Memorandum submitted by the Association
of British Riding Schools
1. INTRODUCTION
In the main my Association still retains the
views expressed in our submission to Peter Hall, Animal Welfare
Division, Defra 5 May 2004. Our comments below are based on the
assumption that the new Bill will embody the content of the Riding
Establishments Act 1964/70 except for the substitutions and insertions
detailed at 8(1) and 8(2) of pages 33 and 34 of the draft Bill.
2. SPECIFIC—RIDING
ESTABLISHMENTS
We remain convinced of the need for both riding
schools and livery yards to be licensed and subscribe to support
of Annex L to the Bill with regard for the need for regular inspection,
particularly with a vet present. However, it is inadequate for
a vet to visit a livery yard only once in five years. We support
the content and Code of Practice of the BHS Livery Scheme. Licensed
riding schools that include livery arrangements should not have
to pay twice! There are many welfare concerns with livery yards,
with some taking money off the public for riding lessons . . .
there must be a level playing field, licensing for all is the
answer. We also feel that some form of qualification is needed
to be a keeper of livery, as is the case with licensed riding
establishments.
3. GENERAL
3.1 We agree
3.1.1 Annex E the need for such licensing
ie sanctuaries.
3.1.2 Annex F the proposal to introduce
a Code of Practice for tethering—there are several simple
codes already in practice.
4. WE QUESTION
4.1 Clause 21 para 93 subsection 2(a) an
eight day period of retention for a seized animal seems unrealistic
. . . follow-up administration including witness identification/location
may go beyond this short time scale.
4.2 Section 3 welfare (3)—abandonment
of an animal should be the subject of a more specific (ie named)
offence. . .duty of care non-compliance is not tough enough!
4.3 Annex G ban on mutilations—there
are arguments for certain working dogs to have their tails docked.
5. PROBLEM—SECTION
11
The RSPCA is currently reluctant to act until
an animal is at a point of great suffering . . . this may be overtaken
by the fact that the Bill specifies "to fail to provide adequate
care even if the animal has not yet suffered". This is a
"woolly" situation for both an inspector and a constable
and in the long term could present a danger for any witnesses
to "care" incidents.
6. CONCLUSION
We support the content and aims of the Bill,
subject to our comments in paragraphs 2 to 5 above. The content
and clarity of the Bill requires that officers of District and
County Councils interpret them correctly and promptly. There still
remains some doubt in our minds as to the effective implementation
of a new Act by local authorities, in view of the poor response
to the Weeds Act and, in particular, the removal of ragwort. This
latter comment does not negate our support for the new Bill.
24 August 2004
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