Memorandum submitted by the National Farm
Attractions Network
Although in principle we are in favour of an
improvement in animal welfare we are concerned about the lack
of detail in the Bill and how much it leaves open to individual
interpretation by the different local authorities and to the opinion
of the local inspector.
1. Cruelty—Who decides what constitutes
suffering? Any animal kept as a pet could be defined as suffering
as they are unable to run loose, fight or breed indiscriminately.
All responsible pet ownership immediately enforces restraints
on the animal. At which stage do these restraints become cruel?
3. Welfare—This again is too open,
what are reasonable steps to ensure the animals' welfare? How
will we know what an inspector would regard as reasonable?
4. Sale to persons under 16. Are all young
people going to be issued with photo ID. If not, how can you tell
what age a young person is?
6b Will the manufacture and supply of rabbit
hutches, chicken coops, etc, come under these regulations and
will these regulations also apply to all imported cages etc or
is it only a UK rule?
CLAUSE 28
Seizure of animals
Who is going to be responsible for the animals
seized? What facilities has the local authority got for housing
seized animals and finding qualified staff to care for them? Movement
of an animal away from a familiar environment could also pose
a welfare risk for that animal.
CLAUSE 44
I am particularly concerned about the appointment
of inspectors. All inspectors should be fully qualified and trained
in the requirements and natural behaviour of all the species covered
by this act. They should ideally have personal experience of keeping
at least some of these animals and be fully aware of the constraints
that captivity puts on the ability to express natural behaviours.
I believe that these inspectors should be totally independent
of any other body already concerned with the welfare of animals.
They should not belong to any charity or other group which is
already involved with animal welfare and has its own political
agenda. Only by appointing impartial inspectors can this act have
any credibility. If a person is unhappy with the opinion of their
local inspector or has a difficult relationship with one, what
safeguards are being put in place to ensure complete impartiality.
Farm attractions operate in the public eye.
They are already subject to the farm animal welfare regulations.
They are very exposed to the risk of complaints from dissatisfied
customers either through spite or just ignorance of the behaviour
of the animals they are looking at. Public perception is of a
picture book countryside where it never rains or gets muddy.
ANNEX A
Proposal to licence animal-related entertainment
Does this include visitor attractions which
run such events as ferret racing or sheep racing? The added cost
of the licence fee would be prohibitive for small farm parks.
There must be some exclusion clause for smaller organisations
or establishments.
Does this also include bird of prey displays
at shows etc?
ANNEX E
In the farm park business we are frequently
being offered animals to re-home. It is not clear how many animals
you have to re-home to become an animal sanctuary. Even a £50
licence fee is an added cost to the business and could result
in the refusal to take in unwanted animals. This would lead to
even more animals being dumped on the streets. What provision
is being made by the local authorities to replace the smaller
sanctuaries that will close when the licensing becomes mandatory?
The added costs for small businesses in the
tourist industry are escalating, with the imposition of new licensing
laws there will be even more paperwork, etc.
How many licences does an establishment have
to have?
Zoo Licence—For exotic animals.
Riding School Licence—For pony rides.
Pet Shop Licence—To sell surplus rabbits,
etc.
Animal Sanctuary Licence—To re-home unwanted
animals.
Performing Animal Licence—For duck racing,
etc.
I have probably missed some out but your impact
assessment assumes that everybody specialises and runs one particular
business. This does not apply to tourism.
The impact assessment does not take into account
all the added costs generated by man hours taken to fill in all
the forms and keep all the records.
24 August 2004
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