Memorandum submitted by Greyhounds UK
Supporters: Alexandra Bastedo, Jean Boht, Rory Bremner,
Simon Callow, Jilly Cooper, Charlotte Cornwell, Annette Crosbie,
Rolf Harris, Sir John Harvey-Jones, Joanna Lumley, Dame Diana
Rigg, Richard Wilson.
EXECUTIVE SUMMARY
— There has been widespread and sustained
concern about the welfare of racing greyhounds in Parliament and
among welfare groups for more than a decade.
— In the self-regulating greyhound
racing industry, cruelty is institutionalised and welfare for
the dogs competes unsuccessfully with business priorities.
— The draft Bill fails the greyhounds.
While it includes provision for licensing, registration and a
Code of Practice which would protect greyhounds, these animals
are last in the line for attention (in 2010). The greyhound industry
is left in the meantime, maybe permanently, to its own devices.
— It is not clear what evidence Defra
would collect in 2010 to decide what then needs to be done for
greyhounds.
— The National Greyhound Racing Club
exists to protect the bookmakers not the dogs. Their Rules are
not a welfare Code of Practice.
— Greyhound racing is a medium for
betting and generates £millions in profits for the bookmakers
and track owners and revenue for the Treasury.
— Veterinary surgeons at all greyhound
tracks should be independent and not directly employed by track
management.
— Independent scrutiny of the greyhound
racing industry is vital to ensure greyhound welfare is not compromised
by profit. Action under the Bill's provisions is needed urgently.
1. Paragraph 13 of the Regulatory Impact
Assessment reports widespread support in those responding to the
Consultation for better regulation of greyhound tracks. The concerns
we expressed in our response to the consultation went wider and
covered the greyhounds' welfare before, during and after racing.
Nearly 300 Members of Parliament signified their concerns about
greyhound welfare by putting their names to an Early Day Motion
earlier this year, 13 years after the Home Affairs Committee recommended
that profits of track owners and bookmakers should be directed
to establish sanctuaries for greyhounds when their racing life
is over. Those recommendations were never actioned.
2. In the 75 years since greyhound racing
was introduced as a medium for betting in this country, a culture
of institutionalised animal cruelty has developed within the greyhound
industry, sanctioned by Government. This self-regulating industry
is a closed world, defensive and without independent inspection
from outside. Welfare for the dogs competes with business priorities
of restaurants, lounges for human customers. Lack of organised
arrangements for looking after the dogs when they are past racing
and surplus to the industry's requirements results in premature
death and abandonment.
3. Hopes were high that a 21st century Animal
Welfare Bill would deliver protection for greyhounds. Our conclusion
on examination of the proposals in the draft Bill is that the
Government has failed the greyhounds not by accident but by design.
4. Our comments on clauses in the draft
Bill are linked to statements in the Explanatory Notes and Regulatory
Impact Assessment (in particular Annex H).
5. Following are the passages in those three
documents which are relevant in considering the welfare of greyhounds:
(a) The power to make regulations for promoting
welfare among animals being used in sport is in Clause 6(2)(a)(v)
of the draft Bill.
(b) The power to license and register activities
involving animals (Clause 6(2)(h) and (i)) which then invokes
the powers of entry and inspection contained in Clause 37 of the
Bill.
(c) Clause 6(2)(q) provides for bodies with
advisory functions on animal welfare.
(d) Clauses 7 and 8 provide the power to
issue Codes of Practice for particular categories of animal care.
As paragraph 49 of the Explanatory Notes indicates, Codes of Practice
issued under the Bill will be capable of being evidence of either
an offence under the Bill or compliance with its requirements.
(e) Paragraph 29 of the regulatory Impact
Assessment describes Option 3—the draft Bill which is now
before the Committee—and anticipates that within five years
of the Act coming into force, regulations and Codes of Practice
would be introduced and enforced by local authorities in relation
to, among others, "The welfare of greyhounds at race tracks".
6. However, Annex H to the Regulatory Impact
Assessment considers a proposal to licence/register kennels at
"Dog Race Tracks" and includes the following statements:
(a) "The National Greyhound Racing Club
(NGRC) works to a Code of practice."
(b) "[NGRC] tracks attract off-course
betting from large betting companies and it is suggested, though
not proved, that this could be to the detriment of the welfare
of the dogs."
(c) "Over the last few years there has
been a growing impetus within the racing industry to raise welfare
standards."
(d) "The British Greyhound Racing Board
(BGRB) is in the process of drawing up proposals for further reform
and in these circumstances it is premature for government to assess
the extent to which government regulation would be necessary to
raise standards."
(e) "Consideration is being given to
self-regulation by the NGRC, who would also regulate non-NGRC
tracks—such regulation would not affect local authority
costs."
(f) In Annex L—Regulations Timetable—Regulation
of Greyhounds is targeted in year 2010.
7. Taken together, the provisions described
above show that while the Government has acknowledged widespread
support for action to licence, register, introduce Codes of Practice
to protect greyhounds, it has chosen not to do anything for five
years and even then would rather leave it to self-regulation.
Without any Code of Practice in the meantime, there will be no
yardstick against which to judge whether the general offences
of cruelty and suffering have been committed against greyhounds
for which some prosecuting authorities already expect a lower
standard of care.
8. The NGRC is a self-appointed undemocratic
body whose purpose is to reassure the bookmakers that dogs are
not doped, that the dog running is the one described in the programme
and that the bookmakers can lay odds on the basis of previous
form. NGRC Rules are not directed toward to the greyhounds' welfare
and in some instances run counter to it: Their view about frequency
of racing is that a dog should race not more than twice a day
whereas veterinary surgeons consider that a race once a week is
desirable. When dogs are found abused, abandoned or dead, the
NGRC refuses to supply details of the last owner to the police
or other lawful authorities, claiming that the Data Protection
Act prevents disclosure; their Registration document with the
Information Commissioner gives the lie to this. Trainers and owners
are penalised if they withdraw their dogs from races because of
concerns over track safety and a challenge to an NGRC ruling of
this kind is due to be heard in the High Court in October. A book
of Rules from a discredited organisation should not constitute
a Code of Practice under Animal Welfare legislation. Self-regulation
protects the bookmakers, not the dogs.
9. It is inaccurate to say that "there
has been a growing impetus within the racing industry to raise
welfare standards". In truth, the greyhound industry has
reacted—slowly, reluctantly—to pressure from welfare
campaigners. Even now, though the word "welfare" is
frequently uttered by Ministers, industry spokesmen and the bookmakers,
action is lacking because it suits the vested interests of Government
and the racing industry not to divert resources from profit-making
enterprises.
10. The following facts and figures show
the level of activity by the animals and profits earned for others
by the greyhounds:
(a) More than 30,000 greyhounds are on the
racing strength of British greyhound tracks which operate under
the rules of the National Greyhound Racing Club (NGRC) and which
provide an off-course betting market. (In addition, an unknown
number of greyhounds race on independent tracks.)
(b) Racing life is short: two to three years.
(c) Around 10,000 greyhounds are surplus
to NGRC racing every year through age or injury. There are no
records of their destination afterwards although cases of abuse,
abandonment and violent death are known to occur. One veterinary
surgeon alone said in 1998 that he euthanased nine greyhounds
every week. A survey by Greyhounds UK in 1999 showed that of those
which survived, more than 130 greyhounds a month ended up in the
care of local authorities, animal welfare charities and voluntary
greyhound rescues.
(d) £2 billion a year is bet on greyhound
races with off course bookmakers. 97% of the total is bet on the
Bookmakers Afternoon Greyhound Service (BAGS) shown in betting
shops between horse races. 16 tracks take part in BAGS; of these
six are owned by bookmakers. In 2002 16,000 races were run for
BAGS, an increase of nearly 300% on the preceding year. The trend
is accelerating sharply and duration of meetings lengthening in
the summer. The dual role of bookmakers has the effect of depressing
the market price for BAGS contracts, impacting on the returns
to owners and trainers.
(e) Bookmakers pay £13.5 million to
tracks for BAGS meetings—in some instances, paying themselves—and
derive £92 million in net profits through betting plus of
course the contract payments back to their own tracks.
(f) The Treasury receives £351 million
a year from bookmakers in general betting duty (15%). Greyhound
racing constitutes 21% of betting office business.
(g) The greyhound industry argues that greyhound
ownership is a "hobby" and greyhound owners have sole
responsibility for the dogs' future once racing is over and the
BGRB Chairman has said that the first principle remains that the
owner should take the dog home in retirement. However, the five
also-rans in BAGS races are likely to receive no more than £20.
Owners have little chance of recouping the purchase price for
the dog, much less cover kennel and veterinary bills or provision
for retirement. The number of private owners is understandably
declining and some bookmaker-owned tracks even prefer dogs to
be owned by trainers. As trainers may have more than 70 dogs in
their kennels there is no chance of them taking that number home.
(h) Most bookmakers pay 0.4% of their gross
profits to the greyhound industry as a voluntary levy and have
promised, not guaranteed, this will rise to 0.6% in the next two
years. 10 years ago this was £1.6 million—this year
it is estimated at £7 million. This funding is used mainly
for infrastructure improvements at tracks (including those owned
by bookmakers). The racing industry decides how much can be allocated
to care for greyhounds after their racing life through financial
support of voluntary rescues.
(i) Under sustained pressure from welfare
campaigners the amount of the bookmakers' money devoted to the
industry controlled charity—the NGRC Retired Greyhound Trust
which uses volunteer labour—has risen from £138,500
10 years ago to £850,000 this year. This is supplemented
by public donations
11. Independent veterinary care at every
track (that is, not employed by track management who could exert
inappropriate influence) should be introduced everywhere. The
focus on reform at independent (flapping) tracks contained in
Appendix H while endorsing and supporting extension of the rules
of the National Greyhound Racing Club is flawed but not unexpected.
12. Recently, the British Greyhound Racing
Board, the governing body for the greyhound industry, has extended
financial inducements to independent tracks to race under the
NGRC rules. This follows the line taken by Defra in Appendix H
to the Explanatory Notes to the Bill. The argument that this is
suggested on welfare grounds is suspect when it is obvious that
existing centres for betting are prime targets for exploitation
under the Government's plans to liberalise gambling. Businesses
overseas have expressed an interest in investment. The self-regulating
industry now wishes to embrace the independent tracks—supposedly
on welfare grounds—which are themselves convenient local
centres for gambling.
13. Many NGRC tracks are poised to incorporate
casinos as soon as they can and will constitute the "entertainment
centres" envisaged by the Labour peer and Chairman of the
BGRB, Lord Lipsey. Casinos will of course yield tax revenue for
the Treasury. But until the public and Parliament can be assured
that no dog suffers injury or premature death, it is not entertainment.
14. The Government's endorsement of the
closed self-regulating world of greyhound racing, as indicated
the Regulatory Impact Assessment could be interpreted as a reluctance
to "rock the (very profitable) boat" because so much
actual and potential tax is involved. Ready utterances of a commitment
to greyhound welfare which emanate from the industry and Government
Ministers do not hide the fact that in future, as now, they want
to leave it to the industry to decide what is necessary for the
greyhounds' welfare without outside interference.
15. Self-regulation by the industry has
failed the greyhounds for 75 years. We have already commented
on the lack of priority given to the animals by the Government.
It is not clear on what objective evidence Defra will be able
to judge whether and what action is needed for greyhounds when
the target date of 2010 arrives. If they are intending to rely
on industry assurances without any independent scrutiny in the
intervening period to inform decisions, then the proposals are
both immoral and incompetent.
16. Independent scrutiny of this industry
is critical and urgent to ensure that greyhound welfare does not
continue to be compromised by profit. An independent adviser on
greyhound welfare should be appointed, drawn from the charitable
sector, who would examine issues of concern and publish annual
reports. As soon as the Bill is passed, we want to see regulations
to provide licensing by Local Authorities with accompanying inspection
together with a Code of Practice drawn up by experienced animal
welfare charities.
17. Delay invites the criticism that Defra,
the Department of Culture, Media and Sport and the Treasury are
in collusion to maximise new gambling opportunities in preference
to legislating to safeguard welfare standards for greyhounds.
24 August 2004
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