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An overview of the consultation

The Scottish Executive issued the draft Animal Health and Welfare (Scotland) Bill consultation on 16 May 2005.

The proposals in this consultation build on earlier consultations of the Scottish Executive's policy intentions. On Part 1 of the Bill, the animal health proposals, a consultation was issued on 28 February 2003 which proposed to amend the Animal Health Act 1981. That act currently provides the legal base for the response to exotic disease outbreaks. The proposals in the Bill draw on the experiences and lessons drawn from the Foot and Mouth Disease ( FMD) outbreak in 2001. In addition, they take into account developments in veterinary and scientific knowledge. For example, Transmissible Spongiform Encephalothopies ( TSEs) were unknown when the 1981 Act came onto the statute book.

On Part 2 of the Bill, the animal welfare proposals, a consultation was issued on 31 March 2003. The proposals in this consultation aimed to address a specific problem of the lack of statutory powers available to local authorities to remove neglected farm livestock which were at risk of suffering. A number of responses clearly demonstrated that there was a need for a wider reform of existing animal welfare legislation. As a result, Scottish Ministers agreed to expand the scope of the proposals and to undertake a wider review of the existing animal welfare legislation. A further consultation was therefore issued on 31 March 2004. It raised a series of questions which focused on 19 topics relating to the existing animal welfare legislation, and gaps in that legislation, on the welfare of all animals (including domestic ones) for which man is responsible, including managing, or in any way keeping an animal, such as buying, selling and transporting. The responses to that consultation, to which 325 were received, were published as "Analysis of responses to the consultation document 'Proposals to revise existing animal welfare legislation'", on 28 February 2005. That document confirmed there was a widespread belief that there was a need to modernise and update the existing animal welfare legislation.

The most recent consultation, of 16 May 2005, on the draft Animal Health and Welfare (Scotland) Bill, listed 17 questions on the animal health provisions and 26 questions on the animal welfare provisions. The consultation period extended to 4 July. In response to a small number of inquiries, a number of organisations submitted their responses after the closing date, and these were accepted and have been included in the consultation analysis.

The consultation was announced be means of a Parliamentary Question and a Scottish Executive News Release, a press conference and Ministerial visit by Ross Finnie, MSP, Minister for Environment and Rural Development, to the Scottish Society for the Prevention of Cruelty to Animals (Scottish SPCA) Animal Welfare Centre at Mansefield, Balerno. The consultation document was published on the Scottish Executive website and published copies were sent to a large number of organisations and individuals who included all the responders to the earlier consultations. Copies were also sent to the Cross-Party Group on Animal Welfare in the Scottish Parliament, the Clerk of the Environment and Rural Development Committee in the Scottish Parliament, SPICe Library, also in the Scottish Parliament, the Scottish Executive Library and the legal copyright libraries in Great Britain and Ireland.

The consultation was widely circulated. A total of 2,245 copies of the consultation document were issued and distributed during the consultation period. At the launch of the consultation, 1,575 copies were issue. A total of 56 consultees received more than one copy, reflecting the structure of their organisation. This figure does not include the statistics for local authorities, each of which was sent a number of copies to a range of appropriate departments and their officials.

Consultees included public bodies such as local authorities, police forces, other enforcement bodies, animal welfare organisations, businesses involved in animal health and welfare, agricultural and rural interests (such as farming organisations, shooting, and markets), abattoirs and slaughterhouses, animal transporters, and the veterinary profession. Others were disability groups (especially those which use assistance animals), equality organisations, the voluntary sector and young people.

During the consultation period, a further 56 copies of the consultation document were issued to other individuals and organisations that had been omitted from the consultation list. The remaining copies were distributed at the consultation meetings and at the Royal Highland Show.

In addition to the written consultation paper, some 4 public meetings took place between 15 and 21 June 2005. These were held in Inverness, Aberdeen, Glasgow and Edinburgh. All were held in the evenings, with the aim of encouraging the public to attend. The timing of these events also addressed criticisms which had been made of the afternoon meetings during the welfare consultation in 2004. These evening meetings were open to all interested individuals, businesses and organisations. Attendees were asked to comment on all aspects of the proposals in the draft Bill.

These meetings were advertised through the letter to consultees issued with the consultation document. This drew attention to the meetings and the arrangements for them. They were also noted in a number of documents which announced the launch of the consultation such as the Parliamentary Question, the News Release and Ministerial launch of the consultation.

The consultation was reported in a range of media. The Ministerial launch on 16 May generated a considerable amount of media attention, especially in the days immediately following it. The media interest reported its subsequent launch, the support of it, and noted its proposals:

Radio programmes

BBC Good Morning Scotland - 16 May
Radio Scotland - lunchtime - 16 May; Scotland Today - lunchtime (Twelve 2 Two - 60 minutes from 12:00) and Scotland Today ( PM) 17 May
Real Radio - lunchtime - 16 May
Radio Forth - lunchtime - 16 May
Kingdom FM - 16 May
BBC Newsdrive - PM 16 May

Websites

BBC News Scotland ( www.bbc.co.uk/)(16 May, 17 May)
Advocates for Animals ( www.advocatesforanimals.org.uk/)
NFU Scotland ( www.nfus.org.uk/uk)

Television: news programmes

Grampian TV - lunchtime - 17 May
Reporting Scotland - PM - 17 May
Borders TV - 16 May
Grampian TV - 16 May

Newspapers

Courier - 17 May (2 articles)
Daily Express - 17 May (editorial and article), 18 May
Daily Mail - 17 May
Daily Mirror - 17 May
Daily Record - 17 May
Daily Star - 17 May (editorial and article)
Edinburgh Evening News - 16 May
Herald - 17 May (2 articles)
Metro - 17 May
Press & Journal - 17 May
Scotsman - 17 May (2 articles)
The Sun - 17 May
The Times - 17 May

Specialist press

Farmers Guardian - 20 May
Scottish Farmer - 21 May (2 articles)

A total of 166 written responses were received to the consultation. Responses received after the closing date of 4 July 2005 are also included in this figure and this analysis. (142 responses were received before the deadline).

Responders were issued with responder forms which indicated how they would like their responses to be dealt with. Returned forms indicated that the responders wanted their responses to be used in a number of ways. A total of 141 responders returned this form, leaving a total of 25 who did not, and have thus not indicated how they wanted the Scottish Executive to deal with their response. As in the welfare consultation of 2004, it has been assumed that these responders were content for their response, and their name and address to be made available. Six responders wanted their contribution to remain confidential The responders who wished their responses to be made public have indicated that their responses should be dealt with in the following ways:

• 108 individuals and organisations wanted their response to be made available, and agreed that their name, address and response could also be made available. (A further 25 did not return their form, and it is also assumed that they will fit into this category)
• 10 responders wanted their response to be made available, but not their name or address.
• 17 individuals wanted their response and name to be made available, but not their address.

Copies of all responses which have been made available under these points, are available for public inspection at the Scottish Executive Library, Saughton House, Broomhouse Drive, Edinburgh, EH11 3XD. Copies of responses can be viewed by visiting the library or can be provided by post. Charges for photocopies are made on a cost-recovery basis. To request copies by post and enquire about charges or make an appointment to view responses, contact the library on 0131 244 4552.

This analysis of responses is also published on the Scottish Executive website at www.scotland.gov.uk/publications. Hard copies and electronic links to the website have been sent to responders. Further copies are available from SEERAD.

(1) The published consultation document

The consultation was sent to a range of parties interested in animal health and animal welfare:

• Individuals, businesses and organisations located in Scotland whose membership or jurisdiction extended throughout the country or part of it.
• Businesses or organisations in England with a British or United Kingdom wide jurisdiction.
• Organisations located in England which should be aware of the Scottish proposals.

A total of 166 responses were received; 117 from Scotland, 9 from England and Wales, 2 from Australia and a further one from New Zealand. The remaining responders did not state their place of residence or business. They usually submitted their response by email. From Scotland, 79 responses were received from organisations, and 38 from individuals.

A total of 112 responders wrote on behalf of organisations or businesses; the majority fell into the former category. A further 54 responses were from private individuals.

The largest number of responses were received from enforcement (16), animal welfare (29), agricultural (8) and canine organisations (16). A small number of responses were received from the following sectors: veterinary (2), legal (1), pet (4), country sports (5) and fisheries (2). These were specialist sectors which would only be affected by certain parts of the proposals in the Bill.

While response rates between the different sectors varied, responses were received from the main stakeholders that would be affected by each of the animal health and animal welfare proposals. Animal welfare was especially well represented by general animal welfare organisations, organisations that focus on a particular species or activity, also sanctuaries, re-homing centres, and lobbying groups. The country sports sector was represented by the major players within this sector: Scottish Gamekeepers' Association, the Game Farmers' Association, the Game Conservancy Trust, BASC Scotland (British Association for Shooting and Conservation) and Union of Country Sports Workers. There were, however, a few gaps in the responders. One of these is within the veterinary organisations, of which only BEVA (British Equine Veterinary Association) and the British Veterinary Association - Scottish Branch responded; only one veterinary surgeon responded.

(2) The consultation meetings

As note above consultation meetings were held in Inverness, Aberdeen, Glasgow and Edinburgh. These were chosen as central meeting points that were easily accessible to urban and rural communities throughout the country. All meetings were held in the evenings, starting at 7.30pm.

The attendance at the consultation meetings is noted in Table 1. Attendance varied between locations, with numbers ranging between 10 and 46 attendees. There was a mixture of private individuals and representatives of organisations. The latter group was more prominent, especially at the meeting in Edinburgh. It was not uncommon for more than one member of an organisation to attend, such as the Scottish SPCA, and for organisations which extended throughout the country, to have representatives at more than one meeting. The represented organisations included the Scottish SPCA, Advocates for Animals, Highland Veggies & Vegans, Pets at Home, Pet Care Trust, Council for Docked Breeds (members). local authorities, and a number of dog breed organisations.

Table 1. Attendance at the consultation meetings

The quality of discussion at each of the meetings was very high. While the meetings were open for comments on both the health and welfare proposals in the Bill, the majority of the time focused on the welfare proposals. This was not surprising as the majority of the attendees represented welfare interests. Nevertheless, Scottish Executive officials ensured that any attendees who had comments on the health proposals had the opportunity to make them. The meetings raised a wide range of subjects. These included:

• The timetable for the Bill, the secondary legislation and the codes of practice;
• The legislation which will be repealed by the Bill;
• The scope of the policy on the vaccination of animals;
• The need to include horse diseases in Part 1;
• Licensing of animal gatherings;
• Slaughter of diseased animals;
• Relationship of the policy in the Defra Animal Welfare Bill and the Scottish Executive Animal Health and Welfare (Scotland) Bill;
• Species of animals covered by the health and the welfare proposals;
• Definition of the person who is responsible for animals under section 16;
• The character and liability of people appointed as inspectors under section 46;
• Licensing of animal sanctuaries and pet shops;
• The provision of care sheets in pet shops;
• The scope of mutilations and cruel operations;
• Prohibition on the keeping of certain animals;
• What constitutes "normal behaviour" in section 22;
• Transportation and sale of puppies.

The consultation document was split in two, reflecting the structure of the Bill with its two parts. Each part had its own series of questions, 17 on the animal health provisions and 26 on the welfare ones. These questions focused on the two sections of the Bill and were arranged according to their sequence. The consultation document was written in a format which would promote consistency in the structure of the responses. The letter to the consultees asked them if they would clearly indicate in their response which question or parts of the consultation document they were responding to, as this would aid the analysis of the responses. Indeed, many of the responses followed the format of the questions and discussed them under the various question numbers, or referred to the relevant sections of the draft Bill. However, some also responded on a small number of issues, but did not specifically indicate the question number or the section number in the Bill.

Responses ranged from short letters, under a page in length, to long discussion papers, and in one case, a piece of commissioned research. In a few instances, responders also included supporting attachments which included guidance documents, videos and DVDs.

The questions generally encouraged responders to submit relatively short responses. A large number simply noted whether they agreed or disagreed with the questions. Sometimes, they also offered additional comments. Others gave a detailed comment on each proposal, in some cases extending to a very comprehensive statement. This form of response facilitated the task of analysing the responses as well as identifying areas of concern, and highlighted any changes that required to be made to the Bill before it was to be introduced into the Scottish Parliament.

However, not all responders specifically commented on the questions which were asked in the consultation document. Some commented on subjects that would be dealt with under the secondary legislation in the welfare part of the Bill or on other animal welfare subjects which were not included in the scope of the Bill. These are noted at the end of the analysis document. In addition, some responders did not directly answer the question that was being asked, but commented on the aspects of the subject.

The subject which attracted most comments, but was not mentioned on the face of the Bill, or in any of the consultation questions, was tail docking dogs. This was a subject which was reported in the Annex of the draft Regulatory Impact Assessment.

A relatively small number of individuals, businesses and organisations answered on only one, or a small number of questions. The individuals who wrote on one issue tended to comment on tail docking in dogs. Most organisations and businesses wrote on all of the questions, either in the health part of the Bill, or the welfare part. Some responders, especially organisations, answered questions only on the welfare part of the Bill, and others commented on areas which were of concern to them and which also affected their organisation and its membership. Many of the responders who answered on a specific part of the Bill, or specific questions within a part, stated the reasons why they were doing this. Organisations also gave information about themselves and their work so that they could place their response within an organisational context.

The majority of responses reflected the views of specific individuals, business and organisations. However, a number of collective responses were also received:

• Two responses took the form of a circular letter. This was part of a campaign organised throughout Great Britain by the Anti-Docking Alliance on tail docking and mutilations. An earlier form of this letter was circulated during the welfare consultation in 2004. The letter received during the latest consultation had been circulated for a few months and additional copies had been received by the Scottish Executive Animal Health and Welfare Division both before and after the consultation period.
• The same response was submitted by 2 organisations. The response from the Society of Chief Officers in Trading Standards in Scotland was identical to that of CoSLA (Convention of Scottish Local Authorities).
• A number of responses had been circulated among responders who drew upon them and sometimes expanded on the comments that had been made in them. The response from Highland Council was expanded upon in the one received from CoSLA. The response from the Game Farmers' Association was drawn upon by the Scottish Gamekeepers' Association.
• A small number of responses commented on the views that had been made by another organisation. They usually noted that they agreed or disagreed with the recommendations and conclusions that they recorded in their response. This was especially noted in the response from Advocates for Animals. A number of individuals who were members, or had affiliation with this society mentioned the name of this organisation as well as other welfare organisations such as West Lothian Animal Rights & Veggies. Advocates for Animals also published its response on its website at:

http://www.advocatesforanimals.org.uk/campaigns/political/scotland08.html.

In addition, the Independent Weimaraner Rescue & Rehoming Service also referred to the response of The Kennel Club.

• No petitions were received.

Table 2 shows the number of responses to each question in Part 1 and Part 2 of the consultation document. In total, 71 responders commented on the animal health provisions and 156 commented on the animal welfare provisions. Of these, 66 commented on both. Four responders noted that they were not commenting on the consultation.

The welfare part of the Bill received a higher number of responses than the health part. It had between 34 and 88 responses for each question. The question which received the highest number of responses was that of mutilations. A large number of responses to this question specifically dealt with tail docking of dogs, though there was no specific question given on this. The other questions had between 35 and 67 responses.

On the health side, each question had between 28 and 51 responses. The subject which received most attention, that of animal gatherings, caused some confusion among keepers and owners of companion animals who believed that events such as dog shows would be covered by this provision.

Table 2: Number of responses to each question in the consultation document

(1) The view of SEERAD

The aim of the consultation was to target a wide audience. A relatively high number of responses were received to the consultation, especially when it is considered that the proposals had already been consulted on the animal health side in 2003 and on the welfare side in 2003 and 2004. SEERAD was content with the quality and quantity of the responses. It was clear that many responders had taken much time and effort to consider carefully the questions in the consultation document. This was reflected in the quality of their responses, some of which made a number of very valuable comments. These have been of great help in making improvements to the Bill before it is introduced into the Scottish Parliament.

As with the earlier consultations on the proposals, SEERAD continues to acknowledge and appreciate the time and effort which responders have given to the proposals and their development.

(2) The view of the responders

A number of the comments which were made during the welfare consultation in 2004 were taken into account and arrangements for the consultation process were modified.

Responders were generally content with the consultation process. Two comments emerged from consultees: The first was that a small number of organisations were omitted from the consultation list. In all cases, a copy of the consultation document was immediately sent to them, and their name was also added to the mailing list. These organisations tended to be specialist ones, interested in one species of animal, such as rabbits. Second, a number of comments were made, both at the consultation meetings, and in responses, that the consultation period of 8 weeks was too short. A couple of organisations noted that it was difficult to circulate the consultation document to their members within this timescale or to meet other members to discuss the proposals. The covering letters of a few responses indicated that committees which met at monthly, or more infrequent intervals, had found it difficult to collate their comments, but endeavoured to pull together a number of points which they considered to be significant.

There were very few indications that the consultation list had not been properly targeted. One organisation, RICS Scotland (Royal Institution of Chartered Surveyors in Scotland), submitted a response to state that it was unable to comment on the consultation. However, it did note that the policies in the Bill were clearly an area of importance. One Government agency, SEPA (Scottish Environment Protection Agency), noted that it had no comments to make on the Bill. SNH (Scottish Natural Heritage) sent in two responses, of which one had no comments. One individual submitted a response, noting that he would send a further detailed one, but this was not received. At least two organisations which were involved in rabbit welfare noted that they had not seen the earlier consultation and pointed out this omission.

In total, 120 of the 166 responders to the consultation were recorded on the list of consultees who were issued with a consultation document. This leaves 46 responders who were not on the initial consultation list. This indicates that while over 72% of the responses were received from responders whom were directly contacted by SEERAD, there were a significant number of new responders who were brought into the consultation process.

The covering letters of the responses frequently noted the attitudes of the responders to the consultation process. Organisations, businesses and individuals stated that they were pleased to be consulted on the draft Bill. Some welcomed the opportunity to respond. Others stated that they would be pleased if the Executive wanted to contact them on any of the points in their response and indicated that they were willing to respond further on the proposals. This was confirmed in the willingness of responders to be further contacted by the Executive for consultation or research purposes, and in them making their views available for public circulation. There were relatively few restrictions placed on the responses and only a very few wanted their identity to remain anonymous, or for their response to be confidential.

Some general views

A number of the responders commented on the broad scope of the proposals in the Bill. Some of their views are noted below. These show that they considered that the Bill would have a positive impact on animal health and welfare in Scotland. Further, they welcomed the proposals, the document and the chance to comment on it. However, as is also noted below, there was some opposition to the proposals:

• "Association members welcome this new discussion document which seems to cover most of the inadequacies of the present legislation and consolidates much of the necessary legislation to control highly infectious and exotic disease." (British Veterinary Association - Scottish Branch)
• "Would welcome any legal provisions that improve the means of tackling the issues of animal health and welfare. Comhairlie would, by and large, support the provisions therein." (Comhairlie nan Eilean Siar)
• "We are fully supportive of high standards of animal health and welfare, and of effective disease controls and eradication measures. In this context we are in general agreement with the content of the Draft Bill." (Scottish Association of Meat Wholesalers)
• "Welcomes the Scottish Executive's draft Animal Health and Welfare (Scotland) Bill. Scottish SPCA involvement in animal welfare cases exceeds that of SEERAD and local authority witnesses put together. The Scottish SPCA looks forward to a significant role in enforcing the new legislation when it comes into force." (Scottish SPCA)
• "Strongly support the modernisation of existing animal welfare legislation, reducing the impact of infectious diseases and raising standards of animal welfare." (Society for the Protection of Aviculture)
• "The NFU Scotland ( NFUS) view of this proposal is that we broadly support the legislative proposals outlined in the Bill, which aim to:
• • Enhance the ability to respond to exotic (foreign) disease outbreaks;
  • Minimise the risk of disease spread;
  • Introduce a duty of care on keeping animals; and
  • Allow animals either suffering or in danger of suffering to be seized." ( NFU Scotland)
• "Scottish Ministers and officials are to be congratulated for taking this matter forward, and for the quality of the work which has gone into producing this draft Bill. In general terms, the policy represented by the Bill will assist in securing and promoting the protection of animals in Scotland, and is greatly to be welcomed. The drafting and structure of the Bill is of a generally high quality." (Mike Radford, University of Aberdeen)
• "We are pleased to continue playing an active part in the process of developing modern and comprehensive legislation, in relation to the welfare of animals in Scotland." ( IFAW)
• "We very much regret the inclusion of these animal health provisions in what was, until recently, an Animal Welfare Bill as the increased slaughter powers are likely to prove highly controversial and so may overshadow the largely welcome provisions on welfare." (Advocates for Animals) (similar comments were also made by Animal Concern)
• "The draft Bill is more of an animal rights charter than being primarily directed towards improving animal health and welfare." (Teviot Scientific)

Responders such as the Ornamental Aquatic Trade Association also pointed out that their comments from the earlier welfare consultation of 2004 remained the same and were still valid. A number of organisations also welcomed the opportunity to work with the Executive in developing and implementing the legislation, the secondary legislation, codes of practice and to undertake their enforcement. These included the Scottish SPCA, British Horse Society, and The Scottish Hawk Board.

Views on the health provisions

The following are the views of a number of responders on the health proposals:

• "The 2001 Foot and Mouth outbreak highlighted the need for updating parts of the 1981 Act and the importance of having robust legislation in place in order to deal quickly with disease outbreaks as and when they occur." (East Ayrshire Council)
• "Pleased to see that the Scottish Parliament is putting into practice the lessons learnt during recent animal disease epidemics." (Scottish Countryside Alliance)
• "We welcome the proposed Animal Health and Welfare (Scotland) Bill that provides the opportunity to update what is in some cases very old legislation to take account of recent events such as Foot and Mouth Disease outbreak in 2001." (Quality Meat Scotland)
• "It is welcomed that in Part 1 of the Bill the Scottish Executive is attempting to learn lessons from previous disease outbreaks and to enable a swift and uniform response to any further outbreaks." (Scottish Rural Property and Business Association)
• The Environment Protection Committee of Midlothian Council … accepted in full the proposals relating to Animal Health and contained in Part 1 of the consultation document in the form of seventeen specific questions". (Midlothian Council)
• "In 2001 SEERAD, in conjunction with MAFF, were responsible for and caused the most horrendous and unnecessary suffering to animals ever known in Britain and, in the opinion of most people, did so illegally. You now want to pass a bill to legalise killing on a mass scale and include in the list of potential disease spreaders goats, presumably included because the French say they "may" have found one goat with Transmissible Spongiform Encephalopathies. The proposed legislation should be based on a sound scientific basis and not on the flawed science that the 2001 holocaust was based upon. There are many areas of this proposed Bill that cause me concern but for the government of our country to want to give itself the powers for wholesale slaughter is a travesty of all that the animal loving people of Britain hold dear." (Mossburn Community Farm)

Views on the welfare provisions

The following are the views of a number of responders on the welfare proposals:

• "Dogs Trust welcomes the Draft Animal Health and Welfare (Scotland) Bill to update animal welfare legislation in Scotland and congratulates the Scottish Executive in pioneering the introduction into legislation in the United Kingdom a principle of the protection of animals before actual harm has come to them." (Dogs Trust)
• "The Kennel Club welcomes the introduction of the Draft Animal Health and Welfare (Scotland) Bill and the Scottish Executive's intention to consolidate and update existing animal welfare legislation." (The Kennel Club)
• "There are many aspects covered in the draft Bill which will hopefully bring animal welfare into the 21 ^st century." (individual)
• "We believe this represents a sound way forward for improving animal welfare in Scotland. The chance is being sought to modernise the law for the general benefit of society. The possibility of keeping the law updated in the future is a great improvement on the present arrangement." (Pet Advisory Committee)
• "Advocates for Animals welcomes much of Part II of the Bill on welfare." (Advocates for Animals)
• "The Draft Bill sets out a reasonable approach to the welfare of animals in the 21 ^st century." (East Ayrshire Council)
• Please be aware that extreme elements in the Animal Rights Groups wish to use this Bill to ban the keeping of animals and birds of prey by making it impossible to meet the standards it will lay down." (The Scottish Lizard Canary Association)
• It was with some regret that we learned that the vast amount of information, suggestions and advice collated during the initial consultation by SEERAD on the "Proposals to Revise Existing Animal Welfare Legislation" had been condensed into a comparatively slim Draft Bill even though the remit of the Bill had unexpectedly been greatly expanded to incorporate proposals to amend animal health legislation. We are concerned that this may be a cost cutting exercise which will cut too many corners and condense both consultations into ineffective and unworthy legislation unlikely to do much to improve the lot of animals in Scotland". (Animal Concern)
• "Concerned about the lack of detail concerning welfare issues." (Loch Ness Project)

A number of responders agreed with all of the provisions in the Consultation document, or all of those in each of the health or the welfare parts. (The Farriers' Registration Council, Dumfries and Galloway Canine Rescue, Scottish Badgers, BEVA) A few agreed with the broad proposals and also made a number of specific comments. ( OSCAR, Rare Breeds Survival Trust, CoSLA)

The following analysis has been undertaken on a question by question basis. This records the views of the responders who wished their responses to be made available to the public, and who commented on one or more of the proposals. It therefore records the views of
160 responders.

The responses are analysed under each question to gauge the support for each of the proposals. In some instances, responders did not indicate whether they agreed or disagreed with a proposal and simply commented on it. In these cases, the analysis notes that they commented on the proposal. Some responders also agreed to a proposal but noted that they had a reservation to their agreement. Where they stated these reservations, they have been noted. Some responders also indicated that they disagreed with a proposal. Where they noted the reasons for this disagreement, these have also been noted. There are also some overlaps in the comments from those who agreed with a proposal, those who had reservations and those who disagreed with it. It is important to note that in many cases where a responder agreed to a proposal, they simply noted their agreement, and did not make any comments.

The analysis of Part 1, the animal health proposals, notes the numbers of responders to each question and the level of support, as well as comments on the proposals. The identity of the responders has not been stated.

The analysis of Part 2, the animal welfare provisions, notes and groups the responders according to sector, rather than individual organisations, as in the analysis of the 2004 welfare consultation. Table 3 notes how these responders have been grouped together. It is recognised that some groups, such as animal welfare, cover a diverse range of organisations and views, as well as activities. Likewise, veterinary organisations cover professional bodies, from a specialist veterinary organisation to an individual practitioner. This approach has been adopted for the welfare proposals as a wide range of sectors responded and it was important to be able to identify trends between the different groups of responders and any specific concerns which they had.

Table 3: Sectors of responders to Part 2 of the draft Bill

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