Memorandum from the League Against Cruel
Sports (DGB 74)
Founded in 1924, the League Against Cruel Sports
maintains a unique approach to the protection of animals—combining
campaigning with conservation. We have recently begun campaigning
on the issue of the welfare of racing greyhounds, and it is in
this context that we are commenting on the draft Gambling Bill.
Our comments focus on the Gambling Commission and its functions,
duties and powers.
1. Although the licensing objectives include
protecting children and other vulnerable persons from being harmed
or exploited by gambling, this clause does not cover the animals
that can be exploited as part of gambling. Our publication "Fat
Cats and Dead Dogs", enclosed, details the problems encountered
by greyhounds before, during and after their racing careers—it
is undeniable that as greyhound racing is currently run, there
is a significant level of suffering. The League feels that the
licensing objectives should include a commitment to protect animals
as well as children and vulnerable persons. Part 1 Section 1 of
the Bill should be amended to state this explicitly. This fits
with the comment in the DCMS document Draft Gambling Bill: The
Policy (p7) that operators will be required to "make gambling
products available in a manner that is socially responsible".
2. There should be an explicit requirement
under Part 1 Section 16 of the Bill for Codes of Practice dealing
with animal welfare to be attached to licences given to tracks
where animals such as greyhounds are bet on. We feel that the
Codes of Practice should, in the case of greyhound tracks, include
clauses on welfare provision at tracks, and on veterinary provision
at tracks. Kennelling standards and track maintenance standards
are both currently highly variable, and often inadequate. Dogs
have previously died or been seriously injured in poorly air-conditioned
kennels, and track surfaces can have an impact on racing injuries.
It is also vital that all tracks should have an independent vet
onsite during races. Currently, not all tracks have a vet; and
in the case of those that do, the vet is usually employed directly
by the track management, who have a vested interest in avoiding
dogs being withdrawn or races cancelled.
3. Similar points of course apply to the
premises licences that the Bill states will be issued by local
authorities, following the same licensing objectives as above.
4. A further licensing objective is to ensure
that gambling is conducted in a fair and open way. In order to
pursue this objective, and at the same time to safeguard greyhound
welfare, the League feels that there should be a full database
of all racing dogs, covering them from birth to death. This will
ensure that punters can be certain of the identity, and the history,
of the dog on which they are betting. In particular, it will tackle
the problem that dogs on independent (flapping) tracks are often
not uniquely identified at all, and certainly do not have records
kept on them—thus impacting on the integrity of the betting
product, in contravention of part (b) of the licensing objectives.
In order to ensure reliable identification of dogs, all puppies
should be microchipped soon after birth, in order to avoid the
abuses that occur with the current ear tattooing scheme (where
dogs' ears are chopped off to avoid identification when they are
dumped). It will also help to address the problem discussed below
of dog retirement.
5. One of the major problems with greyhound
racing is the number of dogs retiring from the industry—around
12,000 dogs every year (around 10,000 retired dogs, and 2,000
young dogs unsuitable for racing), with only 2,000 known to be
rehomed. Many are abandoned, too often mutilated (racing greyhounds
have one ear tattooed as identification, and dumped dogs not infrequently
have this ear removed). This is clearly a problem that needs to
be addressed, and solving it will require significant funding.
The money in greyhound racing is fundamentally in the hands of
the bookmakers, who take over £2 billion every year in greyhound
bets. A tax of a penny in the pound on greyhound bets would cover
the costs of significant welfare improvements to tracks, and rehoming
of all 12,000 greyhounds. There is provision in the Bill for a
statutory levy to fund research into gambling addiction and other
such problems, if the industry fails to voluntarily make sufficient
funds available. This provision should be extended to apply also
to racing greyhound welfare.
6. We further note that the Bill will allow
greyhound tracks to apply for sections of their premises to be
licensed as casinos (as is already the case in the US). This will
mean that the greyhounds will in some sense be acting as "performers"—providing
live entertainment for punters while they are gambling. As such,
their welfare should be protected—again, Codes of Practice
as discussed above will provide such protection.
December 2003
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