ACAL Response on Licensing of Dog, Cat and Rabbit Breeding Consultation
November 30th 2018: Animal Concern Advice Line made a submission to the Scottish Government Consultation on the breeding and sale of pet cats, dogs and rabbits.
Response ID ANON-AJZU-1VDS-R
Submitted to Consultation on Licensing of Dog, Cat and Rabbit Breeding Activities in Scotland
Submitted on 2018-11-30
Questions
1 The Scottish Government proposes that dog, cat and rabbit breeding activities should be regulated. Do you agree?
Yes
Please explain your answer.:
There are too many unwanted pets as it is and we have long needed legislation to curb puppy farming and dealing. To work any new legislation has to make puppy farming illegal in this country and it must deal with the import and sale of pets reared under conditions which would not be legal in Scotland.
2 Do you agree with the proposal to set the licensing threshold for dog, cat and rabbit breeders at three or more litters a year?
No
Please explain your answer.:
Set it at one litter. One litter of 6 pedigree dogs can be worth as much as £6,000. If I was paying £1,000 for a pup I would want to know that it was bred by a responsible, licensed and inspected breeder on suitable premises and under suitable conditions. This would also take into account those people breeding bull terriers or kittens in tiny flats to supplement their benefits and pay for any substance abuse habits they might have.
3 Do you have any comments on the thresholds that should apply? Should these be different for separate species?
Reduce the thresholds for all species. I'd rather see a shortage of animals instead of the huge oversupply there is now.
4 Do you agree with the proposal that a breeding dog, cat or rabbit must not give birth to more than six litters in their lifetime?
No
Please explain your answer.:
Restrict it to two litters and no more than one litter in any year.
5 Do you agree with the proposal that as a condition of licensing, premises should only be allowed a maximum of 20 breeding dogs or cats within one calendar year?
No
Please give reasons for your answer.:
That's still a puppy farm capable of producing over 160 young animals a year. Restrict it to two breeding animals and you produce true home–bred pets that have a much greater chance of avoiding behavioural and physical health problems.
6 Do you agree that individuals with unspent convictions for animal welfare offences or other criminal convictions (e.g. fraud) should not be allowed to hold a licence for breeding activities?
Yes
Please give reasons for your answer.:
Like child abusers animal abusers should be under scrutiny for the rest of their lives and should not be allowed to breed animals even if their conviction is considered spent. Puppy farmers and dealers are in the business to earn big money selling sick, poorly bred animals so it is a business which would attract fraudsters and other financial criminals. Some have said that selling dugs is better than selling drugs because you can earn big bucks without risking a holiday in the big house.
7. Are there other considerations, apart from criminal convictions, that should be part of a “fit and proper person” test for those running dog, cat or rabbit breeding activities?
At Animal Concern Advice Line I have had to deal with several cases of people with learning difficulties who need support to manage their own lives but have started collecting pets and allowing them to breed until the situation gets totally out of control. There should be some test to ensure people have not only suitable premises and any necessary equipment but have the knowledge and ability to care for animals properly.
8 The Scottish Government proposes that reasonable costs of inspections should be charged to recover costs to inspectors approved by Scottish Ministers or local authorities. Do you agree with that proposal?
Yes
Please explain your answer.:
Pets can sell for large sums of money and, even if they increase prices to recoup the expense from buyers, breeders should not be subsidised from the public purse and should pay for any inspections required and the full cost of processing license applications.
9 Should licence fees be set by the authorised inspectors, local authorities or by the Scottish Government? Do you have any comments on what cost is reasonable and what should be included in this? (For example, this might include recovery of administrative costs, or payment for the inspector's time etc.)
Scottish Government
Please explain your answer.:
The fee should cover all costs incurred and should be uniformly set for the whole of Scotland so that there is no benefit in breeders all moving into one local authority area.
10 The Scottish Government considers that licences lasting from one to three years may be issued on the basis of a welfare risk assessment. Do you agree?
Yes
Please explain your answer.:
I would suggest that all premises be subject to at least one unannounced inspection each year.
11 Do you think that a national list of licensed premises and activities should be kept?
Yes
Please explain your answer.:
Giving people one point of contact for information would make sense. Prospective buyers should be encouraged to ask for a list of licensed breeders (a charge should be made for this) so they know they are buying from a licensed and inspected breeder.
12 Do you have any comments on who should be able to access information from the list, and if a charge should be made for information??
Yes
Please explain your answer.:
Anyone should be able to purchase a copy of the list to enable them to find a licensed and inspected breeder. It would be very much in the interest of the breeders and would greatly assist in identifying people breeding animals illegally.
13 The Scottish Government believes that enforcement agencies should be able to suspend, vary or revoke licenses or issue improvement notices for minor irregularities. Do you agree with this proposal?
Yes
Please explain your answer.:
So long as "minor irregularities" are properly defined and are indeed minor and not causing welfare problems. Improvement notices must give strict, short compliance times followed by inspection to ensure they are met. Failure to observe an improvement notice should result in immediate loss of license.
14 The Scottish Government proposes that new legislation will require compliance with any relevant Scottish Government guidance as one of the licence conditions. Do you agree that this should be a condition of licensing? If you are aware of any other relevant standards please comment.
No
Please explain your answer.:
I do not think much of guidance and would prefer that compliance requirements be properly included in enforceable legislation.
15 Do you agree that appropriate fixed penalties should be available for minor non-compliance with the licensing legislation? (These are not currently available for animal welfare offences but may be introduced in future.)
Yes
Please explain your answer.:
Again only if these “minor” problems do not compromise the welfare of any animals and that non–compliance within a specified period then results in further more serious penalties such as loss of license.
16 Do you agree that the Scottish Government should discourage the breeding of dogs, cats and rabbits with a predisposition for specific genetic conditions, which lead to health problems in later life?
Yes
Please explain your answer.:
More than just discouraging bad breeding it should be a criminal offence to breed animals with known welfare problems. I would go as far as to refuse breeding licenses for breeds of animals known to have a predisposition to debilitating and welfare compromising physical defects. This need not spell the extinction of any breed if the breeder can prove, through a Government appointed veterinary examination, that the animals to be bred from do not have physical defects and the intention is to breed back to a more sound standard to eliminate welfare problems.
17 Do you agree that as a condition of licensing, any breeding practices which are likely to cause the offspring suffering in later life should be prohibited?
Yes
Please explain your answer.:
This should include only breeding from sound parents and ensuring those vital first few weeks of life are under conditions which optimise the chances of producing socially adept family pets.
18 Are there any other measures you consider should be included in legislation for animal sanctuaries and rehoming activities in Scotland?
Yes
Please explain your answer.:
Best way to discourage harmful breeding practises is to identify those practises and prosecute those who practise them. Ensuring that any animals born with defects caused by intensive breeding are neutered and not bred from would also help.