Memorandum submitted by Greyhound Rescue
Wales
KEY POINTS
1. Greyhound Rescue Wales generally welcomes
the bill, and in particular that it makes specific provisions
in relation to the independent greyhound-racing sector.
2. The independent sector should be regulated
by Local Authorities. Greyhound Rescue Wales strongly opposes
self-regulation by the NGRC.
3. There would be welfare advantages to
maintaining a properly regulated independent sector.
4. There should be a more rapid phasing
in of regulations affecting greyhounds.
5. The conditions of transport of greyhounds
should be regulated.
6. The regulation of animal sanctuaries
requires further consideration.
DETAILED RESPONSE
1. Greyhound Rescue Wales welcomes the
bill, and in particular the fact that specific provisions
are proposed to promote greyhound welfare and to regulate the
independent greyhound racing sector. We welcome the introduction
of a code of practice for the independent sector, the regulation
of kennels at greyhound tracks, and the obligation for a veterinary
surgeon to be present at race meetings. We are pleased that the
National Assembly for Wales will be able to define a code of practice
in relation to Greyhound Racing in Wales. Greyhound Rescue Wales
would make the following suggestions to improve the bill further.
These are listed in order of priority.
2. The Independent Sector should be
regulated by Local Authorities. The welfare of greyhounds
in the Independent Sector should not be dependent on the willingness
of an unaccountable greyhound-industry based body such as the
NGRC to implement regulations. Greyhound Rescue Wales therefore
strongly opposes the option for "self regulation" of
independent tracks by the NGRC because this organisation has shown
itself to be unwilling or unable to enforce its own rules regarding
welfare over many years. Greyhound Rescue Wales has gathered information
that indicates that rules continue to be flouted for example regarding
the transfer of ownership (see appended report "Greyhounds
Being Killed by Their Owners in South Wales). Greyhound Rescue
Wales is not aware of any reason that suggests the NGRC will enforce
welfare related rules in the future.
3. There would be welfare advantages
to maintaining a properly regulated independent sector. There
would be further disadvantages to regulation of Independent Greyhound
Tracks by the NGRC. Such regulation would effectively incorporate
the independent sector into the registered sector. Independent
Tracks offer racing opportunities for slower greyhounds than race
at registered tracks. This means some greyhounds who would otherwise
be destroyed may instead race in the Independent Sector and that
some greyhounds who become too slow for the Registered Sector
may extend their working lives in the Independent Sector. It would
be helpful to maintain these welfare advantages while at the same
time introducing proper regulation to remove abuses. Independent
Tracks also have the flexibility to further lengthen the useful
racing life of a greyhound for example by introducing graded sprint
races for older greyhounds. This idea was in fact discussed at
a recent meeting of the "Wales Greyhound Forum" which
brings together the three Welsh tracks, the RSPCA, the Dogs Trust
and Greyhound Rescue Wales. The Forum was established by the National
Assembly's All Party Animal Welfare Group (APGAW) and is chaired
by Lorraine Barrett AM the Chair of APGAW. One of the three Welsh
tracks is now holding such races and it is hoped the others will
follow suit.
4. There should be a more rapid phasing
in of regulations affecting greyhounds. Greyhound Rescue Wales
accepts that a period of adjustment is needed to allow Independent
Tracks to adjust to the new regulations. However a six year phasing
in period is too long. It is clear that abuses are widespread
in the Independent Sector and in order to end these as soon as
possible Greyhound Rescue Wales would be keen to see a much shorter
phasing in period. Our information suggests that some independent
greyhound tracks have already decided that they are going to make
no effort to comply with new legislation, preferring instead to
continue to trade as long as they can and then to close. Other
tracks however appear to be taking a more positive attitude and
seem to be willing to adjust. This latter group would probably
not require six years to adjust while the former group have no
intention of making any changes. This suggests that a shorter
phasing in period would be possible. Furthermore we understand
that financial assistance will now be available from the BGRB
to help Independent Tracks adjust to new regulations. Again this
suggests that a shorter phasing in period is possible.
5. The conditions of transport of greyhounds
should be regulated. The Bill covers kennels at greyhound
tracks which is welcomed by Greyhound Rescue Wales. However there
appears to be no mention of the conditions of transport of greyhounds.
This oversight needs to be rectified. Many greyhounds are imported
to the UK each year from Ireland and a large number of these enter
through the Welsh ports. Greyhound Rescue Wales members have witnessed
the conditions in which greyhounds are transported and while some
appear to be satisfactory others are not. It is also of great
concern that there are no restrictions on the length of journeys
and we have been made aware of instances of greyhounds facing
very long journeys as they are taken from one independent track
to another for speed trialling after entering the UK.
6. The regulation of animal sanctuaries
requires further consideration. Greyhound Rescue Wales welcomes
the intention behind the proposal to regulate animal sanctuaries,
ie to ensure that adequate standards are maintained. However greater
clarity is needed about what constitutes an animal sanctuary.
When for example does a private individual who takes some stray
animals into their house become a "sanctuary"? This
proposal must ensure adequate standards while not hindering or
restricting in any way the basic compassionate impulse to help
an animal in distress that underpins the animal welfare sector
and that is at the origin of many of the large and well run animal
welfare organisations that exist today.
22 August 2004
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