DRF response to DEFRA Consultation on Licencing and Breeding March 2016

Here is the response of the Dog Rescue Federation.

The Dog Rescue Federation was formed in 2012 in response to the overwhelming problems being caused by irresponsible dog breeding and ownership.  We represent the concerns of voluntary dog rescuers who operate throughout the UK and handle a significant proportion of the estimated 50,000 dogs abandoned by their owners every year.

In 2013 we conducted a national survey of all local authority dog wardens.  96% of councils in the UK took part in the survey in which they were invited to provide information on a variety of issues ranging from how they manage and organise their dog warden services; what their procedures are for dealing with stray dogs; how much time they spend on dog-related community work and; the number of licensed dog breeding establishments they have and how frequently they inspect them.  The results of the survey were produced in a full report containing a series of conclusions and recommendations. In 2014 we conducted a further survey of local authorities, this time concentrating on the number of stray dogs they handle and what eventually happens to them.

Our main focus of attention is now on so called ‘backstreet breeders’ and we are soon to launch a campaign aimed at making it more difficult for them to operate.  We are placing such emphasis on backstreet breeding because we have good evidence to suggest that most of the dogs that end up in the voluntary sector’s dog rescue centres are bred in this environment.  Larger scale puppy farming, however dreadful this practice is, tends to produce dogs of a particular type and price that will attract buyers who are far more likely to provide long-term care and love. Backstreet breeders cater for a different market, perhaps characterised best by a ‘throw-away’ lifestyle who will give less thought to the purchase of a dog, probably not pay as much for it and be far more inclined to dispose of it when it turns out to be not what they wanted.

The Dog Rescue Federation is alarmed at the scale of dog abandonment in the UK. Some of those abandoned will be lucky enough to find new homes organised by the dog rescue volunteers for whom we provide a voice but too many of these poor dogs will end up being destroyed, simply because the ‘system’ is unable to cope with their numbers.  This dreadful situation is caused almost entirely by the actions of irresponsible dog breeders whose interest in making money totally outstrips any concern for dog welfare. They indiscriminately churn out puppies and sell them recklessly, often to people who are absolutely unsuited to owning a dog or who may not have properly considered the full implications of dog ownership.

The Dog Rescue Federation believes that the best way of solving the problem of dog abandonment and the needless suffering it causes to tens of thousands of innocent dogs each year is to make it increasingly more difficult for so-called backstreet breeders to operate. That is why our number one objective is to make life tough for backstreet breeders and is why our submission to this important consultation is primarily concentrated on the issue of dog breeding licensing and your proposal to set a statutory licensing threshold for dog breeders at three or more litters per year.  You will see that we fundamentally disagree with this proposal and the concept of a threshold limit and would want to see the introduction of compulsory licensing of all forms of dog breeding, irrespective of the number of litters produced by a breeder or purpose.

Question 1: To what extent do you agree or disagree with the proposal to introduce a single Animal Establishment Licence?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation supports this proposal.  We would hope that the introduction of a single licence system would help free-up time to enable local authority licensing officers to concentrate on more proactive enforcement issues, something that we feel is currently being neglected due to its resource implications.  Your intention to clarify that online and home-based business must also be licensed is welcomed although we would need further clarification on how you envisage this being enforced.

Question 2: To what extent do you agree or disagree with the proposal to promote or require use of the Model Conditions by local authorities, for activities where they have been agreed?

Please provide any comments or evidence to support your answer.

The Dog Rescue Federation supports this proposal.  Model conditions certainly help to promote uniform standards of animal welfare and are useful tool for local authorities to use as part of the licensing process.

Question 3: To what extent do you agree or disagree with the proposal to prohibit the sale of puppies below the age of eight weeks?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation supports this proposal, in principle, but in an ideal world we would prefer to see the minimum age set at ten weeks to allow both required sets of vaccinations to be administered. In this respect, we would like to see a requirement introduced that any puppy being sold should be properly vet checked beforehand, verified by appropriate paperwork.

Question 4: To what extent do you agree or disagree with the proposal to make clear that the statutory licensing threshold for dog breeders is set at three or more litters per year?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation does not support this proposal; indeed we believe that the use of licensing thresholds is counterproductive in terms of reducing irresponsible dog breeding practice.

The Dog Rescue Federation was formed in 2012 in response to the overwhelming problems being caused by irresponsible dog breeding and ownership.  We represent the concerns of voluntary dog rescuers who operate throughout the UK and handle a significant proportion of the estimated 50,000 dogs abandoned by their owners every year.

Our main focus of attention is now on so called ‘backstreet breeders’ and we are soon to launch a campaign aimed at making it more difficult for them to operate.  We are placing such emphasis on backstreet breeding because we have good reason to believe that most of the dogs that end up in the voluntary sector’s dog rescue centres are bred in this environment.  Larger scale puppy farming, however dreadful this practice is, tends to produce dogs of a particular type and price that will attract buyers who are far more likely to provide long-term care and love. Backstreet breeders cater for a different market, perhaps best characterised by a ‘throw-away’ lifestyle who will give less thought to the purchase of a dog, probably not pay as much for it and be far more inclined to dispose of it when it turns out not to be what they had wanted.

The Dog Rescue Federation is alarmed at the scale of dog abandonment in the UK. Some of those abandoned will be lucky enough to find new homes with the help of dog rescue volunteers for whom we provide a voice but too many of these poor dogs will end up being destroyed, simply because the ‘system’ is unable to cope with their numbers.  This dreadful situation is caused almost entirely by the actions of irresponsible dog breeders whose interest in making money totally outstrips any concern for dog welfare. They indiscriminately churn out puppies and sell them recklessly, often to people who are absolutely unsuited to owning a dog or who may not have properly considered the full implications of dog ownership.

The Dog Rescue Federation believes that the best way of solving the problem of dog abandonment and the needless suffering it causes to tens of thousands of innocent dogs each year is to make it increasingly more difficult for so-called backstreet breeders to operate.

One of the main reasons why these breeders have been so successful in flooding the market with dogs is that the current legislation is almost impossible to enforce.  Your proposal to reduce the statutory licensing threshold to three or more litters per year would not, in our opinion, create a legislative framework that makes it any easier for local authorities to control the activities of these unscrupulous breeders.  It would simply perpetuate the enforcement problems associated with current legislation and would still rely upon local authorities being able to prove beyond reasonable doubt that a breeder is operating beyond the threshold.

We also do not believe that your proposal addresses the serious animal welfare issues of dogs whose breeders operate below the threshold level and are not, therefore, subject to any form of inspection or control. In our opinion, this is wrong – the legislative framework under which the breeding of dogs takes place should apply equally to all forms of breeding, not just where breeding takes place beyond an arbitrarily agreed threshold. Such a legal framework not only encourages breeders who operate below the threshold level to adopt a less proactive approach towards animal welfare but, as we will set out below, also opens up the prospect of unscrupulous breeders continuing to operate outside the law.

A better way of protecting the welfare of all dogs and making it more difficult for ‘backstreet breeders’ to continue operating would be to bring all forms of dog breeding under the control of a local authority licensing regime; in other words, introducing compulsory licensing for all forms of dog breeding, irrespective of the number of litters produced or purpose. We believe that such a legal framework would offer distinct advantages when compared against the proposal you have put forward.  Here is our analysis, measured against three key tests for new legislation.

Will it be easy to understand?

Current dog breeding laws are not well understood. Local authorities struggle to interpret them; responsible breeders are often unsure about how the rules apply; and the general public is, at best, confused by the contradictory information in circulation on the subject.

The Dog Rescue Federation conducted an exercise in 2015 to establish the accuracy of information provided by local authorities in England in relation to existing dog breeding regulations.   The exercise involved inspecting the information provided about dog breeding on the websites of each local authority in England and was conducted six months after Defra had sent out its letter of explanation on this matter.  The exercise identified no fewer than 38 different interpretations of the 1999 Act:

  1. Any person who breeds dogs 
  2. Any person who keeps a breeding establishment for dogs  
  3. Any person who breeds dogs as a business 
  4. Any person who breeds dogs for commercial purposes
  5. Any person who breeds dogs for sale
  6. Any person who carries on a business of breeding dogs with a view to them being sold
  7. Any person who keeps more than 2 bitches for the purpose of breeding for sale 
  8. Any person who keeps 4 or more bitches for the purpose of breeding for sale 
  9. Any person who breeds 4 or more litters during any 12 months 
  10. Any person who keeps 5 or more bitches for breeding  
  11. Any person who, during any 12 months, breeds 5 or more litters 
  12. Any person who, during any 12 months, produces 5 or more litters and any of the puppies are sold 
  13. Any person who, during any 12 months, produces 5 or more litters for sale 
  14. Any person carrying on a business of breeding dogs if litters are born to 5 or more bitches in any 12 month period unless none of them are sold. 
  15. Any person who, during any 12 months, keeps a bitch that gives birth to a litter and during the same period, 4 or more other litters are born to bitches kept by that person 
  16. Any person who, breeds dogs as a business or sells puppies from 4 or more litters in any 12 months period 
  17. Any person who carries on a business of breeding dogs for sale. Also, any person who produces 4 or more litters, when there is an automatic presumption that the person is running a business 
  18. Any person operating a business of breeding dogs with a view to selling them.  Also if the number of litters delivered, or expected to be delivered, during a 12 month period exceeds 5 in total 
  19. Anyone in the business of breeding dogs for sale, meaning that if a single bitch is kept and gives birth to a litter in a 12 months period, a business is being carried on. Also if 5 or more litters are born to any bitches in any 12 months period
  20. Any person carrying on a business of breeding dogs for sale.  If a total of five or more litters are born then this falls within the definition of a business of a breeding establishment. It would include an intention to produce 5 or more litters, and sell puppies.  In some situations, a business will include the selling of puppies from less than 5 litters 
  21. Any person who breeds dogs for sale will be treated as carrying on a business.  Also, any person whose bitches give birth to 5 or more litters in any 12 months will be presumed to be carrying on a dog breeding business 
  22. Any person keeping more than 2 bitches for breeding which give birth to 5 or more litters during any 12 months and who offers at least one puppy for sale 
  23. Any person who breeds dogs as a business and sells puppies from 4 or more litters in any 12 months 
  24. Any person who carries on the business of breeding dogs for sale by breeding and selling more than two litters in a 12 month period, or during any 12 month period, producing five or more litters born to his/her bitches 
  25. Any person who produces 5 or more litters of puppies in any 12 months, and any of the puppies are sold 
  26. Any person who keeps more than two bitches for the purposes of breeding for sale.  Anyone carrying on a dog breeding business will normally be regarded as needing a licence, regardless of the number of litters involved. A person is presumed to be carrying on a business if in a 12 month period any number of their bitches give birth in total (i.e. collectively) to 5 litters or more 
  27. Any person who owns 5 or more breeding bitches that produce 5 or more litters per year or any person whose premises are used solely for the purpose of breeding dogs 
  28. Any person keeping bitches which give birth to five or more litters during any 12 months period, and who offers at least one puppy for sale 
  29. Any person who keeps more than two bitches for the purposes of breeding which give birth to five or more litters during any 12 month period and who offers at least one puppy for sale 
  30. Any person who produces for sale, 5 or more litters of puppies per year or, 2 or more litters are sold within 12 months or, where the breeding of puppies is considered to constitute a business 
  31. Any person who keeps more than two bitches for the purposes of breeding for sale. Commercial dog breeding establishments are premises having five or more litters of puppies in any twelve month period 
  32. Any person who carries on a business of breeding dogs where litters are born to five or more bitches in any 12 month period unless none of them is sold 
  33. Any person who carries out a business of breeding dogs with a view to selling them. This means any dog breeding establishment that produces five or more litters of puppies for sale per year 
  34. Any person who wants to breed dogs to sell. A licence may not be required if the person breeds dogs as a hobby, for show rather than for sale, and produces less than five litters in a year 
  35. Any person who has just has one bitch but the pups are sold as a business.   However if the person breeds 5 or more litters a year from any number of bitches whether or not they claim it is a hobby they must be licensed 
  36. If the main purpose for breeding is for showing, you will not need a licence. If you have more than 5 breeding bitches, you will require a licence.  If you have less than 5 breeding bitches but are still breeding for sale, you may require a licence.
  37. Any person who breeds and sells more than two litters in a 12 month period, or during any 12 months period, five or more litters are born to their bitches 
  38. Any person carrying on a business of breeding dogs with a view to them being sold.  The Act indicates that the keeping of bitches who give birth to 5 or more litters, of which at least one puppy is sold, in any period of 12 months is presumed to constitute a business 

The point of reproducing the results of our exercise is to illustrate that when laws are open to interpretation, they will almost certainly be misinterpreted. Local authorities are responsible for implementing and enforcing the laws relating to dog breeding and are seen as the primary source of information and advice about the licensing requirements.  Yet it appears from the evidence of this exercise that they struggle to understand how the law is intended to work and generally offer poor, often wrong, advice to those wanting to know more about it.

The Dog Rescue Federation wants to see the new laws on dog breeding written in clear, unambiguous terms to avoid this type of confusion. We accept that Defra’s proposal to reduce the statutory licensing threshold from five or more litters per year to three or more litters per year is, in itself, unambiguous.  However, the ancillary requirement that anyone ‘in the business of breeding dogs for sale’ must also be licensed throws the matter back into confusion. For example, would a breeder who operates below the three-litter threshold but then sells a few puppies to cover their costs require a licence?   Or what about a breeder who operates below the threshold and breeds dogs for the purpose of showing but will sell any that do not achieve the required show standard? And would someone who breeds and sells the occasional litter of puppies but does not see themselves as being ‘in the business of breeding dogs for sale’ be required to hold a licence?

Our proposal that anyone who breeds dogs must be properly licensed removes any such ambiguity.  It would be clear to anyone intending to breed from their dog(s) that they must first make an application to become licensed.  There would be no issues about how many litters they intend to produce or over what period, nor would there be any question about whether they are conducting a business if they choose to sell the puppies they produce. The only consideration would be their intention to breed dogs.

Making the law on breeding so abundantly clear would ensure that it is communicated easily and without misinterpretation.  Importantly, it also substantially reduces the ‘wriggle room’ that irresponsible breeders currently enjoy by claiming that they are neither producing sufficient litters nor operating as a business to warrant being licensed.  Removing any scope for this type of activity is an essential requirement of any new law as it is currently far too easy for irresponsible breeders to use the ambiguities of existing regulations to their advantage. The Dog Rescue Federation does not believe that Defra’s proposed reduction in the statutory licensing threshold would do enough to address the problem of unlicensed dog breeding primarily because it will remain open to misinterpretation and, therefore, abuse. Locking down all forms of dog breeding within one very clear licensing regime would be a much better way of ensuring that everyone – local authorities, breeders, the general public – understand the law. It would also dramatically increase the percentage of puppies being born to properly licensed/regulated breeders and that must surely be the right way forward.

Will it be easy to enforce?

Perhaps the greatest problem associated with the Breeding and Sale of Dogs (Welfare) Act 1999 is that it is extremely difficult to enforce. That is because local authorities are currently required to prove that a breeder is either producing five or more litters in any period of 12 months, or that they are in the business of breeding dogs for sale. Many breeders are exploiting this difficulty, believing that councils have neither the time nor the money to gather sufficient evidence to successfully pursue a case against them through the courts.  In effect, these breeders are waving ‘two fingers’ at the licensing authorities, producing litter after litter of puppies for sale with little or no likelihood of being prosecuted.  This cannot be be allowed to continue – local authorities must be in a much stronger position to enforce dog breeding laws and breeders must believe that if they break the law, they are likely to be caught and penalised.

Unfortunately, your proposal to reduce the statutory licensing threshold from five or more to three or more litters per year will not make the local authorities’ task of enforcement any easier and, in our judgment, will not deter unlicensed breeders from continuing to produce and sell excessive numbers of puppies.

The Dog Rescue Federation’s proposal of bringing all forms of dog breeding under a licensing arrangement would greatly simplify enforcement activity.  Local authorities would no longer be required to prove that a breeder is producing more than a prescribed number of litters in a 12 month period, or that they are in the business of breeding dogs for sale; the only issue would be whether a person is or is not breeding dogs. This simplified approach would drastically ease the burden on enforcement and would afford unscrupulous breeders far less scope to produce litters of puppies outside of regulation and control.  The matter would be clear, anyone breeding from dogs without a licence, irrespective of the number of litters produced or purpose, would be committing an offence and be liable to prosecution – making it a very simple law to enforce.

The Dog Rescue Federation believes that by having this attitude towards dog breeding, the opportunity for excessive and uncontrolled breeding of dogs would be reduced and, in time, the dog population would drop to more manageable numbers.  This should be an important aspiration of any new legislation given the clear evidence that already exists that there is a growing excess in the supply of dogs compared with likely demand from good owners.  Just think how many fewer dogs would end up in rescue centres each year if improved enforcement activity made it more difficult for irresponsible dog breeders to continue operating?

The Dog Rescue Federation recognises that the compulsory licensing of all dog breeding will impinge upon the legitimate activities of responsible ‘small scale’ breeders who would otherwise not be required to become licensed; this may even be considered a disproportionate reaction to a problem that these breeders have played no part in creating.  However, although these breeders do not produce many dogs individually, collectively they make a large contribution to the overall UK dog population and it seems right, therefore, that they should be placed under some form of control. It is also equally important that the same standards of welfare should be required of everyone not just the breeders who produce more than a prescribed ‘threshold’ number of litters per year or who carry on a business of breeding dogs for sale.

We also recognise that by extending the licensing requirements to all dog breeders it will inevitably cause an increase in the workload of local authority licensing officers and may add to the volume of enforcement issues.  But these increases could, in part, be funded by the consequential increases in licensing revenue and might also be offset by your proposal to extend the period of licensing up to a maximum fixed term of three years.  Local authorities may well find that many of the responsible breeders who would be required under our proposal to become licensed would be considered suitable for the issue of a longer-term licence.  This would mitigate the burden of such a compulsory licensing regime – for the breeder in terms of the cost of renewing their licence on an annual basis, and for the local authority in terms of processing annual applications for renewal.

Under our proposal we would also want to see all breeders issued with a licence number that they would be required to include when advertising puppies for sale, including on the internet (we understand that a system similar to this is already in operation in France). Also, we would wish to see the introduction of national database – searchable by postcode – containing the details of all breeders to whom licenses have been issued.   In addition we would want the government to mount a public awareness campaign to clearly advise the public not to purchase a puppy from breeders who do not possess such a licence. All of this would help to improve the accountability of breeders and make it increasingly more difficult for irresponsible breeders to continue operating. Also, it would aid consumer protection and offer purchasers greater assurance that any puppy bought will have been bred under the auspices of a local authority licensing regime.

Finally, there would be scope under our proposal to cater for accidental matings.  Whilst we would always recommend that owners should neuter any dog they do not intend to breed from we accept that accidents will happen and when they do, owners should not find themselves outside the law.   In these circumstances owners would be required to apply for a temporary licence to cover the single litter of puppies resulting from the accidental mating.   Only one temporary licence would be issued to an owner who would then be encouraged to have their dog neutered to prevent future accidental matings.  Under the temporary licence arrangement, a local authority would still be required to arrange an inspection of the premises concerned to ensure that all the necessary animal welfare arrangements are in place and would also be entitled to charge the owner for the issue of a temporary licence and the cost of inspecting their premises.

Will it be observed?

In its 2015 Breeding Report, Battersea Dogs and Cats Home indicated that as many as 88% of all puppies born in the UK are born to unlicensed breeders.  Even allowing for puppies produced by breeders who are currently entitled to breed dogs without a licence, such a high percentage strongly suggests that the current legislation is largely ignored by a majority of dog breeders. In our opinion this is due mainly to the fact that most of the breeders who fail to observe the current legislative framework do so in the firm belief that they are not likely to be caught and that the risk of producing and selling dogs without an appropriate licence is well worth taking.  Any proposed changes in the laws governing dog breeding must, therefore, directly address this issue otherwise there is every possibility that non-observation will remain a real problem.

The Dog Rescue Federation strongly believes that there is little prospect of improved observance of any revised dog breeding laws unless the changes being made introduce regulations that are significantly more simple to understand and, in particular, enforce.  Unfortunately, your current proposal to keep the basic legislative framework for dog breeding in much the same format as it is at present (albeit reducing the numbers of litters a breeder may produce in a 12 months period without a licence) would not, in our opinion, lead to such an improvement.  Infact, we would go as far as to say that it would be a pointless exercise to make these changes because they do not do enough to alter the mind-sets of those who currently believe that it is very much worth taking the risk of ignoring existing licensing arrangements.

Our proposal to bring all forms of dog breeding under proper local authority licensing control would hopefully overcome the problem of non-observation, primarily because local authorities would no longer have to prove that a breeder is producing more than a prescribed maximum number litters in a 12 month period or carrying on a business of breeding dogs for sale.  All that they would be required to do is to produce evidence that an individual is breeding dogs and this, in turn, should change the breeder’s perception of the risks of operating without a licence.  We fully accept that some breeders would be willing continue to take the risk but our proposed compulsory approach towards all forms of dog breeding would hopefully tip the balance against them and make it make it much harder for them to operate outside of the licensing arrangements

Question 5: To what extent do you agree or disagree with the proposal to legally require pet sales to provide written information when selling animals?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation supports this proposal and would wish its scope extended to include not only information about animal type but also detailed information about the specific animal being purchased – breed type, dam, sire (if known) age, sex, microchip number, vaccination details, etc.  Rescue centres are full of dogs that people have bought on a whim or fancy, only to realise that the cuddly little ball of fluff that they purchased as a puppy has turned to something they no can longer afford to feed, manage or have adequate time to care for.  According to our own surveys of local authorities conducted in 2013 and 2014 approximately 50,000 dogs are abandoned annually in the UK.  Most of these are usually originally bought without the owner properly considering the full implications of their choice.  Therefore, anything that can be done to better inform potential owners of dogs about the characteristics of breed and whether a dog would fit into their lifestyle is to be encouraged. Evidence suggests, however, the many dog purchasers are more likely influenced by fashion trends that facts, as witnessed by the massive increase in Staffordshire Bull Terrier type ownership in recent years.  Irresponsible breeders feed on this desire and have little interest, if any, in providing information that might deter a potential purchaser.

Question 6: What other proportionate measures could address concerns around the care of exotic animals?

The Dog Rescue Federation has no comment.

Question 7: To what extent do you agree or disagree with the proposal to allow licences to be issued for a fixed term, set at any point in the year?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation supports this proposal

Question 8: To what extent do you agree or disagree with the proposal to increase the maximum length of a licence that local authorities may issue to up to three years?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation supports this proposal, in principle, to enable local authority licensing officers to concentrate more of their time on enforcement and dog welfare issues.  However, we are concerned that three years might be too long for a licence to be held without the possibility of any further local authority inspection.  Therefore, we would wish to see a more structured approach towards the periodic review of licensed premises with ‘lighter touch’ inspections being required at the mid-point of the licence period, supplemented by unannounced inspections.  We would also want to see an improvement in the scope of record keeping by the licence holder, possibly the introduction of an annual report to their local authority, to ensure that a lengthened licence period does not become an excuse for a drop in animal welfare standards.  In other words, licence holders must still feel that their local authority is closely monitoring them even though they may no longer be subject to an annual licence renewal process.

Question 9: To what extent do you agree or disagree with the proposal to allow licence holders to transfer licences to new owners of the same premises, subject to notification of and approval by the local authority?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation has concerns about this proposal.  The fact that an existing licence holder has achieved the required standards of animal welfare to be allowed to operate a licensed animal establishment does not guarantee that a new owner will also meet these standards.  Your proposal involves taking an unnecessary risk.

Question 10: To what extent do you agree or disagree with the proposal to require licence holders to notify local authorities of major changes, such as a change of premises or scale of activities?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation supports this proposal

Question 11: To what extent do you agree or disagree with the proposal to maintain the registration requirement for performing animals?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation has no comment.

Question 12: To what extent do you agree or disagree with the proposed changes to the registration system for performing animals?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation has no comment.

Question 13: To what extent do you agree or disagree with these proposals on powers of entry?  Please provide any comments or evidence to support your answer.

The Dog Rescue Federation fully supports this proposal although you may wish to look again at the limit of how many people are allowed entry. Four persons seems rather low.

Question 14: To what extent do you agree or disagree with the proposal to allow an exemption from licensing requirements for businesses affiliated to a body accredited by UKAS? Please provide any comments or evidence to support your answer.

The Dog Rescue Federation does not support this proposal.

UKAS accreditation clearly has its place in other spheres of activity but we do not see it as a regulatory model that would fit animal establishments. Although UKAS accreditation is in use in the greyhound racing industry, we understand that there is no clear evidence to suggest that it has achieved higher welfare standards.  More particularly, we believe that the introduction of UKAS accredited bodies to control standards in some animal establishments, when other such establishments would still be under the control of local authorities, will only serve to confuse the general public.

Question 15: Do you think sector-led UKAS-accredited certification schemes could improve animal welfare in unlicensed areas? If so, what would work best and how could 

this process be encouraged?

The Dog Rescue Federation would only support this proposal if it serves to drive-up standards of animal welfare in those types of animal business currently not covered by licensing requirements.  However, we remain unconvinced that such schemes offer demonstrable benefits in an animal welfare environment, as outlined in our response to the previous question.