Friday 16th June 2017 1:38 pm.Katherine Ernst

LEADING Victorian conditioner Rob Britton has labelled the draft Code of Practice for the Keeping of Racing Greyhounds as a disgrace.

The code was recently released by the Victorian Governments Department of Economic Development, Jobs, Transport and Resources and was formulated as a response to the 2015 reports by Sal Perna and Dr. Charles Milne.

The code covers a wide range of issues facing the industry such as the management of greyhounds throughout their entire lifecycle and minimum standards expected from participants encompassing housing, socialisation and mental stimulation.

Britton said certain aspects of the code could spell the end for many participants within the industry if implemented, including new standards for kennels, yards and fencing.

There should be a grandfather clause in there regarding these new standards which should specify that properties should be brought up to standard as participants have to replace and repair otherwise having to bring everything to comply with these standards at once will send people broke, Britton said.

As long as there are no welfare concerns participants shouldnt have to re-invent the wheel and fix what hasnt been broken for years.

Britton also felt most of the industrys feedback had not been considered when writing the code.

I attended number of industry workshops and spoke to the department of agriculture many of the parts of the code were brought up then and we gave reasons why they shouldnt be implemented but it just seems like they have ignored our input.

Most of these points are ideology rather than practical business sense and if allowed to go ahead in the current form the industry is going to crumble.

There are a lot of little things in there that shouldnt be there such as the size of the dog determining the size of the kennel needed.

Also the staffing issue is totally unnecessary we have surveillance systems in place here and we live on the property so we are here most of the time but on occasion we go to the dogs together, to the shops but reading this report we will have to have someone here all the time.

Then you read that people with more than two dogs are going to be considered professional trainers its out of control.

I tried explaining this to them, but they obviously had their ideas on what was going to be in there.

Britton said the code will make it impossible to be a part of the industry for many participants and urged Greyhound Racing Victoria (GRV) to step up to protect the sport.

Weve been singled out ever since the live baiting scandal and its like we are being punished, he said.

This code of conduct is supposed to be about setting a minimum standard but these are gold-plated Rolls-Royce standards.

I am a bit disappointed in GRV too they pretty much said that because this is a government report they have no influence and that they are just the regulator.

But under the act GRV have a duty of care to keep the industry viable but if this code is enforced it will be non viable so GRV really have to stand up.

Britton also urged participants to speak out and provide feedback on the draft Code of Conduct in order to send a message on what will and wont work for the participants in the industry.

Everyone has to read this report and analyse it figure out how it will affect you and respond in writing to let them know, he said.

Its important to also note the points you support because its not all bad we need to show them its not all one way and we are happy to get behind the rules which are positive.

Your Voice needs to be heard - As well as putting forward your submission - Contact your Local MP - Remind Him/Her of NSW Premier Mike Bairds fate in Legislating a Ban on Greyhound Racing in NSW. List of Victorian State MPs - EXTERNAL LINK

Hello .............
Does the Victorian Andrews Government have a Department of Gaming and Racing - If so are they incompetent. Why is the Racing Minister unable to oversee a Draft Code of Practice for the Greyhound Industry in Victoria. Why does the Andrews Government believe this issue to be a Farming / Primary Industry matter with the draft prepared by the Department of Agriculture.
The requirements in this draft will see the demise of The Greyhound Industry, Red Tape and Business Costs will force many small Self Employed business people out of the Industry.
Greyhound Racing contributes in excess of $400.000.000 Directly and another $130,000,000 indirectly to Victorias economy.
Does the Victorian Andrews Government need to be reminded of NSW Premier Mike Bairds inability to deal with poor decision making?

Peter Bryce
Victorian Citizen

Another reply to Draft Code of Practice of Greyhound Racing in Victoria

Dear Peter,

Thank you for your email to Dee. She has noted your comments and has asked me to respond on her behalf.

Last week a Draft Code of Practice For the Keeping of Racing Greyhounds was released by the Andrews Government and is presently open for public comment until August 14.

Shadow Minister for Racing, Tim Bull MLA, will hold a meeting with representatives of the 13 Victorian Clubs in the very near future to discuss their concerns with the Draft Code, which they believe are too onerous.

We encourage you to contribute to the public feedback process as follows:

Hard copy submissions (postmarked before 14 August) may be sent to:

Draft Code of Practice for the Keeping of Racing Greyhounds Public Comment

Domestic Animals,

475 Mickleham Rd,

Attwood, Vic, 3049.

Or follow this link to submit electronically EXTERNAL LINK
With regards,

Nicole Gooch

Electorate Officer & Diary Manager

Dear Peter

The Victorian Greens want to see greyhound racing banned in Victoria, however, we have been lobbying the current Minister for Racing in Victoria, Martin Pakula for this and will continue to do so.

Animals Australia report that an estimated 18 000 healthy dogs are killed in the greyhound racing industry each year in Australia. This includes 8000 pups and young dogs that never make it to the track and another 10 000 that are retired from racing because they are simply regarded as being too slow. Four out of five dogs that are retired from racing are killed and five dogs every week are killed on the racetrack.

Those that are not killed on the racetrack are still at risk of significant injuries such as broken hocks and legs, and head trauma during racing and in training. Up to 200 dogs are reported injured during official races every week. Some are even reported to have died from cardiac arrest due to the extreme physical intensity of racing. On many occasions such injuries are 'uneconomical' to treat, and the owner will instead have the dog put down.

Sue Pennicuik, Greens spokesperson on Animal Welfare, has raised the issue in parliament, calling for the greyhound industry to be phased out and for the establishment of an independent regulatory body for animal welfare, which can put the welfare of animals first. She has spoken about it in Parliament, for example here: EXTERNAL LINK and the Greens published a media release last week following the NSW announcement: EXTERNAL LINK
We will continue to campaign for greyhound racing to be banned and for an independent regulatory body for animal welfare in Victoria.

If you require further information, youre welcome to contact Sue Pennicuik at [email protected] or on (03) 9530 8399.

David

--
Office of Ellen Sandell MP
State Member for Melbourne
Victorian Greens
P | (03) 9328 4637 E | [email protected]
Sign up for regular updates a EXTERNAL LINK
The Office of Ellen Sandell MP respectfully acknowledges the Traditional Owners and Custodians of the Country on which we work.

On 19 June 2017 at 15:18, Peter Bryce wrote:

Hello Ellen
Does the Victorian Andrews Government have a Department of Gaming and Racing - If so are they incompetent. Why is the Racing Minister unable to oversee a Draft Code of Practice for the Greyhound Industry in Victoria. Why does the Andrews Government believe this issue to be a Farming / Primary Industry matter with the draft prepared by the Department of Agriculture.
The requirements in this draft will see the demise of The Greyhound Industry, Red Tape and Business Costs will force many small Self Employed business people out of the Industry.
Greyhound Racing contributes in excess of $400.000.000 Directly and another $130,000,000 indirectly to Victorias economy.
Does the Victorian Andrews Government need to be reminded of NSW Premier Mike Bairds inability to deal with poor decision making?

Peter Bryce
Victorian Citizen

Thanks Peter, I have grave concerns with the Draft Code of Practice. The anomaly with this is that although it is racing, this Code itself falls under the Department of Agriculture as part of the Domestic Animals Act as it relates to animal welfare.

The points I have made in Parliament and to media today are as follows:

We support greyhound racing in Victoria and we believe this code of practice looks like overreach by the Andrews Labor Government and a banning by stealth of greyhound racing in Victoria.

If the Andrews Labor Government wants to ban greyhound racing they should just say so instead of this mealy-mouthed attempt.

Those in the industry caught doing the wrong thing should not only be banned from the industry but also receive a punitive punishment that sends a strong message of deterrence to others to make an example of them to others who ever contemplate doing the wrong thing.

I will be meeting with greyhound industry and club representatives this week to discuss the concerns around the governments policy.

Many thanks

Tim Bull
State Member, Gippsland East
Shadow Minister for Disability, Housing, Racing
143 Main Street, Bairnsdale
P: 51523491

GOTBA Victoria
June 19 at 11:49am Public
..
Sorry for the long posts....
Below is a copy of the "Letter of Adequacy" written to justify the Regulatory Impact Statement (RIS) for the draft Code. We know that it not "Adequate" as it relies on a flawed assumption of 100% compliance with the existing Code. The RIS determines the cost impact of the new draft Code from what was required in the current Code. It is from this flawed RIS that the draft Code was put together.....

3 March 2017
Ms Sally Fensling
Executive Director, Domestic Animals, Forestry and Game Branch
Department of Economic Development, Jobs, Transport and Resources
475 Mickleham Road
ATTWOOD VIC 3049

Dear Ms Fensling
REGULATORY IMPACT STATEMENT FOR THE PROPOSED CODE OF PRACTICE FOR THE KEEPING OF RACING GREYHOUNDS 2017
I would like to thank the staff of the Domestic Animals, Forestry and Game Branch within the Department of Economic Development, Jobs, Transport and Resources (DEDJTR) for working with my team on the preparation of the Regulatory Impact Statement (RIS) for the Proposed Code of Practice for the Keeping of Racing Greyhounds 2017.
Under section 10 of the Subordinate Legislation Act 1994 (the Act), the Commissioner for Better Regulation is required to provide independent advice on the adequacy of all RIS prepared in Victoria. The Commissioners role is to advise on the adequacy or otherwise of the analysis presented in the RIS, rather than the merits or otherwise of policy or regulatory proposals.

A RIS is deemed to be adequate when it contains analysis that is logical, draws on relevant evidence, is transparent about assumptions made, and is proportionate to the proposals expected effects. The RIS also needs to be clearly written so that it can be a suitable basis for public consultation.

I am pleased to advise that the final version of the RIS received on 23 February 2017 meets the adequacy requirements of the Act.
The proposed Code prescribes and enforces requirements for greyhound owners, rearers and trainers, including health management plans, independent veterinarian checks, fencing and housing requirements, and socialisation requirements. Greyhound Racing Victoria (GRV) will administer and enforce the proposed Code.

The RIS states that the Departments objectives in regard to the proposed Code are:
To increase (improve) the quality of life and welfare of greyhounds, throughout their lifecycle and provide consistent management which will alleviate stress and therefore enable an easy, smooth and rapid, transition to a pet at any time point in its lifecycle.

To achieve this, the RIS explains that the proposed Code covers a range of matters related to:
management practices that impact on animal welfare and quality of life (excluding the issues of live baiting and wastage), and the transition to rehoming.

The RIS notes that:
The issue of wastage (oversupply of dogs) and euthanasia is not addressed specifically in this RIS but that Although the proposed Code does not address wastage in itself, GRV strategies and policies (running in conjunction with the proposed Code) will."
The RIS analyses 6 options to achieve the Departments objectives which are variations of the preferred option the proposed Code with GRV enforcement. These include adjusting elements of the proposed Code that have more significant compliance costs (health management plans and rearing requirements), and options based around the instruments or enforcement tools used to influence compliance (including voluntary compliance with the proposed Code supported by an information campaign; adopting the proposed Code in local rules; or using local councils to enforce the proposed Code). The RIS uses a multi-criteria analysis to examine options against the criteria of animal welfare, rehoming potential, and net cost to industry and government. The Department concludes that the proposed Code achieves the best welfare and rehoming outcomes, while also considering the costs.

The Department estimates that the proposed Code will impose a net cost of around $118 million over 10 years, which will affect greyhound breeders and trainers, and GRV in administering and enforcing the Code. The Department notes that many of these costs will be passed on to owners, which is likely to increase the cost by $1,550 per dog over their lifetime a 7.8% increase from the average estimated costs of ownership. It is unclear if this will reduce involvement in the industry.
The Department expects that small industry participants are not likely to face significantly different or disproportionate costs in complying with the proposed Code, as the costs that breeders and trainers will face per dog are likely to be similar, and driven by existing levels of compliance rather than size of operation.

In regard to the costs for hobby breeders, the proposed Code exempts hobby breeders (defined as 2 adult greyhounds and 1 litter) from complying with housing pen/yard requirements, but that all record keeping requirements, vet agreements, health plans etc. however, would still need to be undertaken.

In terms of evaluation, the Department notes that the proposed Code will be evaluated in the context of GRVs broad-based animal welfare evaluation strategy from mid-2019. The stated aims of this evaluation strategy include:

Preventing excessive breeding (reducing litter numbers);
Reducing the premature death of racing greyhounds;
Optimising the use of the racing greyhound populations;
Improving outcomes for rehoming greyhounds;
Informing GRVs infrastructure investments into greyhound welfare; and
Providing training to industry participants to improve greyhound welfare at every stage of the dogs lifecycle.
The Department notes the high level of cooperation it has received from GRV in preparing the RIS, especially in regard to the provision of data, and relevant information.

Should you wish to discuss any of the issues raised in this letter, or the implications of new information or policy options identified through the public consultation process for your proposal, please do not hesitate to contact our office on (03) 9092 5800.

Yours sincerely
Anna Cronin (signed 3 March 2017)
Commissioner for Better Regulation