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

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2.2 Policy objective

In relation to the case for action identified in Parts 2.1 and 2.2, the following overarching policy objective is identified:

To meet community values and expectations regarding the welfare of exhibited animals, and associated protection of the environment and agriculture; in ways that are practical for implementation and industry compliance.
The main criterion for evaluating the proposed national standards and the feasible alternatives is net benefit for the community, in terms of achieving this policy objective.

3.0 Alternatives to proposed national standards

In accordance with the COAG guidelines, a RIS is required to identify feasible alternatives to the proposed national standards. Conversely, a RIS is not required to identify alternatives which are not practicable, or where there are no significant cost burdens being imposed.

Having no standards at all is not a feasible option, because some jurisdictions already have their own standards as part of the base case; and it is outside the scope of this RIS to consider revoking individual state or territory standards.

Education and publicity campaigns attempting to raise awareness regarding the welfare of exhibited animals have been conducted over several years by a number of animal welfare lobby groups. The national industry body, ZAA, has also established accreditation criteria which involve policy statements, publications and accreditation criteria and guidelines. Industry bodies like ZAA and the NSWFMPA also involve their membership in commenting on proposed standards and legislation. However despite being aware of their existence, many exhibitors have not elected to join such industry groups and take advantage of the education opportunities already available. In some cases, even members of some of these industry bodies have chosen to ignore the advice available.

This experience has shown that public education campaigns as an alternative to national standards are not likely to be effective and therefore not a feasible alternative. The behaviours that need to be changed are displayed by a minority of exhibitors, most of whom are already aware of the risks to animal welfare and the environment and agriculture associated with their exhibits. These exhibitors are much less likely to be influenced by public education campaigns than by enforceable standards.

Better enforcement of existing standards has also been considered as an alternative. However, as shown in Part 2.1. and Appendix 1 of this RIS, there are so many deficiencies in existing standards, particularly in jurisdictions other than NSW and QLD, that this alternative would not solve the problems that have been identified, even if enforcement was 100% effective. Also, the guidelines in codes of practice are not enforceable.

The possibility of improving compliance by ‘naming and shaming’ exhibitors who do not comply with codes of practice has also been considered. For example, the NSW Food Authority website publishes the names of people who have been issued infringement notices by inspectors (as well as the outcomes of prosecution proceedings). However, because the codes of practice would not be mandatory, animal exhibitors would not be prosecuted for any offence. They would therefore be denied an opportunity to defend their reputations in court or in other public forums. It would not be sufficient to rely on the media to fairly present both sides of the story; and thus injustices could occur. It appears ‘naming and shaming’ could be useful as an adjunct to a system based on mandatory standards but is unlikely to be seen as just where adherence to codes of practice is voluntary.
Having more comprehensive standards e.g. more taxon standards is not currently a feasible option either, because the necessary research, standard development and key stakeholder consultation has not yet been done. The development of certain taxon standards may not be feasible for some years.
The practicable alternatives below have emerged from discussions with the Expert Consultative Forum (ECF) referred to in Part 1.3 of this RIS. The suggested variations to the proposed national standards are those where standards are likely to be costly and/or contentious amongst stakeholders. The public consultation seeks the views and advice of interested parties in the further formulation of variations to the existing proposals. Selected additional variations may be investigated and reported in the decision RIS.
At an earlier stage in the preparation of this RIS, a variation of the proposed national standards was considered to amend General Standard S2.1 to ‘The operator of a facility must ensure: a) the facility has a secure perimeter fence; and b) that each enclosure containing a dangerous terrestrial animal or a terrestrial animal of a species of serious or extreme risk to agriculture or ecosystems is surrounded by a secure secondary enclosure that will act as a barrier to the animal.’ This variation was proposed as a possibly less costly alternative to upgrading perimeter fences. However, after further consideration, this alternative has been addressed by changing the definition of ‘perimeter fence’ as secure secondary enclosures are considered unnecessary and impractical.

The practicable alternatives together with the proposed national standards will from here on be referred to as ‘options’. The options to be assessed in terms of costs and benefits are:

  • Option A: converting the proposed national standards into national voluntary guidelines (the minimum intervention option);

  • Option B: the proposed national standards as currently drafted;

  • Option C: one or more variations of the proposed national standards as follows:

  • Option C1: amend proposed Macropod Standard S3.2 regarding fox-proof fencing to allow for alternative fox management measures such as baiting (records of measures to be kept by operator). i.e. require fox-proof fence or effective alternative.

    • Option C2: amend General Standard S3.28 to state a maximum period in a holding enclosure of 30 days without government approval instead of 90 days.

Each of these options and variations is likely to entail a different combination of incremental costs and benefits, as discussed in the following impact analysis, where information on their meanings and implications is also provided.
Interested Australians are now being asked via this Consultation RIS to consider the costs and benefits of each option and whether they are willing to accept the costs of meeting community values and expectations.

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