Memorandum submitted by the Natural Horse
Group
EXECUTIVE SUMMARY
The Natural Horse Group believes that there
is no evidence of a need for licensing livery yards and that the
Animal Welfare Bill will mitigate further the need for licensing
by giving legal powers to combat cruelty. If, in the future, the
need for licensing is demonstrated, licensing guidelines should
be drawn up by experts in horse behaviour and welfare and after
a consultation process. Any licensing criteria must be in line
with good horse welfare practices, which the existing British
Horse Society licensing scheme does not fulfil. The Natural Horse
Group believes that licensing of animal sanctuaries may be necessary,
but again, licensing criteria must be in line with good welfare
practices. We agree that a code of conduct for tethering is a
good idea, but needs to be drawn up by people who understand and
have experience of tethering.
The Natural Horse Group welcomes the chance
to respond to the Draft Animal Welfare Bill and supports the aims
of the bill. We would like to comment on the specific parts below.
1. Annex F: Proposal to License Livery Yards
The Natural Horse Group is not convinced that
compulsory licensing of livery yards is necessary. Our reservations
about the scheme are:
(i) The legislation in the new Animal Welfare
Bill will give powers to the authorities to prevent cruelty. Licensing
is actually made less necessary by the introduction of the Animal
Welfare Bill.
(ii) Livery yards are patronised by individual
horse owners, whose level of knowledge should be such that they
make a judgement about the conditions at a livery yard. Unlike,
boarding kennels and catteries, where the animal is left in the
care of the establishment, owners visit livery yards regularly
and so are in a position to see how the yard is run. Livery yards
that do not provide good care will not succeed.
(iii) The cost of licensing is high for small
livery yards that may keep a few horses. There is no guarantee
that the cost of licensing will not increase in the future.
(iv) Focusing on farm diversification, as
one reason that licensing and inspection are necessary does not
take account of the fact that a farm livery is an appropriate
environment for horses than traditional stables. A study looking
at behavioural restriction of horses under different husbandry
conditions, and showed that horses kept in loose-housing (ie,
yarded areas) divided their time in much the same way as feral
horses. [4]A
farm livery has the potential to allow horses to be kept more
extensively, using yards and barns, thereby allowing more behavioural
freedom. Any guidance on good practice should be encouraging farmers
to keep their systems extensive.
2. Shortcomings of current licensing requirements
(i) Clause 11 (subsection 4) of this draft
bill states that welfare needs consist of:
(a) the need for a suitable environment
in which to live;
(b) the need for adequate food and water
at appropriate intervals;
(c) the need to be able to exhibit normal
behavioural patterns;
(d) any need to be housed with, or apart
from, others of its own or other species; and
(e) the need for appropriate protection
from, and diagnosis and treatment of pain, injury and disease.
(ii) Our concern is that a licensing scheme,
based on the existing British Horse Society licensing scheme would
not ensure that horses were kept in conditions that comply with
the above needs. These concerns are summarised as follows:
(a) The need for a suitable environment
in which to live.
The existing British Horse Society
guidelines permit horses to be kept in stalls or looseboxes with
only one hour's turnout and no turnout on some days. It also permits
horses to be kept outside without adequate access to shelter.
This is a particular problem in summer when horses need to be
able to escape the heat and insects.
It is rare for horses to be kept in
stalls today, however, it should not be presumed that a loosebox
is an acceptable alternative. One study, funded by the RSPCA,
showed that circus horses kept in looseboxes showed more behavioural
abnormalities than those kept in stalls, because the former group
had less social interaction with other horses. [5]Humane
horse keeping would favour barns and yards as suitable accommodation
for horses, so that they can be kept in social groups with constant
movement.
(b) The need for adequate food and water
at appropriate intervals.
The existing British Horse Society
guidelines permit horses to be kept without constant access to
appropriate forage. Naturally living horses spend about sixteen
hours a day foraging. Their digestive systems are designed to
have a constant supply of low energy, high fibre feed. Horse's
stomachs are not designed to digest large quantities of starch
and sugar[6].
When fed concentrated feed in meals, digestive problems result
because ulceration results, often leading to crib-biting.
(c) The need to be able to exhibit normal
behavioural patterns.
The existing British Horse Society
guidelines permit horses to be kept in stalls or looseboxes, in
close confinement. This limits the natural behaviour of movement,
socialising, and foraging for food.
(d) Any need to be housed with, or apart
from, others of its own or other species.
The existing British Horse Society
guidelines permit horses to be kept in isolation. Horses are social
animals, forming long-term bonds and intra-group relationships.
They spend their whole lives with other horses. Horses that are
kept in loose boxes, stalls or individual turnout paddocks cannot
fulfil their social needs in terms of physical contact with other
horses for the purposes of play, mutual grooming or simple companionship.
(e) The need for appropriate protection
from, and diagnosis and treatment of pain, injury and disease.
Horses that are restricted in behaviour,
appropriate diet and prevented from forming companionship bonds,
as outlined above, live under mental strain and therefore, cannot
be said to be free of pain, injury or disease.
(iii) If licensing is to go ahead, we should
not be licensing bad horse-keeping practices. Current good practice
in terms of animal keeping in zoos, circuses, farming and laboratories
focuses on the requirement for animals "to live in environments
that foster the expression of species-typical behaviours [sic]"
[7]Animals
that cannot express species-typical behaviours often exhibit abnormal
and maladaptive behaviour. Animal Welfare Institute guidelines
state that: "[t]he essentials of adequate housing for horses
in research institutions are: Access to hay and water ad libitum,
a soft substrate for lying, visual contact with other horses and
opportunity to exercise at will with other horses." [8]If
horses in laboratories and circuses are acknowledged as needing
certain living conditions, the same must be done for domestic
horses being kept for pleasure, breeding and sport. There are
many adaptations that can be made, easily and cheaply, to provide
environmental enrichment to horses living in existing systems.
However, many establishments could be licensed under the current
BHS scheme that would not fulfil the basic needs of horses, as
required by this Bill.
(iv) The Natural Horse Group believes that,
if yards are to be licensed, in addition to being protected from
pain, injury and disease the yards need to fulfil four criteria
for good welfare:
First, space to move. Second, constant companionship.
Third, an appropriate diet in the form of a forage-based diet
and finally, the opportunity to exercise a wide range of natural
behaviour.
Yards should be inspected for horses showing
signs of behavioural distress manifested as abnormal and maladaptive
behaviour. Yards that combat such behaviour by mechanical or electrical
means, for example, crib-biting collars and weaving bars, are
not exhibiting good horse-keeping practices. Yards that combat
stereotyped behaviours by providing environmental enrichment would
be following good equine keeping practises.
4. Annex E Proposal to Licensee/Register
Animal Sanctuaries
Our comments about Annex F also apply to Annex
E as regards the standards to which horses should be kept. However,
we agree that some form of inspection is necessary for sanctuaries,
because the horses are not under the care of individual owners
as is the case for livery yards. We would support the cost of
inspection being kept to a minimum, so that funds are not diverted
from the care of horses.
5. Annex F Tethering
The Natural Horse Group welcomes guidelines
on tethering. It is important that any tethering code of practice
is drawn up by people who understand, and have experience of tethering.
DEFRA may need to consider who to ask to draw up such guidelines
as traditional representatives of the horse welfare do not have
such expertise. Tethering can be more humane than isolation in
a loosebox, allowing grazing, movement and visual contact with
other horses. It also has benefits in that the horse is constantly
moved to fresh grazing, thereby reducing the risk of it grazing
worm contaminated pasture. However, good tethering depends on
where and how the horse is tethered and the same reservations
about keeping horses restricted in looseboxes apply to tethering.
Both methods of restricting horses arise from a time when horses
were worked hard and so were ready to rest once restricted. Tethered
horses still need to be given the opportunity to move and socialise
without restriction for a proportion of their time, every day.
A particular concern is that of access to shelter in hot weather.
We have evidence that welfare organisations
may be focusing attention on tethered horses, with false beliefs
about what is natural for them. For example, offering water to
a horse twice a day is adequate, if it is difficult to provide
constant water; in feral conditions they may drink once a day
or less.
Concerns about tethered horses belonging to
Travelling people could be addressed by the provision of fields
for horses in the vicinity of Traveller sites.
6. Tail docking in dogs
Although the Natural Horse Group is concerned
with equines, we do believe that it is time to enforce the law
about docking dogs' tails for cosmetic reasons. It is virtually
impossible to buy a pedigree puppy of certain breeds that has
not been docked at birth. Docking is mutilation, involving the
severing of the spinal column, and therefore contrary to the law
under the proposed bill.
25 August 2004
4 Kiley-Worhtington, B, Equine Welfare, J A
Allen, 1997. Back
5
Kiley-Worthington, D, Animals in Circuses and Zoos, Little
Eco-Farms Publishing, 1990. Back
6
Cuddeford, D, Equine Nutrition: some unique features, functions
and frailties of the digestive system of the horse. Back
7
Stewart, K L and Bayne, K, "Environmental enrichment for
laboratory animals" in Laboratory Animal Medicine and Management,
Reuter J D and Suckow M A (Eds) International Veterinary Information
Service, 2004. Back
8
Houpt, K A, and Ogilvie-Graham, T S, "Comfortable Quarters
for Horses in Research Institutions", Animal Welfare Institute,
2002. Back
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