Proposed Australian Animal Welfare Standards and Guidelines – Exhibited Animals Consultation Regulation Impact Statement March 2014
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4.0 Evaluation of Costs and Benefits4.1 IntroductionThis part of the RIS identifies the relative costs and benefits for the proposed national standards and each of the other options, as identified in Part 3.0, in comparison with the ‘base case’. The ‘base case’ is used as a reference point for measuring the incremental costs and benefits of each of the options, including the proposed standards. Each of the options is assessed in relation to how well the underlying policy objective identified in Part 2.2 of this RIS is likely to be achieved. Where data exists, discounted55 quantitative estimates of costs and benefits are provided over the 10-year life of the proposed standards. A detailed discussion of the estimation of costs and benefits is provided in Appendices 2 and 3 to the RIS. However, where cost and benefit data is not available, the assessment is made using qualitative criteria about the achievement of the policy objective. All costs and benefits reported are incremental to the base case (refer to Part 4.2 of this RIS). The costs and benefits of Options A, B, and C (the practical alternatives) are assessed by using the following criteria (I to III) to compare the effectiveness of each option in achieving the relevant part of the policy objective:
4.2 The base caseThe term ‘base case’ means the relevant status quo, or the situation that would exist if the proposed national standards were not adopted i.e. the existing state and territory standards plus market forces and the relevant federal, state and territory legislation (refer to Appendix 1 for details). This includes animal welfare legislation as discussed in Part 2.1 of this RIS. The base case provides the benchmark for measuring the incremental costs and benefits of the proposed national standards. The influence of market forces on the base case should not be underestimated. Whether public or private organisations, most zoos and wildlife parks operate as income-generating businesses. Their commercial survival and the activities they undertake in relation to conservation, research and education relies on income from the visiting public. Therefore, attracting and retaining visitors is a major consideration for all members of the industry. A facility with healthy animals (that are well cared for and managed), adequate food outlets and eating areas, and well-trained staff who communicate with the public about the exhibited animals, will provide a more pleasant experience than a facility that does not provide appropriate care or housing for its animals. This in turn is likely to result in higher financial viability. Many of the animals themselves have a high value, not so much in terms of sale prices but replacement costs. Exhibiting organisations therefore have a significant financial incentive to adequately feed, water and generally care for the health and well-being of their animals. Because the consequences of an escape of a dangerous animal are potentially high, even though the likelihood may be low, organisations exhibiting animals also have a high financial incentive to avoid civil litigation for damages. 4.3 Evaluation of optionsThe assessment of the costs and benefits of the proposed regulations and the policy alternatives will be conducted by discussing each option in terms of its expected incidence and distribution of costs and benefits, relative to the ‘base case’ (defined in Part 4.2 of the RIS). The data used in this analysis and the assumptions and qualifications to the data on which the costs and benefits have been estimated are provided in the appendices. In order to consolidate the analysis by removing duplication and thereby making the options easier to compare, the following main benefit and cost features of the proposed national standards are outlined in Part 4.3.1 and 4.3.2, respectively. The discussion of options therefore highlights their differences, thereby avoiding the repetition of text and figures. 4.3.1 Benefit drivers of the proposed national standards – Criteria I and IIThis part of the RIS highlights specific benefit drivers, which underlie the proposed standards. These are identified as unquantifiable benefits in terms of improved animal welfare outcomes, as well as, reduced ecological risks. Reduction in regulatory burden and uncertainty is discussed in general terms with respect to the change in net compliance costs under Criterion III. Drivers of unquantifiable animal welfare benefits – Criterion I There would be additional benefits to animal welfare from training of proficient keepers in terms of improved supervision of animals under proposed standard S1.4 (13, 10 and 28 keepers in large, medium and small facilities, respectively – particularly in VIC, QLD and WA). There would also be improvement of animal welfare by ensuring assessment of proficiency of keepers and hiring of keepers for 1%57 of small facilities for jurisdictions apart from NSW under proposed standard S1.6. Moreover, there would be animal welfare benefits from the development of procedures and plans targeting the risk management of animals including:
Moreover proposed standard S2.13 would entail that 5%58 of all keepers in both medium and small facilities obtain 3.5hrs of training a year in emergency procedures involving evacuations, medical or other animal/non-animal related incidents. This would involve 39 keepers in medium size facilities and 69 keepers in small size facilities with the majority of keepers in NSW, VIC, QLD and WA. Under the proposed standards, there would be a requirement for the additional development of procedures regarding the health, safety and behavioural needs of the animal;
Under proposed standard S3.3, operators would be required to ensure that moats used to contain animals do not cause injury should an animal accidentally fall in; and that they allow the animal to climb out without leaving the enclosure. Moreover if a moat were part of the area used by animals, operators would be required to enable easy entry and exit. This would provide minor welfare benefits to all jurisdictions where moats are used except for NSW, WA with some exceptions for VIC. The number of enclosures that this would affect and size of facilities remains unknown. Moreover under proposed standard S3.6, operators in non-compliant facilities (i.e. affecting animals in 420 non-walk through display enclosures) would ensure that enclosures allow for the expression of appropriate natural behaviours of the animals in those enclosures. However, due to the variability of needs between different species within groupings, it is not possible to estimate the incremental benefit of enclosure modification across the industry in terms of the general standards, apart from noting that the animals in these 420 enclosures would benefit from improved welfare. Under proposed standard S3.22 operators would be required to invest in one-off capital investment in enrichment including toys and furniture that contributes to enrichment of the enclosed animal. This would affect animals in 5%59 of mammal non-walk through enclosures for large, medium and small facilities (other than facilities in NSW and WA where enrichment is already required under the base case). This would affect, 1, 19 and 28 enclosures in large, medium and small size facilities, respectively with the majority of small medium and small enclosures in VIC and QLD. Under proposed standard S3.28 operators (excluding those in NSW, WA and QLD60) would be required to avoid continuously keep an animal in a holding enclosure for a period longer than 90 days. Under proposed standard S3.29 operators would be required to ensure that holding enclosures comply with spatial requirements recommended by relevant taxon standards with animals in 124 holding enclosures affected, as shown in Table 5. Table 5: Estimated number of non-display (holding) enclosures by taxon affected by proposed standard S3.29
Under proposed standard S3.30, operators would be required to ensure that where no holding enclosure spatial requirements are stipulated by relevant taxon standards - that the spatial dimensions of a holding enclosure are a minimum of 1/3 of a non-walk through display enclosure. This would affect non-compliant holding enclosures for species groups (i.e. 5% of enclosures), as shown in Table 6. Table 6: Estimated number of non-display (holding) enclosures by species group affected by proposed standard S3.30
Under Clauses S3.31 and S3.32 operators would be required to ensure that a holding enclosure is not used for routine management to rotate an animal through an enclosure; or alternatively to seek 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. Under proposed standard S10.4 operators, in 5% of medium (i.e. 1) and small facilities (i.e. 9), would be required to ensure that a risk assessment examining the risks to the animals is undertaken for each interactive program and is reviewed on a regular basis. The majority of small facilities would be in NSW, VIC, QLD and WA. Under the proposed standards a number of additional record keeping activities would need to be undertaken by non-compliant operators (i.e. 5% of all operators61). The records of individual animals would assist with monitoring the health and welfare of an animal over time. Such records would provide a better capacity to monitor treatment and address problems both in the short and longer term. These record-keeping requirements would include the operator ensuring that:
This would affect 30, 111 and 279 enclosures in large, medium and small size facilities, respectively with the majority of enclosures in medium and small facilities located in NSW, VIC, QLD and WA. Macropods Under proposed standard S3.2 (macropods), operators of non-compliant macropod enclosures (i.e. 5% of enclosures) would be required to ensure that macropods kept in regions where wild fox populations occur are held within a fox-proof enclosure, apart from NSW, VIC and WA where fox proofing is already required under the base case. This would affect 2, 3, and 19 enclosures in large, medium and small facilities, respectively. The majority of enclosures in small facilities would be in QLD and TAS. Under proposed standard S3.3 (macropods), operators would be required to ensure that a walk-through enclosure housing macropods provides at least one visitor exclusion area where animals are able to withdraw from visitor contact. Proposed standard S3.3 (ratites) has the same requirement for walk-through enclosures housing ratites. These standards would affect non-compliant62 walk through enclosures for macropods and would include ratites excluding NSW and QLD, which have this requirement under the base case. This would affect 1, 1, and 6 enclosures in large, medium and small facilities, respectively. The majority of enclosures in small facilities would be in VIC and WA. Under proposed standard S3.4 (macropods), operators of non-compliant macropod walk-through enclosures would be required to provide visitors with information on appropriate visitor behaviour in the enclosure - apart from QLD where such information is already required under the base case. This would affect 1, 2, and 9 enclosures in large, medium and small facilities, respectively. The majority of enclosures in small facilities would be in NSW, VIC and WA. Under proposed standard S3.5 (macropods), operators would be required to incorporate either a non-climbable enclosure barrier; a 500mm inhang; or a secure roof for enclosures housing macropods capable of climbing such as the musky rat-kangaroo, tree-kangaroo and rock-wallaby. This would provide minor animal welfare benefits to animals in all jurisdictions except for NSW, QLD and VIC where operators do not currently incorporate such features in enclosures. The number of enclosures that this would affect and size of facilities remains unknown. Under proposed standard S3.7 (macropods), operators would be required to ensure that display and walk through enclosures housing rock wallabies provide physical features including, but not limited to, boulder piles and tree trunks. This would affect 5% of rock wallaby enclosures belonging to medium and small facilities – apart from NSW, QLD and VIC, where such enrichment is already required under the base case. This would affect 2 enclosures in medium size facilities and 10 enclosures in small facilities, respectively. The majority of enclosures in small facilities would be in WA. Under proposed standard S3.8 (macropods), operators would be required to ensure that macropod enclosures meet the minimum floor area requirements specified in Appendix 1 of the proposed standards. This would be relevant for all jurisdictions except for NSW, VIC and QLD where existing codes already specify these requirements under the base case. This would affect 1, 2, and 10 non-walkthrough and walkthrough display enclosures in large, medium and small facilities, respectively. The majority of enclosures in small facilities would be in WA. Under proposed standard S5.1 (macropods), operators would be required to ensure that macropod enclosures provide elevated positions where all animals in the enclosure can avoid wet, boggy conditions. This would be relevant for all jurisdictions excluding NSW, VIC, QLD and WA - which have this requirement under the base case. This would affect 1, 1, and 4 enclosures in large, medium and small facilities, respectively. The majority of enclosures in small facilities would be in TAS. Under Clauses S6.1 and S8.1 (macropods), operators of 1 medium and 6 small facilities63 would voluntarily develop maintain and implement:
Under proposed standard S11.1 (macropods) the operator would be required to ensure macropod transportation containers do not have slatted floors providing for more appropriate transport arrangements. The benefits in terms of numbers of animals affected by proposed standard S11.1 remains unquantifiable as the number of containers typically used for macropod transport in jurisdictions, or Australia for that matter, is unknown. Crocodiles Under proposed standard S1.2 (crocodiles) there would be a requirement for operators to develop maintain and implement written procedures for keepers undertaking hand feeding procedures. This would affect 3 small size facilities and 1 medium size facility. Under proposed standard S5.4 (crocodiles) there would be a requirement for 3 small and 1 medium size facility operators in NSW, VIC, QLD, WA, SA, NT, TAS, and ACT to develop maintain and implement written procedures to confirm equipment is functioning properly and temperatures adjusted as necessary where any artificial means of heating is required for land areas or ponds. Under the crocodile taxon standards the operator would also be required to ensure:
i. one horizontal surface dimension 4 x snout-vent length of the longest crocodilian it houses; and ii. one area with a minimum width of 1 x snout-vent length of the longest crocodilian in the enclosure. This width must cover the horizontal dimension calculated in 3.5.i.
i. a minimum of 200 mm of water covers their highest point; or ii. a depth of water equivalent to 0.2 x snout-vent length covers their highest point (proposed standard S3.6) (except for QLD)
i. 2.5 x snout-vent length long; and ii. 1.5 x snout-vent length wide (proposed standard S3.7) (except NSW).
This would affect holding enclosures for individual crocodilians for facilities in all jurisdictions except for NSW. This would affect 3, 10, and 4 enclosures in large, medium and small facilities, respectively. The majority of enclosures in small and medium facilities would be in VIC, QLD and WA. With respect to protecting crocodilians from extreme temperatures, this would affect all jurisdictions including NSW and would impact on 3, 14 and 6 enclosures in large, medium and small facilities, respectively. The majority of enclosures in small and medium facilities would be in NSW, VIC, QLD and WA. Under proposed standard S6.2 (crocodiles) there would be a requirement for 3 small and 1 medium size facility operators in NSW, VIC, QLD, WA, SA, NT, TAS, and ACT to develop maintain and implement written procedures to enable the collection of eggs. Ratites Under proposed standard S3.4 (ratites), the operator would be required to ensure ratite display enclosures included a species appropriate wallow64. Proposed standard S3.5 (ratites) would require operators to ensure that cassowaries are provided with shade. proposed standard S3.6 (ratites) would require operators to ensure ratite enclosures meet the minimum floor area requirements. These clauses would apply to 5% of ratite enclosures apart from QLD where this is required under the base case. This would affect 1, 3, and 5 enclosures in large, medium and small facilities, respectively. The majority of enclosures in small and medium facilities would be in NSW, VIC and WA. Under proposed standard S6.1 (ratites), an operator would be required to ensure that written procedures are developed, maintained and implemented for the collection of eggs. This would affect 5 small and 1 medium size facilities. Koalas Under proposed standard S3.3 (koalas), the operator be required to ensure a minimum of two resting forks, one at least 1800 mm above the ground and one at least 1500 mm above the ground, are provided for each independent koala in an enclosure. With holding enclosures containing a single koala it would need to contain a minimum of one resting fork unless otherwise prescribed by a veterinarian. Animal welfare benefits would apply to 5% of display and holding enclosures except for NSW and QLD where this requirement exists under the base case. This would affect animals in 1 to 2 enclosures in a medium facility with the majority of medium facilities in VIC and WA. Under proposed standard S3.8 (koalas), the operator would be required to ensure a koala in a fully enclosed enclosure can perch in the highest fork without being restricted by the ceiling of the enclosure. Also under proposed standard S3.9 (koalas), the operator would be required to ensure holding enclosures provide sufficient height above the resting fork(s) to: i. allow the koalas to sit upright; and ii. provide clearance from enclosure barriers to allow the koalas to rest without contacting the barriers. An incremental benefit would apply to all jurisdictions except NSW (as height requirements already apply to this jurisdiction under the base case). This would affect animals in 7 enclosures in large facilities and 67 enclosures in medium facilities and with the majority of medium size facilities in VIC, QLD and WA. Under Clauses S3.6 and S3.7 (koalas) the operator would be required to ensure koala enclosures meet the minimum floor area requirements specified. Proposed standard S3.6 would be relevant for all jurisdictions except for QLD where existing codes already specify these requirements under the base case and proposed standard S3.7 would be relevant for all jurisdictions except for NSW. Furthermore, under proposed standard S5.2 (koalas) the operator would be required to ensure that all koalas within an enclosure are able to simultaneously access shade at all times and would provide additional benefits to all jurisdictions apart from NSW. These clauses would affect 2 enclosures in large size facilities and 13 enclosures in medium size facilities – with the majority of medium size facilities in VIC, QLD and WA. Under proposed standard S5.1 (koalas), the operator would be required to ensure that each koala is weighed at least monthly as part of routine health monitoring. Under proposed standard S10.7 (koalas), the operator would be required to ensure that each koala used for handling is weighed a minimum of fortnightly to confirm: i. maintenance of body weight in mature adults; or ii. appropriate rates of growth in juvenile or sub-adult individuals. Under proposed standard S10.9 (koalas), the operator would be required to ensure that records of koala identification and handling times are kept daily in a consistent format and retained on file for the life of the animal plus two years. Furthermore under proposed standard S12.1 (koalas), the operator would be required to ensure that the weight of individual koalas is recorded monthly in accordance with proposed standard S5.1 of these standards. Finally, under proposed standard S12.2 (koalas), the operator would be required to ensure that the handling of each koala is recorded. These records would include: i. date of handling; and ii. handling time; and iii. the keeper who handled the koala; and iv. purpose of handling the koala; and v. any adverse behaviours of the koala before, during and after handling. These aforementioned Clauses regard record keeping (i.e. Clauses S5.1 to S12.2) would affect koalas in 1 enclosure in a large size facility and 5 enclosures in medium size facilities and with the majority of medium size facilities in VIC, QLD and WA. Under proposed standard S5.3 (koalas), the operator would be required to ensure that newly acquired koalas undergo a minimum 30-day period of quarantine, unless advised otherwise by a veterinarian. Given that this situation occurs randomly the unquantifiable incremental benefit of keeping new koalas in quarantine by jurisdiction remains unknown. Under proposed standard S10.1 (koalas), the operator would need to ensure that written procedures are developed, maintained and implemented for interactive programs utilising koalas and this would benefit animals in 1 enclosure in a medium size facility. Under proposed standard S11.1 (koalas), the operator sending a koala would be required to ensure independent koalas are transported individually. Independent koalas with dependent offspring would be exempt. Under proposed standard S11.2 (koalas), the operator sending a koala would be required to ensure 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. The frequency and incidence of koala transport remains unknown as does the jurisdictions affected. Wombats Under proposed standard S3.3 (wombats), 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 (wombats), 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 (wombats), 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. Under proposed standard S3.6 (wombats), 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). Under proposed standard S3.8 (wombats), 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 proposed standard S3.9 (wombats), the operator would be required to ensure that for each additional adult wombat the floor area is increased by a minimum of ten square metres (except for QLD). Under proposed standard S3.10 (wombats), the operator would be required to ensure enclosures that provide housing for wombats at night time meet all enclosure standards (except for QLD). Finally, under proposed standard S5.2 (wombats), the operator (except for 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 the public.
Under proposed standard S3.6 (macropods) operators with respect to 12.5%65 of enclosures, except in NSW, QLD and VIC, would be required to ensure a fence of at least the following height: i. 1800 mm for large macropods (red kangaroos, grey kangaroos and wallaroos); and ii. 1400 mm for medium macropods (e.g. swamp wallabies, agile wallabies, whiptail wallabies and red-necked wallabies); and iii. 1000 mm small macropods (e.g. mala, bettongs, potoroos, pademelons, musky rat-kangaroos); and iv. 1500 mm non-climbable or 1500 mm wire-mesh with a 500 mm inhang for tree-kangaroos; and v. 2000 mm with 500 mm inhang for rock-wallabies; and vi. unless otherwise approved by the relevant government authority This would affect 5, 9, and 57 enclosures in large, medium and small facilities, respectively. The majority of enclosures in small facilities would be in WA and TAS. Under proposed standard S3.3 (ratites), non-compliant operators would be required to ensure that enclosure barriers for adult ratites provide containment to at least the following height: i. ostriches and cassowaries – 1800 mm; ii. emus – 1500 mm; iii. rheas – 1200 mm.
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