investigating officer." These measures do not provide adequate notice to citizens of what is allowable and what is not allowable behavior. For example, the City of Edina had its barking dog ordinance struck down as it was not adequately defined. The ordinance prohibited the keeping of an animal which "by any noise disturbs the peace and quiet of any persons in the vicinity." The Court did not find there to be any well accepted, generally understood meaning of the phrase "disturb the peace and quiet." The ordinance did not provide any standard to measure annoyance of persons in the vicinity. The standard was based upon the personal senses of the enforcing officer and from this an average person of common intelligence would not be able to determine the prohibited conduct. This type of standard invites arbitrary enforcement of the law by officers. Therefore, a municipality should provide for some type of measure in their animal control ordinance that defines at what point an animal because a noisy nuisance. For example, many municipalities have decided that more than five minutes of continuous barking, whining, howling, etc. is a nuisance and a citation may be issued under their ordinance. C. Breeding moratorium Recently, mandatory spay and neuter legislation has begun springing up across the country. For example, San Mateo County adopted an ordinance mandating the spaying and neutering of dogs and cats within the unincorporated areas of the county unless the owner had a breeding license or, in limited circumstances, written certification from a veterinarian dispensing with spaying or neutering for health reasons? The stated purpose of this type of ordinance is the reduction of euthanasia of unwanted animals. Although the stated purpose of the ordinance is commendable, for the following reasons a municipality should exercise caution before adopting such an ordinance. First, despite the fact that this type of ordinance has yet to be challenged in court. the G. V'C_L 61 C Lery[ n( M;mmu Cue G 1999 n . .vvamxmn vnr[eoan. . vn"(c °. rvro V 1