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ANALYSIS OF RESPONSES TO THE CONSULTATION DOCUMENT 'PROPOSALS TO REVISE EXISTING ANIMAL WELFARE LEGISLATION'
Reactions to the consultation
(1) The view of SEERAD
The consultation exercise targeted a wide audience and was intended to cover all the specific sectors with an interest in any or all the 19 subject areas of the consultation document. A high number of responses were received to the written consultation paper. SEERAD was content with the responses, both in terms of quantity and quality. It was evident that a number of responders, especially key players in animal welfare in Scotland and throughout Britain, had taken much time and effort to carefully consider the different subject areas and this was reflected in the quality of their responses. SEERAD acknowledges and appreciates the time and effort which has been given to the proposals.
A large volume of detailed evidence was produced across a wide range of sectors. The extent of this evidence varied according to the degree of engagement and expertise with the subjects of the respondents. The evidence related to the proposed bill, to secondary legislation which is likely to be made under it, licence conditions and codes of practice.
A subject by subject analysis of the consultation responses has been undertaken and this approach has enabled SEERAD to record the views of the responders who have wished these to made available to the public. This approach also allows the views of all responders to a single subject to be brought together so that any differences between sectors or within a sector can be identified. It also gives a systematic analysis of the evidence that has been provided and to gauge the level of support for each issue.
The analysis has included extracts of evidence which has been provided by responders. This will help gauge the exact views of the responders and to note the strength of their feelings to specific proposals. The names of each organisation and business has been included after each extract of evidence. However, individuals have not been identified, with the exception of Mr Mike Radford, a specialist in animal welfare law at Aberdeen University.
The Scottish Executive has taken every effort to ensure that the views of the responders have been properly represented.
(2) The view of the responders
A small number of comments, both positive and negative, were made on the consultation process itself. These will be taken into account for the next phase in the development of the legislation. The small number of negative comments will be dealt with first. A very small number of responders expressed their disappointment, in writing or by telephone, to SEERAD that they were not included on the initial list of consultees. In all cases, a copy of the consultation document was immediately sent to them. In a number of further cases, a responder who noted that they were not on the mailing list had their name added to it. A few responders telephoned to suggest additional organisations that should be included in the consultation, and copies of the document were sent to them.
There were very few indications that the list of consultees had not been properly targeted. Two organisations responded to state that they were not directly involved in the subject area of the consultation. Youth Link Scotland noted that 'animal welfare is not an area … which … has a direct interest or involvement'. The Scottish Police Federation had 'no issues which concern us' and also 'no enforcement issues which concern us'. A local enterprise company, noted that it was not responding to the consultation document. Few telephone calls or correspondence were received which suggested that the mailing list had been inaccurate. Any such details were amended.
A small number of responders commented on the general content of the consultation document. However, only a few were critical. The Pet Care Trust suggested that it was written by welfare groups, while the Scottish Gamekeepers Association considered that 'some of this document reads as though it was written by animal rights groups'. Three responders were critical of the scope of the proposals. Central Scotland Police suggested that 'it seems strange that the consultation goes into great depth for DWA, but scarcely mentions the dog breeding, boarding and riding establishment licences, all of which need reviewing, and which form the "bread and butter" of local authority licences. These are dealt with on a daily basis, and no doubt the licensing authorities will welcome this opportunity to comment of the review of these pieces of legislation'. The Scottish Hawk Board stated that 'Your consultation document has been written to lead us into agreeing with your line of thought, as your basic comments appear logical and end with "Do you agree?" The result is that you will be able to conclude that we and the rest of the consultees agree with these changes. In fact you suggest legislating for every aspect of animal involvement with "man" from the cat on your lap to the sheep in your dreams! If all your suggestions were incorporated into law, the net result would be that animals have more rights than humans. We are worried that if these well-meaning but poorly conceived proposals become law, vast numbers of innocent raptor keepers and other animal and bird owners, including pet owners, would unwittingly find themselves breading the law'. The Pet Care Trust, critically pointed out that the 'Executive has taken on a considerable amount of proposals put forward by Defra'.
A very small number of negative comments were also received about the consultation meetings, especially the open ones. The most common one concerned the publicity of the events. A few people telephoned SEERAD to comment that the open meetings were not well publicised and that they had heard about them by word of mouth. These had been publicised by way of a News Release, articles in newspapers and targeted letters to organisations. Letters of invitation were issued in sufficient time to allow them to inform any further interested parties of the meetings. However, one canine organisation informed its members of the open meetings in such a way that some of its members had been informed of them in time, others did not receive their letter with sufficient notice to allow them to attend, and in some instances further members received the letter after the meetings had taken place. This led a number of that organisation's members to complain to SEERAD about the lateness of the letter they had received from their organisation. A number of comments were also received about the timing of the open meetings. Some felt that afternoons were not the most suitable time to hold a public meeting as this excluded people who were at work. At the Aberdeen open meeting a petition was handed in to SEERAD officials which listed the name of 21 individuals who could not attend due to work commitments, and who would have liked to do so. A few telephone calls were received which stated that people could not organise their work at short notice so that they could attend a meeting. One letter from an MSP pointed out that no meetings had been held in the south-west of the country. Consideration is being given to schedule future public meetings in the evenings so that members of the can have greater access to them and whether they should be extended over a greater geographical area.
However, the greatest number of comments received on the consultation process were very positive and supportive and were specific about the different stages of the consultation process. For example, The Home of Rest for Horses commented on the 'excellent consultation document'. Four letters were received from people who attended open consultation meetings in Edinburgh, Glasgow, and Inverness which expressed favourable comments about them, including the standard of the presentation and the patience and helpful team members. One found one of the meetings to be 'most useful and the discussion sparked off a number of thoughts on the subject'; another commented that the session was 'very interesting'. General discussion among the attendees after the focus group sessions suggested that they found them to be very useful and constructive. They felt that they had the opportunity to contribute fully. A number of attendees, as also responders, warmly welcomed the opportunity to engage closely with SEERAD and meet officials and be part of the consultation process. One wrote to express thanks 'for the opportunity to discuss the proposed animal welfare legislation yesterday in Inverness'. Attendees also congratulated the SEERAD team leader on his patience in chairing a small number of difficult sessions such as the focus group on tail docking.
Covering letters frequently noted the attitudes of the responders to the consultation process. Organisations and individuals stated that they were pleased to be consulted on the written proposals. Others welcomed the opportunity to respond (e.g. BASC Scotland, British Greyhound Racing Board, British Horse Society, The Brittany Club of Great Britain, Council of Docked Breeds, Dogs Trust, The Home of Rest for Horses, Mossburn Animal Sanctuary, National Working Terrier Federation, NEWC, PDSA, Scottish Agricultural College, Scottish Countryside Alliance, Scottish Rural Property and Business Association and Union of Country Sports Workers). Others also stated that they were willing to respond further to the consultation or any other related matter (e.g., Royal Association of British Dairy Farmers). Responder forms also confirmed the willingness of the responders to participate further in the consultation process. There were relatively few restrictions placed on the responses, and only a small number of responders wanted their response to remain anonymous, or for it to be confidential.
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