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


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5.0 Nature and impacts of preferred option


The preferred option, i.e. the variation of the proposed national standards (Option C2), addresses the identified problems far more comprehensively than the base case, i.e. the existing legislation and standards as listed in Appendix 1 to this RIS.

5.1 Implementation


The intent of preparing the variation of the proposed national standards is to replace current jurisdictional standards, but it is ultimately a matter for each jurisdiction as to whether and how they will implement the national standards, if and when adopted by AMF.

5.2. Impact on competition


The markets affected by the proposed national standards under Option C2 are the markets for recreation, tourism and education. National Competition Policy (NCP) applies to businesses rather than to individuals engaging in non-business activities. To the extent that the proposed national standards would impact on businesses, namely zoos, wildlife parks and aquariums, the incremental costs per business are unlikely to be large enough to create a barrier to entry; and such businesses would be equally affected by the same regulatory environment. Thus the proposed national standards would be unlikely to restrict competition.
Table 12 estimates the distributional impact of the quantifiable general standards and taxon standards on samples of small, medium and large facilities arising under Option C2. As shown in Table 12, annualised average cost of general standards per facility as a proportion of admissions revenue represents 0.005% for a medium facility to a maximum of 1.26%. In relation to small facilities, which are the majority representation, costs are likely to represent a proportion of revenue in the vicinity of 0.118% to 0.734%. Therefore, the general standards are unlikely to create a barrier to entry. As shown in Table A3.28 in Appendix 3 – the main cost to small facilities is record keeping (an ongoing cost) and represents 76.97% of all costs. Therefore, the bulk of the average 10-year cost $22,113 to small facilities (see Table A3.28) is likely to be incurred over time (i.e. $2,211 per annum), as opposed to upfront.
Table 12: Distributional impact of general and taxon standards on samples of small, medium and large facilities – Option C2


Size of facility

Estimated admissions revenue

Annualised average cost per facility

Annualised average cost per facility as a % of estimated admission revenue







General standards95




Large

$5,045,42796

$9,702

0.192%

Large

$28,188,49397

$9,702

0.034%

Large

$30,100,00098

$9,702

0.032%

Medium

$104,000,00099

$5,614

0.005%

Medium

$445,500100

$5,614

1.260%

Small

$301,125101

$2,211

0.734%

Small

$1,875,000102

$2,211

0.118%







Taxon standards103




Large

$5,045,427

$874

0.017%

Large

$28,188,493

$874

0.003%

Large

$30,100,000

$874

0.003%

Medium

$104,000,000

$1,289

0.001%

Medium

$445,500

$1,289

0.289%

Small

$301,125

$215

0.071%

Small

$1,875,000

$215

0.011%

With regard to the quantifiable taxon standards under C2, annualised average cost per facility as a proportion of admissions revenue represents 0.001% for a medium facility to a maximum of 0.289%. In relation to small facilities, which are the majority representation, costs are likely to represent a proportion of revenue in the vicinity of 0.011% to 0.071%. For these reasons the taxon standards are unlikely to create a barrier to entry.



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