Proposed Australian Animal Welfare Standards and Guidelines – Exhibited Animals Consultation Regulation Impact Statement March 2014
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A4.25 – Unquantifiable minor cost of transport requirements – S11.1 and S11.2 (Koalas)Under proposed standard S11.1, the operator transporting a koala must ensure independent koalas are transported individually. Independent koalas with dependent offspring are exempt. Under proposed standard S11.2, the operator sending a koala would have to ensure that 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. These clauses would result in 5% of non-compliant facilities having to obtain both additional containers and ones that would meet spatial requirements. This is unlikely to be a significant cost. However, given that the population and frequency of koala transport is unknown – these clauses remain unquantifiable. A4.26 – Incremental cost of substrate drainage, furniture, spatial and health requirements – S3.3, S3.4, S3.5, S3.6, S3.7, S3.8, S3.9, S3.10 and S5.2 (Wombats)Under proposed standard S3.3, the operator would be required to ensure that each adult wombat has access to substrate to a minimum depth of 500 mm over an area not less than four square metres (except for QLD). Under proposed standard S3.4, the operator would be required to ensure that for each additional adult wombat the area of substrate with a minimum depth of 500 mm is increased by two square metres. Under proposed standard S3.5, the operator would be required to ensure that substrate deeper than 500 mm must be of a type that does not pose a risk of collapse and burial of the wombat. The incremental cost of these requirements would be approximately $500202 per enclosure, which would include the cost of appropriate substrate material and labour. Under proposed standard S3.6, the operator would be required to ensure wombats are provided with shaded retreats at all times and digging opportunities within the enclosure (except for QLD). Moreover, under proposed standard S3.7, the operator would be required to ensure enclosure furniture is positioned in a manner that will not allow a digging wombat to cause the enclosure furniture to shift in any way that may cause injury to any animal. Under proposed standard S3.8, the operator would be required to ensure that a wombat enclosure for up to two adult specimens has a minimum floor area of 45 square metres (except for QLD) and that under S3.9, the operator would be require to ensure that for each additional adult wombat the floor area is increased by a minimum of ten square metres. Finally, under proposed standard S3.10, the operator would be required to ensure enclosures that provide housing for wombats at night time meet all enclosure standards (except for QLD). The implication of this is that for the 5% of non-compliant non-walkthrough display enclosures or holding enclosures, this would involve moving or removing fencing at a rate of $50 per hour for 2hrs of labour time (i.e. $100 per enclosure). That is to say, the operator would have the option of combining enclosures to ensure that the minimum floor area requirements are met (i.e. removing fences) or moving fences. Under S5.2, the operator (apart from those in QLD), unless otherwise advised by a veterinarian, would be required to ensure that wombats are provided with the opportunity to: i. behaviourally thermoregulate; and ii. withdraw from other wombats; and iii. withdraw from viewing by the public. A human made burrow allowing for comfortable temperature could easily be constructed from 2 x 44 gallon drums, insulation batts, plastic tubing (approximately 1 metre in length and 250mm in diameter), form ply for waterproofing, grass seed for stopping erosion, with rocks and logs for the entrance, blocks to prevent the plastic tubing from dislodging from the burrow, straw to maintain temperature and a deep layer of dirt.203 This cost would be estimated to be around $200 of materials and $200 labour (4 hours) per burrow. For a typical enclosure with around 4 wombats the estimated incremental cost would be around $1,600 per enclosure. The total incremental cost to 5% of non-compliant enclosures would therefore be approximately $2,200 per enclosure to satisfy the aforementioned requirements under clauses S3.3, S3.4, S3.5, S3.6, S3.7 and S5.2. The estimated one-off cost of substrate drainage, furniture, spatial and health requirements under Clauses S3.3, S3.4, S3.5, S3.6, S3.7, S3.8, S3.9, S3.10 and S5.2 would be $43,794, as shown in Table A4.43. Table A4.43: Estimated cost of substrate drainage, furniture, spatial and health requirements for wombats
As shown in Table A4.44, the estimated one-off cost of substrate drainage, furniture, spatial and health requirements for wombats over 10 years would be $40,929 in present value 2012-13 dollars with 50.38% of the cost incurred by medium size facilities - particularly in NSW, VIC and WA and 46.02% of the cost incurred by small size facilities – particularly in NSW, VIC and WA. Table A4.44: Estimated one-off cost of substrate drainage, furniture, spatial and health requirements for wombats by state and territory and size of facility over 10 years – 2012-13 dollars
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