Make animal welfare a common priority!
1. Our comments concentrate on serious omissions on the welfare of animals of all species and the respect and consideration that they should enjoy on territories rightly named as common lands. References (e.g. p. 57, A4; p. 63, A34; p. 66, A56; p. 79, A133) are made in the consultation paper to animal welfare, but they receive inadequate continuation into prospects of improvement, except for some recognition of the harm done by agricultural policies based on subsidies ineptly administered and now undergoing change.
2. We expect that changes in the CAP and pursued in the Haskins review will anticipate further emphasis on the declining importance of farming output against the value of the countryside for leisure and tourism and for the enjoyment of harmony with feral and wildlife in terms of conservation and evolution.
3. We look for greater authority accorded to the writ of specialised organisations such as the FAWC and the RSPB, as well as bodies such as the RSPCA with a more nearly consistent purview of animal welfare. Many of the problems arise from animals introduced by human interventions into unequal conditions – as the toll of the foot-and-mouth epidemics and rigours of lambing in exposed areas indicate. Extended movements and traffic in livestock reduce the remoteness of animals (including people) on common lands from zoonotic effects and changes in the micro-environment (which would include bacteria, viruses, and prions, some airborne, as well as radioactivity due to nuclear fallout).
4. This further surveillance must entail the activities and authority of the State Veterinary Service. We call for particular attention for rigour and consistency on the following matters:
i. Shooting and culling of animals (we imply of all species in this term) must be allowed only on grounds of euthanasia (e.g. for fallen stock, road casualties, as well as for controlled balancing of populations on grounds of the general benefit to conspecifics and conservation). Killing for “sport” must be disallowed as a criminal perversion and a commercially outlawed procedure (like rustling).
ii. Inspection of kept livestock, rules and means of traceability, and conditions of shearing, transportation, and slaughter must conform to such welfare provisions as are applied to all farmed animals. Such supervision is especially necessary for animals having had little contact with human handlers and are thus flighty when attempts are made to round them up, market them, and slaughter them. Tagging is a newly-introduced means of identification objectionable for the risks it entails.
iii. All keepers and handlers of animals on common lands must be trained or prove experience for licensing in the manner we and other welfare organisations in Europe demand for owners, stockpersons, and dealers.
iv. Regulations for common lands must allow for introductions of “exotic” species (such as llama, buffalo, or reindeer, as well as of animals of familiar species but bred or genetically modified with characteristics undermining their ability to cope in the “wild”). They must also reassert the penalties for harassing or tormenting animals on common land, e.g. by domestic dogs or by animals trained and introduced for such purposes in the interests of “sport”.
v. Other nuisances causing undue disturbances needing bans or policing include:
a. Off-road use of motorised vehicles (e.g. for racing, but not restricting farmers’ and wardens’ use of quad bikes and the like) must be banned. Speed limits on roads and warnings of restricted vision must be enforced.
b. Occasional meetings, gatherings, and protests must require from organisers responsibility and policing to avoid undue disturbance (e.g. from fireworks) and littering (ruminants and other animals suffer seriously from ingested plastic wrappings or from curiosity at derelict equipment and machinery).
c. Control of disturbances from the air, other than disease by micro-organisms, must be given more attention, e.g. by hot air balloons, gliders, helicopters, and other low-flying and landing craft, which terrify animals. Some usage, for spraying pesticides, for example, must be severely curtailed; other usages, e.g. for rescues or remediation of worn-out paths in remote places, need special dispensations.
Dr. Alan Long