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

A3.12 – Incremental quantifiable and unquantifiable costs of holding enclosure requirements¹⁴⁸ – S3.28, S3.29, S3.30, S3.31, S3.32

A3.12.1 – Incremental unquantifiable minor cost of S3.28

Under proposed standard S3.28, the operator would not be permitted to continuously keep an animal in a holding enclosure for a period longer than 90 days unless the operator has been granted approval by the relevant government authority. For the most part it would be relatively easy for an operator to meet this requirement by reducing the ‘continuous’ number of days that an animal is kept in a holding enclosure for most of the following reasons:

ii. repair and maintenance of the animal’s enclosure;

iii. overnight security;

v. overnight sleeping dens; and

vi. as part of, or in preparation for, an animal demonstration.
Furthermore, this would already be a requirement under NSW Code 20, WA Code 18; and the QLD Code (in part) under the base case. However, it may be difficult for an operator to meet this requirement by reducing the ‘continuous’ number of days that an animal is kept in a holding enclosure for:
iv. capture, restraint, transport or veterinary reasons.
For example, it is conceivable that a sick animal (e.g. one suffering from broken bones) would have to be maintained and cared for in a holding enclosure for a longer period than the minimum continuous days allowed. In this case there would be an incremental cost of seeking approval by the relevant government authority. However, given that the frequency and magnitude of this occurring is unknown – this proposed standard remains unquantifiable.

A3.12.2 – Incremental unquantifiable minor cost of amended S3.28 – Option C2

Under Option C2, general Standard S3.28 would be amended to state a maximum period in a holding enclosure of 30 days without government approval instead of 90 days. This option is introduced to address the concern that the current time of 90 days could promote an animal welfare issue given that a holding enclosure only needs to be 1/3 of the specified exhibit size. This would require that government approval be sought more often with the use of holding enclosures particularly for veterinary reasons. This is likely to add a minor incremental cost however as with part A3.12.1, given that the frequency and magnitude of this occurring is unknown – this proposed standard remains unquantifiable.

A3.12.3 – Incremental unquantifiable cost of S3.29

Proposed standard S3.29 requires that the operator must ensure that a holding enclosure complies with the holding enclosure spatial requirements stipulated by relevant taxon standards unless:

A3.12.4 – Incremental cost of S3.30

Proposed standard S3.30 requires where no holding enclosure spatial requirements are stipulated by relevant taxon standards the operator must ensure that the spatial dimensions of a holding enclosure are a minimum of 1/3 of a non-walk through display enclosure. The implication of this is that for the 5% of non-compliant holding enclosures for species groups, this would involve moving or removing fencing at a rate of $50 per hour for 2hrs of labour time (i.e. $100 per holding enclosure). The estimated one-off cost of ensuring sufficient spatial dimensions of a holding enclosure under proposed standard S3.30 would be $0.06m, as shown in Table A3.20.

As shown in Table A3.21, the estimated one-off cost of providing sufficient spatial dimensions for holding enclosures under proposed standard S3.30 over 10 years would be $0.06m in present value 2012-13 dollars with 56.86% of the cost incurred by small size facilities.

A3.12.5 – Incremental unquantifiable cost of S3.31

Proposed standard S3.31 requires that an operator must ensure that a holding enclosure is not used for routine management to rotate an animal through an enclosure unless:

ii. where no holding enclosure spatial requirements are stipulated by relevant taxon standards, the holding enclosure is a minimum of 1/3 the enclosure spatial requirements stipulated by relevant taxon standards; and

iii. the animal is kept in the holding enclosure no more than 24 hours in any 48 hour period.
The incremental cost of (ii) has already been accounted for and it would be relatively simply for an operator to ensure that an animal is kept in a holding enclosure for a maximum of 24 hours over 2 days (i.e. iii). However, as with S3.29, there would an unknown proportion of approximately of 124 holding enclosures that would be affected by spatial requirements under (i). Therefore, for the same reasons as under proposed standard S3.29, the incremental cost of proposed standard S3.31 remains unquantifiable.

A3.12.6 – Incremental unquantifiable cost of S3.32

Under proposed standard S3.32 there would be an incremental cost to an operator for seeking written advice from the treating veterinarian that recommends 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 and it is either:

ii. where no holding enclosure spatial requirements are stipulated by relevant taxon standards, smaller than 1/3 of the prescribed enclosure dimensions