To a degree with Labs, some of those Labs now bred to be so heavy as to resemble a small Rottweiller will have this issue regardless of fitness. The more Athletic English working type it's not so much an issue at all. There's a reason many call them "huffer dogs". Having said I have seen a spaniel put out of a live game trial for panting too loud... everyone was a bit shocked, but that was the standard the judge wanted met.
In a deer situation a dog, any dog, lab or not, of reasonable fitness shouldn;t be in a situation where it is breathing overly loudly unless it is stressed, has just chased something, is out of shape.
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