Proposed Australian Animal Welfare Standards and Guidelines – Exhibited Animals Consultation Regulation Impact Statement March 2014

4.3.2 Cost drivers of the proposed national standards – Criterion III

A summary of the 10-year quantifiable costs of the proposed general standards under Option B is presented in Table 7 and is estimated to be $6.24m (i.e. an average of $0.624m p.a. in today’s dollars) with approximately 62% of the cost being incurred by small facilities and mainly with respect to training and record keeping.

A summary of the 10-year quantifiable costs of the proposed general standards under Option B is presented in Table 8 by state and territory with the majority of the cost being incurred by NSW, VIC, QLD and WA and mainly with respect to training and record keeping (except for NSW where there are $0 costs under proposed standard S1.4).

The list of unquantifiable costs under general standards, is given as follows:

• 
  proposed standard S3.6 – unquantifiable cost of ensuring expression of natural behaviours for up to 420 non-walk through display enclosures.⁶⁶
  
• 
  proposed standard S3.28 – unquantifiable cost of not being permitted to continuously keep an animal in a holding enclosure for a period longer than 90 days.⁶⁷
  
• 
  proposed standard S3.29 – unquantifiable cost of ensuring that a holding enclosure complies with the holding enclosure spatial requirements for up to 124 holding enclosures.⁶⁸
  
• 
  proposed standard S3.31 –unquantifiable cost of ensuring that a holding enclosure is not used for routine management to rotate an animal for up to 124 holding enclosures.⁶⁹
  
• 
  proposed standard S3.32 – unquantifiable cost of seeking written advice from the treating veterinarian for continued holding of an animal in a holding enclosure if an animal undergoing veterinary treatment is held for more than seven days in that holding enclosure.⁷⁰
  

• 
  the extent of transport of exhibited animals across state borders;
  
• 
  the extent of operations in relation to operating temporary exhibits or establishing permanent exhibitor facilities in other jurisdictions; or
  
• 
  the frequency of liaising between Industry associations and the eight different jurisdictions; and
  

therefore, these cost savings associated with these issues are unquantifiable.

A summary of the 10-year quantifiable costs of the proposed taxon standards under Option B is presented in Table 10 by state and territory with the majority of the cost being incurred by NSW, VIC, QLD, WA and TAS and mainly with respect to: enclosure, furniture and spatial requirements for crocodiles; fox proofing enclosures for macropods⁷²; fencing requirements for macropods⁷³; enclosure furniture and spatial requirements for crocodiles; providing for appropriate enclosure height for ratites; weighing and recording requirements for koalas⁷⁴.

The list of unquantifiable costs under the proposed taxon standards under Option B, is given as follows:

• 
  proposed standard S11.1 – unquantifiable cost of ensuring macropod transportation containers do not have slatted floors.⁷⁵
  
• 
  proposed standard S5.3 –unquantifiable cost of ensuring that newly acquired koalas undergo a minimum 30 day period of quarantine, unless advised otherwise by a veterinarian.⁷⁶
  
• 
  proposed standard S11.1 –unquantifiable cost of ensuring independent koalas are transported individually.⁷⁷
  
• 
  proposed standard S11.2 – unquantifiable cost of ensuring transportation containers are of a sufficient size to allow the koala to maintain a normal resting posture without being in contact with the container’s sides or roof.⁷⁸
  
• 
  proposed standard S11.1 – unquantifiable cost of ensuring that the wombat is transported in a solid, secure container measuring at least 10% longer than the length of the animal and with sufficient width that enables the wombat to lie comfortably on its side.⁷⁹
  
• 
  proposed standard S11.2 – unquantifiable cost of ensuring that each adult wombat is transported individually.⁸⁰
  

Some governments have not been able to adequately resource development of their own enforceable standards but would benefit from the availability of national standards and the opportunity to be part of a system of jointly developed standards.

4.3.3 Option A: (non-regulatory option – voluntary national guidelines)

Option A would involve the issuing and promotion of agreed national risk-based guidelines once every 5 years by AMF, to meet the policy objective as discussed in Part 2.2 of this RIS. These agreed national guidelines would encompass ‘should statements’ as opposed to ‘must statements’ and, unlike the proposed standards, these guidelines would not become regulations and therefore would not be mandatory (i.e. adherence⁸¹ would be voluntary).

Option A would lead to improved animal welfare outcomes, depending on the level of voluntary adherence with the national guidelines, through a better management of risks to animal welfare in exhibited animal facilities. For a detailed discussion of benefit drivers for animal welfare see Part 4.3.1 of this RIS. However, any resulting improvement over the base case is likely to be significantly less than that which would occur under a situation of mandatory compliance with enforceable risk-based standards.

Option A would lead to better ecological outcomes than the ‘base case’. Option A would be marginally more effective in dealing with any pest potential arising from intentional theft, natural disasters, poor transport procedures; or escapes of exotic animals.⁸² For a more detailed discussion on the benefit drivers for ecology see Part 4.3.1 of this RIS. However, the reduction in ecological risks under Option A would again depend on the level of adherence to voluntary guidelines.

Under Option A, operators of exhibited animal facilities would incur voluntary costs, depending on the degree of adherence to the voluntary guidelines. However there would be no incremental costs imposed under Option A as compared to the ‘base case’. Importantly, any voluntary cost incurred would be driven by the degree of adherence to the guidelines. A description of potential voluntary costs with respect to general and taxon guidelines that might be incurred is summarised in Tables 7 and 9 in Part 4.3.2 of this RIS. The potential voluntary costs with respect to general and taxon guidelines per state or territory under Option A (as illustrated in Tables 8 and 10 in Part 4.3.2) will again depend on the degree of adherence to the guidelines.

4.3.4 Option B: (the proposed national standards)

Option B would involve the issuing and promotion of agreed national risk-based standards once every 5 years by the AMF, to meet the policy objective as discussed in Part 2.2 of this RIS. These agreed national standards would encompass ‘must statements’ and, unlike Option A, these standards would become regulations and would be mandatory (i.e. compliance would be mandatory).

As compared with Option A, Option B would lead to much improved animal welfare outcomes, through a better management of risks to animal welfare in exhibited animal facilities due to mandatory compliance with enforceable risk-based standards. Specifically, there would be improvements in the welfare of animals with respect to the provision of food and water, suitable environments, health care, opportunity to express most normal behaviours and protection from fear and distress.⁸³ For a more detailed discussion of the benefit drivers of animal welfare under the proposed general and taxon standards, see Part 4.3.1 of this RIS.

Option B would lead to better ecological outcomes than the ‘base case’ than under Option A and would be more effective in dealing with any pest potential arising from intentional theft, natural disasters, poor transport procedures or escapes of exotic animals.⁸⁴ For a more detailed discussion of the benefit drivers of reduced ecological risk under the proposed general and taxon standards, see Part 4.3.1 of this RIS.

With respect to the general standards – Option B would lead to higher incremental costs than the ‘base case’, of approximately $6.24m over 10 years in 2012-13 dollars (discounted at a rate of 7%), as summarised in Table 7 in this RIS. Also, as shown in Table 7, the distribution of incremental costs would be 12.45%, 25.66%, and 61.89% for large, medium and small size facilities, respectively. As shown in Table 8 in this RIS, the quantifiable costs of the general standards would fall mainly on NSW, QLD, VIC and WA with cost shares of 21.79%, 21.65%, 19.55% and 18.34%, respectively. These costs would mainly be incurred with respect to training of keepers and record keeping.

Option B would be effective in promoting industry-wide standards, would have a positive effect on the economy and would reduce transaction costs of compliance. The proposed standards would facilitate improved consistency of animal welfare outcomes across states and territories. This would mean more certainty and increased compliance, as well as reduced regulatory burden.

With respect to taxon standards – Option B would lead to higher incremental costs than the ‘base case’, of approximately $0.81m over 10 years in 2012-13 dollars (discounted at a rate of 7%), as summarised in Table 9 in this RIS. Also, as shown in Table 9, the distribution of incremental costs would be 8.51%, 45.33% and 46.17% for large, medium and small size facilities, respectively. As shown in Table 10 in this RIS, the quantifiable costs of the taxon guidelines would fall mainly on WA, NSW, VIC and QLD with cost shares of 24.72%, 20.58%, 20.43% and 12.49%, respectively. Costs would mainly be incurred with respect to enclosure furniture and spatial requirements for crocodiles; fox proofing enclosures for macropods⁸⁵; fencing requirements for macropods⁸⁶; providing for appropriate enclosure height for ratites; and weighing and recording requirements for koalas⁸⁷.

4.3.5 Options C1 and C2: (variations of the proposed national general and taxon standards)

As with Option B, Options C1 and C2 would each involve the issuing and promotion of agreed national risk-based standards once every 5 years by AMF, to meet the policy objective as discussed in Part 2.2 of this RIS. These agreed national standards would become regulations and would be mandatory.

As with Option B, Options C1 and C2 would lead to improved animal welfare outcomes, through a better management of risks to animal welfare in exhibited animal facilities due to mandatory compliance with enforceable risk-based standards. As with Option B, there would be improvements the welfare of animals with respect to the provision of food and water, suitable environments, health care, opportunity to express most normal behaviours and protection from fear and distress.⁸⁸ However, Option C2 would lead to greater animal welfare outcomes than Options B and C1 as there would be a reduction in the number of days an animal would be kept in a holding enclosure given that this option requires that a holding enclosure only needs to be 1/3 of the specified exhibit size.

Options C1 and C2 would lead to the same quantifiable incremental costs for the general standards as Option B (see Table 7) of approximately $6.24m over 10 years in 2012-13 dollars.

With regard to the unquantifiable costs for the general Standards, Option C1 would be identical to Option B (see Part 4.3.2 of this RIS). However, Option C2 would result in additional unquantifiable costs by requiring a maximum period in a holding enclosure of 30 days without government approval instead of 90 days under an amended proposed standard S3.28. This is likely to result in a slightly higher cost than under Options B and C1.

Options C1 and C2 would be as effective in promoting consistency as Option B. As with Option B, this would be likely to result in more certainty and increased compliance, as well as reduced regulatory burden.

Option C2 would lead to the same quantifiable incremental costs for the taxon standards as Option B (see Table 9 in this RIS) of approximately $0.81m over 10 years in 2012-13 dollars.

Option C1 which would allow for an alternative to fox proofing macropod enclosures would result in the same incremental costs for the taxon Standards as Option B – except that the incremental cost of proposed taxon standard S3.2 would have an annual cost of $25,251 and a one-off cost of $4,570 or $0.18m⁹⁰ over 10 years, instead of $0.08m⁹¹ over 10 years, a net increase of $0.1m over Option B. Moreover, 81.2% of the cost would be incurred by small size facilities and particularly in QLD. This would make the total quantifiable cost of taxon standards under Option C1 equal to approximately $0.91m⁹² over 10 years in 2012-13 dollars.

Unquantifiable costs of taxon standards:

With regard to the unquantifiable costs for the taxon Standards, Options C1 and C2 would be identical to Option B.