Ernest Lungaro, director of Westchester County's SPCA, said it did not appear that the owner intentionally harmed the animals.
He said the dogs died from the accidental fire last Wednesday.
The blaze was sparked by one of several space heaters in the 20-by-20-foot backyard shed in Greenburgh.
Owner Ross Taylor told the Journal News (http://lohud.us/smaKcW0) it was an accident and he missed his dogs.
Taylor faces a string of code violations, including breeding dogs in a residential area.
Officials said his business was shut down in 2006. They did not know when he resumed the breeding operation.