This is the Coalition for the Protection of Greyhounds submission to the proposed planning guidelines. We encourage you to make a submission at:
Feel free to use ours as a guide.
The CPG Submission
1.0 Purpose of Planning Guidelines
The stated goal of the new planning guidelines for greyhound facilities across Victoria as stated is to “increase planning certainty for participants, councils and the public.”
It is also stated that “the provisions are based on outcomes from a 2013 planning-led working group that was comprised of state government departments and agencies, local government and greyhound racing industry representatives.”
There is acknowledgment that DELP is also undertaking work as part of the implementation of two independent investigations into the greyhound racing industry.
The Coalition for the Protection of Greyhounds (CPG) is concerned that these guidelines will not meet their stated goal because it directly removes the ability of the public, through their local council, to have a say in whether greyhound racing facilities can be established or retained in their local area.
It does this through stipulating that in specified geographic areas and where there are fewer than the specified numbers of dogs in Tier 1 and Tier 2, no permit is required. It is of high concern that these planning guidelines would enable industry participants to keep as many as 50 dogs without a permit, as long as certain “objectives and performance measures were met.”
It is not in the interests of members of the public to remove their ability to protest the establishment of a facility with 50 dogs through their local council’s planning process.
2.0 Planning Guidelines Feedback
The independent investigations mentioned in the preamble of these guidelines both emphasised the importance of focusing on animal welfare. In contrast, these new planning guidelines give no consideration to animal welfare. Instead, the stipulated objectives and performance measures focus on public amenity – most particularly noise and appearance.
There are a large number of performance measures that aim to prevent greyhounds from receiving any kind of visual stimulation in an effort to prevent barking. This shows demonstrable ignorance of the breed and the cause of problem barking in dogs as a whole.
Problem barking in greyhounds on facilities is less likely to be due to visual stimulation such as passing cars and more likely to be due to a lack of enrichment and mental stimulation. Dogs display problem barking as a symptom of boredom or anxiety and if the source of the problem is not tackled, it is unlikely that any amount of acoustic requirements and setbacks of boundaries will prevent neighbours from being affected.
At this present juncture, greyhound racing facilities commonly use barking muzzles (see attached image) as a measure to keep animals quiet. Barking muzzles are inhumane as they prevent dogs from opening their mouths to pant or drink, removing the greyhound’s ability to regulate its body temperature. Given that Victoria can experience temperatures of over 35°C and even 40°C in summer, we suggest that the guidelines be amended to include an explicit clause banning the use of barking muzzles as a shortcut to stop problem barking. In Queensland, a greyhound died of heat exhaustion due to barking muzzle usage over the summer (http://www.racingqueensland.com.au/Greyhound/Industry-Licensing/Integrity/Stewards-Reports/2016/April/Stewards-Report-Andrew-Johnson).
We propose that additional guidelines with regards to a minimum staff: dog ratio be imposed to ensure that the dogs are given the appropriate amount of mental stimulation, whether through play or walks where they are allowed to sniff, so that problem barking can be prevented instead of attempts to hide the problem once it becomes an issue.
As the only scenario where dogs are likely to be kept in similar conditions to a greyhound racing facility is an animal shelter, we recommend incorporating guidelines from the Association of Shelter Veterinarians’ “Guidelines for Standard of Care in Animal Shelters”.
These guidelines recommend a minimum of 15 minutes of care time per day just for feeding and cleaning each dog housed (nine minutes for cleaning and six minutes for feeding) and at least one hour per day per dog for socialisation. Quick calculations will show that a typical greyhound racing establishment with one couple to look after 50 dogs is not appropriate as just the bare minimum of socialisation and care is 62.5 hours per day.
A more appropriate ratio for a 50-dog establishment would be a couple and six employees to care for the animals, in which case it is not desirable for such an establishment to be created with no local council permits.
Another concern of focus is on the facility having an acceptable appearance – not on the comfort of the dogs – “ensure the materials and finishes used to construct buildings and works associated with the racing dog facility minimise impacts on the visual amenity of the surrounding area.”
It is alarming that no additional requirements for shade cloths or some other method of providing shade for the greyhounds living in outdoor kennels has been included. For facilities where kennels are not located within buildings, but built out in the open, it is essential that shade cloths be provided so the dogs have shelter outside of their kennels.
2.3 Registration Requirements
No mention is made of registration requirements with the local council. This is in complete contrast to the recommendations of the 2015 Milne report which states that “a large number of greyhound establishments have not registered with local councils, creating a significant compliance and enforcement gap. “ Consequently, the Milne report recommends in recommendation 1.4 “That Greyhound Racing Victoria immediately identify all greyhound establishments that are potentially ‘Domestic Animal Businesses’ under the Domestic Animals Act 1994 2015 Victorian Live baiting inquiry.pdf and notify them to the relevant council to be assessed for registration.”
3.0 Animal Welfare Concerns
These planning guidelines are, in effect, applying a layer of public gagging, by removing or weakening the ability of the public to oppose a facility. They appear to be aimed at ensuring the construction of these facilities is such that the condition of the animals they house is hidden from public sight and awareness.
Given the concerns around animal welfare transgressions in the greyhound racing industry and the fact that most of these transgressions take place in breeding, rearing, breaking or training facilities like the ones these guidelines cover, it is not in the interest of the public or the greyhounds to hide these animals away.
The lack of clarity around how they will work in conjunction with Greyhound Racing Victoria (GRV) guidelines is concerning. Would participants only need to comply with these guidelines, these guidelines as well as GRV standards, or would GRV standards not apply anymore at all? For example, would someone whose kennel sizes are smaller than GRV requirements be considered non-compliant and therefore in need of a permit, or would they still not need a permit as kennel sizes are not mentioned in these guidelines?
Should these guidelines supersede GRV standards, the lack of measures to guarantee animal welfare is concerning. Given the focus appears to be only on constructing buildings in a way that neighbours are not inconvenienced by the sight or sound of racing greyhounds, these guidelines are wholly inadequate for improving animal welfare. They appear to be aimed at improving public perception of the industry only.