Animal activities licensing consultation flawed, but Welsh Government refuse to re-issue

The Welsh Government’s consultation on the licensing of animal activities has come under fire for not allowing respondents to give reasons where they object to the Government’s proposals whether in whole or part.

The Countryside Alliance formally complained to the consultations’ department that the majority of the consultation questions only asked for reasons for your views if you agreed with the proposals. Should you respond in the negative to some or all of what was proposed then you were not asked to give reasons for your answer. The Alliance called for the consultation to be withdrawn and re-issued in a form allowing for all responses, so as to produce a fair and balanced evidence base from which Welsh Government could make decisions.

It's of no great surprise that our complaint was not upheld. The general public have less and less confidence in the consultation process of Welsh Government with many suggesting that consultation questions are leading and decisions are pre-determined. By refusing to re-issue an amended consultation the Welsh Government simply adds to public scepticism about the process and confirms that for many of its proposals they lack the evidence which would justify them.

This is the latest phase in developing a national model for regulating animal welfare, by introducing the licensing of animal welfare establishments, activities involving animals, animal exhibits (static and mobile) and dog racing.

The licensing scheme proposal would cover currently unlicensed or minimally regulated animal-related activities. The full list of their considerations are as follows;

1. Pet Day Care
2. Dog Walking
3. Dog Play Parks
4. Home Boarding (Pets) such as kennels and catteries
5. Pet care facilities such as animal rehabilitation or conservation facilities, for instance, hedgehog hospitals
6. Pet Grooming
7. Pet Sitters
8. Animal Trainers including animal behaviourists, training and socialisation classes
9. Rescue Centres
10. Animal Sanctuaries
11. Re-homing Centres#
12. Fostering
13. Animal encounters such as pet therapy, cat cafes, ‘borrow my pet’ enterprises, puppy yoga, llama/alpaca walks, pony painting parties
14. Mobile and Static Animal Exhibits such as birds of prey exhibits, reptile or exotic animal exhibits/handling
15. Owners, keepers or trainers of racing dogs, including greyhounds
16. Livery Services
17. Primates as pets.

The consultation also asks if respondents want to see a phased ban on greyhound racing in Wales and this is in fact the only question that requests reasons for your answer whether yes or no. There is no justification for banning an activity where any welfare concerns could and should be addressed by regulation, working with the greyhound sector.

The proposals lack clarity as to who is intended to be licensed especially whether licensing should relate to commercial activity or both commercial and non-commercial. We do not believe licensing should extent to the voluntary sector, and our recent feature on ITV Wales explores the need for them to be excluded from any licensing scheme. Whatever comes forward must be properly evidence based, proportionate and workable both for those who will require a licence and those who will have to administer and enforce any scheme. Regulation for the sake of regulation will not deliver animal welfare benefits but will be a burdensome interference with many of those who interact with animals.