PIAA response to the NSW DPI consultation paper on licensing and regulation of dog and cat breeders…

 PIAA Response to the NSW Department of Primary Industries Consultation paper on Licensing and regulation of dog and cat breeders.

When you investigate the pet industry from the outside you wouldn’t find a more emotive based industry where every individual, organisation, group, club or association has an opinion. All of which is correct is some way shape or form based on their own interpretation of information or research completed, read or written by the latest experts. Is the pet industry so emotive based because it represents a cohort who has no voice for themselves, so we project our own feelings and emotions on the subject? So, who is right in this situation and who is the one voice in Australia developing the overarching framework to create the one voice that represents our most sentient animals? 

Likewise, we would imagine that DPI will receive a significant amount of response to their request for information, some specific to the subject and much more that draws attention to a broader range of issues.

In response to the NSW DPI Consultation paper on licensing and regulation of cat and dog breeders, the Pet Industry Association of Australia (PIAA) offers the following commentary which highlights the broader issues along with some specifics to the topic.

Firstly, noting 3 current documents in circulation in NSW that governs both companion animal ownership and the regulations for the industry. 

1. POCTA prevention of cruelty to animals’ act.

2. NSW code of practice for breeding of dogs and cats (the breeding code).

3. Companion animals act CAA.

For the purposes of reference, we also refer to the Victorian Domestic animals’ amendment (puppy farms and pet shops) act 2017. We also refer to our own internal reviews of defining the root cause analysis that relate to our industry and the best ways to improve on the outcomes all unpinned by only one focal point “Animal welfare”.

Our first reference point is to call for a national approach to animal welfare instead of a state-based approach where issues are moved from state to state as in the case of The Victorian act pushing puppy farms from Victoria to NSW through regulation. We therefore suggest that whilst the Victorian act is by no means perfect it can be a good place to start the review process, with a review of what works best and what needs amendment. This leads us into the need for a framework to deliver a process of continuous improvement of the referred 3 documents mentioned above that could be reviewed annually by a group like the NSW pet ownership reference group. The underlying issue that causes the most debate but receives little commentary or focus on improvement is the demand and supply of companion animals to the industry.  We note that most of the government intervention comes from the puppy farm debate with several political parties offering radical solutions that provides little or no industry input to the solution.

From a demand perspective periods of huge increase such as the current pandemic on companion animal ownership will cause spikes that breeders will respond to that needs to be controlled when demand drops off otherwise creating an oversupply that will lead to other animal welfare challenges. 

In relation to the supply of companion animals to the industry the greatest failure of the Victorian act was to confuse the Australian consumer into what is an “approved source” for the purchase of animals thus creating further black market and or scamming of new owners. The PIAA also challenges that “pet shops” should be part of the solution to new pet ownership and not ridiculed as the cause of puppy farms as some would suggest. Pet shops should indeed be on the approved list as they can be regulated as equal to the breeding community and are more visible to both the greater public and the inspectorate for compliance to animal welfare laws. 

The PIAA therefore challenges the NSW government perhaps through DPI to place this debate up for review from which we can write into policy for the longer-term control of the breeding of companion animals. 

In specific response to the question for designing a licensing scheme and subsequent questions to exemptions the PIAA are very much in support of such a scheme. We do however believe that there should be NO exemptions to the scheme whatsoever. Animal welfare misconduct can be practiced by the untrained, unaware, single dog breeder or multiple dog breeders, there should be no discrimination, anyone in charge of an animal must face the same laws across the industry. 

This of course brings us to the need for increased funding for the inspectorate to administer the laws where traditionally has been under resourced to act on any laws that are passed. The PIAA believe that the industry needs to address this challenge where a financial model be presented that self-funds the inspectorate to ensure compliance. This could be either through licensing of breeders and sellers or through a more specific model where “pet levies” be applied across the industry wide. The PIAA would be happy to facilitate such an event should the NSW government require it as recommended by the DPI noting deficiencies in the current funding model.

The PIAA will leave the specifics of any such scheme to the better placed organisations such as the Australian Association of Pet Dog Breeders who we are in receipt of their submission and support it accordingly. However, will be at your service should you require further industry expertise from our wide membership base and or want to discuss further our submission herein.

Further information and interview requests:
Linda Chamarette | 0414 945 990 | events@piaa.net.au

Spokesperson available:
Barry Codling, President, Pet Industry Association of Australia