ANIMAL
DEFENDERS
OFFICE
Submissions
Part of the Animal Defenders Office's mission is to raise awareness about how our regulatory frameworks adversely impact animals. An important way of doing this is by making submissions to inquiries on issues and law reform proposals that affect animals and human choices. Below are the submissions the Animal Defenders Office (ADO) has made.
2024 SUBMISSIONS
In 2024 ADO volunteers have made the following submissions on animal law and related issues:
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12 JANUARY 2024: Submission to the Victorian Parliament's Upper House Inquiry into Pig Welfare in Victoria. Our submission is #265 on the Inquiry's webpage. You can read our submission here.
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2 FEBRUARY 2024: Submission to the Australian Government's Review of the Code of Practice on the Humane Treatment of Wild and Farmed Australian Crocodiles.You can read our submission here.
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20 FEBRUARY 2024: Submission to the 2023 Inquiry into the operation of the approved charitable organisations under the Prevention of Cruelty to Animals Act 1979.The inquiry is conducted by the Portfolio Committee - Regional NSW of the Upper House of NSW Parliament. The ADO's submission is #2 on the Inquiry's webpage. You can read our submission here.
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19 MARCH 2024: Submission to the ACT Legislative Assembly's Inquiry into Petition 17-23: Indian (Common) Myna Control. Our submission is #52 on the Inquiry's submissions webpage.You can read our submission here.
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25 MARCH 2024: Submission to the Victorian Government's public consultation on the draft Animal Care and Protection Bill (VIC). You can read our submission here.
2023 SUBMISSIONS
In 2023 we made the following submissions on animal law and related issues:
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31 January 2023: Submission to the Eurobodalla Shire Council objecting to the proposed grant of a 5-year rodeo licence. You can read our submission here.
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21 April 2023: Submission to the NSW Government's statutory review of the Biodiversity Conservation Act 2016. You can read our submission here.
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5 May 2023: Submission to the Productivity Commission's public inquiry into philanthropy, especially the exclusion of animal advocacy organisations from deductible gift (donations) schemes.You can read our submission on the inquiry's website: #184.
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8 May 2023: Submission to the Victorian Parliament's select committee inquiry into Victoria's recreational native bird hunting arrangements. You can read our submission here.
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2 August 2023: Submission to the public consultation process on DA-202341697 - Ginninderry Conservation Corridor ACT about the impact of the development on local wildlife including wombats. Our submission is here.
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11 August 2023: Submission to the NSW Government's public consultation into NSW rental laws, especially about keeping pets. Our submission is here.
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16 August 2023: Submission to the Australian Senate's inquiry into a bill to ban the export of greyhounds for racing and other commercial purposes. We published a GUIDE TO THE BILL to help people write their submissions. Our submission is here.
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18 August 2023: NSW Parliamentary inquiry into pounds. Our submission (#116) is here.
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11 September 2023: Submission to the public consultation process on proposal to use aerial shooting of wild horses in the Kosciuszko National Park Wild Horse Heritage Management Plan. Our submission is here.
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16 October 2023: Submission to the NSW Parliamentary Inquiry into the proposed aerial shooting of Brumbies in Kosciuszko National Park. Our submission (#163) is here.
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6 November 2023: Submission to the independent review of the Commonwealth Government's National Legal Assistance Partnership (NLAP). Our submission as published on the NLAP Review's website is here.
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15 December 2023: Submission on Queensland's Agriculture and Fisheries and Other Legislation Amendment Bill 2023 and in particular, the proposed amendments to the Animal Management (Cats and Dogs) Act 2008. See our submission (#46) on the inquiry's website here.
SUBMISSIONS 2014-2022
Plan for Victoria’s new animal care and protection laws
In September 2022 the Victorian Government released its Plan for Victoria's new animal care and protection laws for public consultation. The ADO made a submission commenting on aspects of the Plan, including recognition of sentience, species of animals included in the definition of 'animal', replacing codes of practice with regulations, and exempting activities that harm animals from the application of the proposed new laws. You can read our submission here.
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Game and Feral Animal Control Regulation 2022 (NSW)
In 2022 the NSW Government proposed new laws that would make hunting animals even easier. The proposed Game and Feral Animal Control Regulation 2022 was based on feedback received from ‘hunting stakeholders’ and released for public consultation. The ADO made a submission objecting to the proposed regulation on the grounds that it permitted cruelty to animals and harming animals in the name of recreation. When gun violence is out of control around the world, we submitted that now is definitely not the time to be encouraging adults and children to be killing things with guns and other lethal weapons. You can read our submission here.
Fortunately the final Regulation was released on 1 September 2022, and two of the most concerning proposals were scrapped: allowing children under 12 to get hunting licences and allowing 16 & 17 year olds to hunt unsupervised.
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Inquiry into the QLD Animal Care and Protection Amendment Bill 2022
On 12 May 2022 the Queensland Government introduced the Animal Care and Protection Amendment Bill 2022 into the Queensland Parliament. The Bill was referred to the State Development and Regional Industries Committee for consideration. The ADO made a written submission (#900) and was invited to give evidence at a public hearing of the Inquiry on 15 June 2022. ADO lawyers Sarah Margo and Tara Ward appeared by videolink. More about the Inquiry is available here.
Inquiry into the use of primates and other animals in medical research in NSW
A NSW parliamentary inquiry was established on 3 December 2021 to inquire into and report on the use of primates and other animals in medical research in NSW. The ADO lodged a written submission in April 2022 and ADO lawyers Sarah Margo and Tara Ward gave evidence at the public hearing on 16 May 2022. Given the inherently cruel nature of invasive medical research on animals, the ADO supports phasing out the use of animals in medical research in favour of modern, more humane, and more reliable methods and technologies. Our written submission (#245) is available here. More information about the Inquiry is available here.
Consultation for an Australian Openness Agreement on Animal Research
Millions of animals are bred and used for medical research in Australia each year. They are subjected to painful procedures and/or killed, regardless of whether they are used or surplus to requirements. Very little is known about the research or the harmful procedures inflicted on the animals. In 2014 the UK released the first 'openness agreement' between organisations that wanted to demonstrate a commitment to greater transparency in their use of animals for research or teaching. A proposed Openness Agreement for Australia was released for comment in February 2022. The ADO provided written feedback on 21 March 2022. More information about the Australian Openness Agreement is available here.
Proposed intensive dog breeding facility on NSW Central Coast
On 11 March 2022 the ADO provided written objections to Central Coast Council in NSW regarding Development Application No 97/2020/A for a ‘Modification to Existing Approval for Use of Existing Property for the Purpose of an Animal Boarding & Training Facility – Dog Breeding’ ("DA"). The ADO strongly urged the Council to reconsider making an exception for the relevant land to be used as a dog breeding facility, and to refuse the continued use of the land for such a purpose. More information about the DA can be found here.
NSW parliamentary inquiry into puppy farming
A special parliamentary inquiry has been established to look into and report on puppy and kitten farming in New South Wales (NSW). The terms of reference include examining the exciting Bill that has been introduced to crack down on intensive breeding of cats and dogs. The Bill is called the Companion Animals Amendment (Puppy Farms) Bill 2021. To help people have their say about the Bill and puppy/kitten farming in general, the ADO released an information sheet available here. More information about the Parliamentary inquiry is available here. The ADO's submission was lodged on 7 March 2022 and is available on the Inquiry webpage (#6).
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Inquiry into approved charitable organisations under POCTA Act (NSW)
The NSW Upper House's Portfolio Committee No. 4 – Regional New South Wales, Water and Agriculture recently announced it will hold an annual
inquiry into the operation of the charitable organisations approved under s 34B of the Prevention of Cruelty to Animals Act 1979 (NSW). For the inaugural inquiry in 2022 an online questionnaire was open to the public until Monday 28 February 2022. It was an opportunity for members of the community to provide their views on whether there is enough transparency about how the current private charity enforcement agencies, RSPCA and AWL, operate and whether they are sufficiently funded to protect animals properly. The ADO's responses to the questionnaire are here. The Inquiry Committee invited the ADO to appear at the Inquiry hearing. ADO's Principal Solicitor, Tara Ward, gave evidence at the hearing on Monday 28 March 2022 in Parliament House NSW.
Inquiry into the Animal Welfare Bill 2022 (NSW)
2022 got off to a huge start for animal law reform, with the NSW Government releasing an entirely new animal welfare statute for consultation! The NSW Parliament is holding an inquiry into the new law and animal welfare policy in general. The new law is called the Animal Welfare Bill 2022.
To help people have their say about the Bill, the ADO released a Guide to the Animal Welfare Bill which is available here.
More information about the Parliamentary inquiry is available here. The ADO's submission was lodged on 4 March 2022 and is available on the Inquiry webpage (#146). The Committee of Inquiry invited the ADO to appear at the Inquiry hearing. ADO's Principal Solicitor, Tara Ward, gave evidence at the hearing on 21 March 2022 in Parliament House NSW.
Proposed new greyhound racing track in Queensland
The Queensland Government has announced the creation of the Greater Brisbane Greyhound Centre ("GBGC"), including greyhound racing tracks, at Purga, near Ipswich in South East Queensland. In our view the archaic and barbaric practice of greyhound racing should be phased out in Australia rather than expanded through projects such as the GBGC. The ADO made a submission to the Government's public consultation period in February 2022. ADO's submission is available here. More information about the GBGC is available here.
Inquiry into Public Health Amendment Bill 2021 (No 2) (ACT)
On 2 December 2021 the ACT's Legislative Assembly referred the Public Health Amendment Bill 2021 (No 2) to the Standing Committee on Health and Community Wellbeing for inquiry. Information about the Assembly's inquiry is available here. As the ADO's mission is to use the law to protect the interests of animals and to enable compassionate choices for humans, the ADO made a submission to the inquiry on 14 January 2022. The ADO's submission is available on the inquiry's website here.
NSW Consultation Paper - Licensing and regulation of dog and cat breeders
In November 2021 the NSW Government released a Consultation Paper about regulating dog and cat breeders in the State. The Consultation Paper is written by the NSW Department of Primary Industries ("DPI"). The DPI is seeking views from the community about its proposals.
To help people have their say about how dog and cat breeders should be regulated, the ADO released a Guide to the Consultation Paper.
More information about the Government's review is available here.
The ADO's submission was lodged on 31 December 2021 and is available here.
NSW Animal Welfare reform -
DPI Discussion Paper 2021
In 2021 the NSW Government continued its review of the State's animal welfare legislation, including the Prevention of Cruelty to Animals Act 1979. After releasing an Issues Paper for consultation in 2020 (see our submission below), the Government published a Discussion Paper in July 2021 and sought the community's views on its reform proposals by 17 September 2021. To help people get started we put together a Guide to the Discussion Paper. We lodged our submission to the Inquiry on 17 September 2021. Our submission is available here. More information about the Government's review is available here.
Senate inquiry into plant-based food labelling
The Australian Senate has instigated an Inquiry into the 'current state of meat category branding in Australia'. The Inquiry is being run by the Senate Rural and Regional Affairs and Transport Legislation Committee, and is looking at the 'definitions of meat and other animal products' or, in lay terms, how plant-based products are labelled. The inquiry is based on the premise that the current labelling of plant-based products is misleading and threatens the viability of equivalent products made from or with animals or animal products. As the ADO's mission includes using the law to enable compassionate choices for humans, we made a submission to the Inquiry in August 2021.Our full submission is #135 on the Inquiry's website. The ADO was invited by the Committee to give evidence at a public hearing of the Inquiry. On 17 September the ADO's co-founder and volunteer managing solicitor joined with representatives from Animal Liberation Queensland and the Animal Justice Party on the 'animal rights panel' to give evidence and respond to questions from Senators. The hearing can be viewed here.
The Inquiry report is due by February 2022.
Draft NSW Commercial Kangaroo Harvest Management Plan 2022–26
In 2021 the New South Wales Department of Planning, Industry & Environment released the draft NSW Commercial Kangaroo Harvest Management Plan 2022–26 for consideration as an approved wildlife trade management plan under the Environment Protection and Biodiversity Conservation Act 1999 (Cth) (EPBC Act). The consultation period closed in July 2021, well before the release of the report by the NSW Legislative Council's Portfolio Committee No. 7 – Planning and Environment parliamentary committee report containing the findings and recommendations from its inquiry into the health and wellbeing of kangaroos and other macropods in that State. The committee's report is due by 14 October 2021. In our comments on the draft commercial killing plan we recommended that a decision under the EPBC Act in relation to the plan should await the release of the committee's report. More on the draft plan can be found here. Our submission is available here.
Review of Queensland's animal welfare legislation
In 2021 the Queensland Government started a review of the State's primary animal welfare legislation, the Animal Care and Protection Act 2001. A public consultation period is open until midnight Friday 21 May 2021. The Government has published a Discussion Paper and is seeking the community's views on issues raised in the Paper. To help people make a submission we put together an information sheet, available here. More about the Government's review is available here.
NSW Inquiry into health and wellbeing of kangaroos and other macropods
A NSW parliamentary committee has established an inquiry into the health and wellbeing of kangaroos and other macropods in New South Wales. Information about the inquiry is available from the NSW Parliament's website: https://tinyurl.com/24fhneup. To help people make a submission we put together an information sheet, available here. Submissions were due by Monday 26 April 2021.
The ADO made a submission supported by leading animal law organisations Voiceless, the Animal Law Institute, and the Australasian Animal Law Teachers and Researchers Association (AALTRA). Our submission is #234 on the NSW Parliamentary Inquiry website. ADO lawyers were invited to give evidence at the Inquiry hearing on 11 June 2021. The parliamentary committee's report was released on 15 October 2021 and is available here. The ADO’s joint submission is cited throughout the report. The Government's response is due by 19 April 2022.
Review of Victoria's animal welfare legislation
In October 2020 the Victorian Government opened public consultation on proposals for a new animal welfare Act. The new legislation would replace the Prevention of Cruelty to Animals Act 1986. In December 2020 the ADO made a submission to the Government on the broad proposals for reform. Our submission is available here. More about the Government's review is available here.
Review of ban on importation of parrots as pets into Australia
The Australian Government is looking to lift a ban on importing exotic parrot species into Australia, and has released a draft report for the 'import risk review for psittacine birds from all countries'. The ADO holds serious concerns for the welfare of birds who are kept in cages and used for breeding or showing or sold as ‘pets’. There are few welfare controls. The ACT and NSW have codes of practice for keeping birds in captivity, but they were written over 20 years ago in 1995 and 1996 respectively. It is not clear how the codes are enforced. More about the Government's review is available here. We made a submission during the public consultation phase on the draft report on 19 September 2020. Our submission is available here.
Commonwealth inquiry into cats in Australia
The Commonwealth Standing Committee on the Environment and Energy resolved on 18 June 2020 to conduct an inquiry into what it called the 'problem of feral and domestic cats in Australia'. The ADO made a submission to the Inquiry. We acknowledged the sentience of all cats regardless of their classification by humans and stated that while we support measures to protect ecosystems and eco-communities that have been significantly affected by humans, we do not support any protection measures that cause pain or suffering to individual sentient animals. More about the Inquiry is available here. Our submission (No. 136; submitted 30 Jul 2020) is available on the submissions page here.
NSW Bill to ban mulesing sheep and to require pain relief for other practices
More important animal law reform is proposed in NSW, this time by the Hon. Mark Pearson from the Animal Justice Party and member of the NSW Parliament's Upper House. The Hon. Mark Pearson has introduced into Parliament the Prevention of Cruelty to Animals Amendment (Restrictions on Stock Animal Procedures) Bill 2019 ('the Bill'). The Bill proposes a BAN on the cruel practice of 'mulesing', where farmers slice chunks of flesh from a sheep's backside without any pain relief. It is very painful for the sheep, who are often young lambs when it happens. The Bill also proposes to introduce a mandatory requirement for pain relief when conducting other husbandry practices on animals such as castrating, branding, or dehorning them.
The NSW Parliamentary Committee in 'Industry' matters conducted an inquiry into the Bill and sought comments from the public by online survey or submission. The ADO published a one-page info sheet on the Bill here. Our submission (No.21) is available on the inquiry webpage here. On 11 August 2020 our Executive Director gave evidence at the oral hearings at NSW Parliament House as part of the inquiry. In September 2020 the Committee handed down its report, which rejected the Bill.
NSW Animal Welfare Reform -
DPI 'Issues Paper'
Big animal law reform is coming for NSW! The Department of Primary Industries (yes, that is the government entity responsible for animal welfare in NSW), wants to reform the State’s animal welfare laws. As part of that process it released an ‘Issues Paper’ with its priorities and invited the public to do a survey or put in a submission: https://tinyurl.com/yctvnt9r. To help people contribute to the consultation process we put out a guide, available here. Our submission was lodged on 21 June 2020 and is available here.
Development application for intensive piggery in Harden NSW (Take 2!)
At a time when Australia is demanding the closure of intensive live animal markets in other countries, it is beyond comprehension that we could contemplate building new intensive animal facilities in our own backyard. But an intensive piggery company is trying AGAIN to build a facility in Harden NSW, confining tens of thousands of pigs inside for their entire lives. The community opposed the company’s application the first time round, and won (see below, 2016-2017 submissions)! In mid 2020 during COVID-19 lockdown we hit our keyboards to object to the new application on animal and human welfare grounds. Our objections were lodged in May 2020 and are available here. You can sign a petition against the proposed piggery here.
Draft NSW Greyhound Welfare
Code of Practice 2020
We didn’t miss the chance to comment on the draft NSW Greyhound Welfare Code of Practice. The draft code is part of the NSW Government’s backflip on a ban on greyhound racing, opting instead to try (yet again) to regulate the industry. The code proposes minimum industry standards for things such as kennel size, breeding, and ‘retirement’ of racing dogs, so it was important to have a say on these and other welfare issues. Our submission on the proposed new code was lodged in April 2020 and is available here.
On 2 September 2020 the ADO also completed the online survey into the review of the Greyhound Act 2017 (NSW).
WA's 'ag-gag' Bill 2020
Another uniquely Australian ag-gag law was put out for public consultation early in 2020. The Animal Welfare and Trespass Legislation Amendment Bill 2020 (WA) tries to have it both ways. It at least acknowledges there is a problem with transparency so the Bill purports to augment official inspections of animal agriculture facilities and slaughterhouses, while at the same time increasing penalties and deterrence measures for trespassing on agricultural land. It proposes a mandatory minimum sentence for ag trespasses of community service and a fine of at least $2,400! And conversely, it doesn’t contain any measures to ensure official inspections actually take place. Our submission on the proposed new law was lodged in March 2020 and is available here.
Review of the Australian commercial code of practice for shooting kangaroos
A proposed new code of practice for the commercial shooting of kangaroos was released in 2019 for public comment. It arose out of a review of the existing code conducted by AgriFutures, a statutory authority funded by the Federal Government under the Primary Industries Research and Development Act 1989. While AgriFutures thinks shooting kangaroos for profit is a good thing and can be done humanely, we disagree with both these assumptions. Our submission on the proposed new code was lodged on 31 December 2019 and is available here.
Select Committee on Animal Cruelty Laws in New South Wales
On 8 August 2019 the NSW Parliament’s Upper House established a committee to inquire and report on the effectiveness of arrangements for the administration and enforcement of the laws of New South Wales for the protection of animals from cruelty. On 6 December 2019 the ADO made a written submission to the Inquiry, which is available here. In short, we submitted that by delegating investigation and enforcement functions to private charities with extremely limited funding and resources, the current legal framework will never be able to detect, prevent and deter cruelty to animals, and especially to farm animals, at a level that is acceptable by today’s community standards. Our submission calls for the creation of an independent statutory authority with responsibility for enforcing animal protection laws in NSW. On 13 February 2020 our lawyers travelled to Sydney to give evidence at the inquiry hearing. You can watch our lawyers in action at the inquiry here. The committee’s report was released on 4 June 2020 and is available here. The NSW Government's response to the committee's recommendations was released on 4 December 2020 and is available here. Spoiler alert: it is extremely disappointing.
NSW inquiry into the use of exotic animals in circuses and the exhibition of cetaceans
On 26 September 2019 the NSW Parliament’s Upper House established an inquiry into the use of exotic animals in circuses and the exhibition of cetaceans (dolphins and whales) in New South Wales. Our written submission to the inquiry is available here. In our submission we state our opposition to the practice of breeding or keeping exotic animals for use in circuses and cetaceans for exhibition. We also express our support for legislative bans on keeping and breeding cetaceans for exhibition purposes, and on the keeping, breeding and transporting in or through NSW of exotic animals for use in circuses. On 14 August 2020 our volunteer lawyers gave evidence at the oral hearing into the inquiry. We gave our evidence by phone from our office in Canberra. The inquiry report was handed down in December 2020 and is available here.
NSW Government’s Right to Farm Bill and new trespass penalties
The NSW Government’s Right to Farm Bill was yet another proposed anti-animal activist law released in 2019. By way of background, previously proposed ‘right to farm’ bills, such as the Protection of Agricultural Production (Right to Farm) Bill 2005 (NSW), were introduced not to hinder the actions of animal rights or climate activists, but to protect farms against urban sprawl – ie to limit ‘purchasers of land adjoining or adjacent to rural land’ from bringing legal proceedings against their neighbours using their land for agricultural purposes. A NSW parliamentary inquiry into the 2019 Bill was established on 24 September 2019. Our written submission against the Bill is available here. The ADO was invited to give evidence at the Inquiry’s public hearings in Sydney on 3 October 2019. A transcript of our oral evidence is available here (from p35).
Draft Prevention of Cruelty to Animal Regulations 2019 (VIC)
On 28 August 2019 the Victorian Government released draft new Prevention of Cruelty to Animal (‘POCTA’) Regulations 2019 for public comment. The ADO’s written submission on the new draft regulations is available here. In short, we supported the proposals to ban mulesing sheep, leaving animals in vehicles on hot days, certain types of fruit netting, and glue traps. However, we did not support arbitrary exemptions from offences in relation to certain types of 'unpopular' animals (leaving them unprotected under the law). In relation to traps and rodeos, we urged an outright ban of these practices, and submitted that the proposed regulations were not sufficient to prevent harm and distress to the animals involved. The new regulations came into effect on 14 December 2019.
Agriculture and Other Legislation Amendment Bill 2019 (QLD)
In August the Queensland Labor Government released an ‘omnibus’ bill, 80 pages long, with 'ag-gag' (ie anti-animal activist) provisions sprinkled throughout. The public consultation period was absurdly short (c.2 weeks), but we managed to make a written submission (#6) registering our strong opposition to the provisions targeted at animal activists' right to speak out against injustice to animals. Our submission is available here.
Inquiry into the Impact of Animal Rights Activism on Victorian Agriculture
In May 2019 the Economy and Infrastructure Committee of the Victorian Upper House established an inquiry into ‘the effectiveness of legislation and other measures to prevent and deter activities by unauthorised persons on agricultural and associated industries’. Our submission to the inquiry was lodged on 2 August 2019 and is available here.
Criminal Code Amendment (Agricultural Protection) Bill 2019 (CTH)
On 4 July 2019 the Australian Government introduced the Criminal Code Amendment (Agricultural Protection) Bill 2019. The Bill proposed new criminal offences of using the internet or a mobile phone to distribute material which could be construed as intending to incite others to enter onto agricultural land. The Bill was widely regarded as an attempt to gag animal activists, or an 'ag-gag' law. The Bill was referred to the Australian Senate Legal and Constitutional Affairs Legislation Committee. Our written submission to the Committee’s inquiry opposing the Bill is #51 on the Committee's webpage.
ADO lawyers also gave evidence at the Committee’s public hearings into the Bill on 12 August 2019. The transcript of our oral evidence is available here.
Unfortunately this Commonwealth ag-gag law was passed by both Houses of the Australian Parliament and commenced on 20 September 2019.
Inquiry into use of battery cages for hens in NSW egg production industry
The newly elected Emma Hurst MLC, member of the NSW Animal Justice Party, hit the ground running and in the first weeks of her term had established a ground-breaking parliamentary inquiry into the use of battery cages for hens in the egg production industry in NSW. The ADO’s written submission to the inquiry is available here.
ADO lawyers were invited to give oral evidence at the inquiry's public hearings. We spoke in favour of a complete legislative ban on battery cages, and cited the ACT as a precedent. The transcript of our oral evidence is available here (from p14).
The inquiry report is here. We recommend The Hon. Emma Hurst’s powerful dissenting statement at pp110-111.
ACT Pest Plants and Animals (Pest Animals) Declaration discussion paper
The ACT's Pest Plants and Animals (Pest Animals) Declaration (the declaration) identifies which animals are declared as 'pest' animals in the ACT. A discussion paper was released regarding proposed changes to the declaration. The ADO's comments on the proposed amendments to the declaration are available here.
ACT Government's draft Cat Plan 2019-2029
Approximately 25% of households in the ACT have a pet cat. In April 2019 the ACT Government released a draft cat management plan for public comment. The ADO's submission to the public consultation process is available here.
Objection to Development Application re piggery in rural NSW
The ADO contributed to another grass-roots campaign to stop the expansion of an intensive piggery in rural NSW. In support of the Say No to Pig Improvement Company's Expansion In Matong campaign we lodged a submission opposing the proposed piggery. In short, we submitted that the development application would be bad for animals, people and the environment!
The ADO's submission against the proposed development application was made on 13 May 2019 and is available here.
Draft animal welfare legislation amendments in the ACT
The ADO welcomed the opportunity to comment on the ACT Government's draft Animal Welfare Legislation Amendment Bill 2019 (“draft Bill”). In particular we welcome the intention and spirit of the draft Bill, and support many of its initiatives. We particularly support the recognition that animals are sentient beings with intrinsic value, and acknowledge that the ACT would be the first jurisdiction in Australia to make such a change. We congratulate the ACT Government for again leading the country on animal law initiatives.
The ADO's detailed submission on the proposed amendments was made on 7 February 2019 and is available here.
Revised Australian Standards for the Export of Livestock
On 27 November 2018 the ADO lodged a submission on the revised Australian Standards for the Export of Livestock (known as 'ASEL'). Our conclusion: "The ADO submits that the live export industry is inherently incapable of providing an acceptable standard of animal welfare, and that the draft revised Standards will not alter this. We submit that it is not possible to deliver acceptable animal welfare standards for exported livestock within an industry that is also viable, ethical and acceptable to the community. ...There is strong community support for the cessation of the live export trade. The ADO also supports the cessation of the industry as soon as possible."
The ADO's submission is here.
City of Canterbury Bankstown's proposed ban on wild animal circuses
The ADO commends Canterbury Bankstown City Council for considering a ban on the use of exotic animals for performance or display on council land, and for putting the Council's proposed circus policy out for public consultation. The ADO lodged a submission on 30 July 2018. In our submission we expressed our support for the proposed ban on circuses 'using' exotic animals. We also suggested that future consideration be given to banning circuses with any exotic animals whether or not the circuses use them (as is the case in the ACT), banning any animal circus from setting up on council land, and supporting a state-wide ban under NSW law. A state-wide ban would stop circuses setting up on private land to get around councils' bans on setting up on council land. See the Animal Justice Party's proposed legislation to ban animal circuses in NSW here.
The ADO's submission is here.
*Update* Great news from the City of Canterbury Bankstown! On 16 October 2018 its Council formally adopted a policy to ban circuses with wild animals from setting up on Council land!
NSW inquiry - filming or surveilling animal enterprises without consent
In May 2018 the Upper House of the NSW Parliament established a select committee on 'landowner protection from unauthorised filming or surveillance'. Headed by a member of the Shooters, Fishers and Farmers Party, the inquiry will be looking at whether farmers and business operators have enough 'protection' from members of the public who wish to find out what's really going on behind the closed doors of animal enterprises. The inquiry's terms of reference will consider matters such as 'the extent and appropriateness of penalties for unauthorised filming or surveillance'. In our submission we argued that landholders are already very well protected compared to other jurisdictions, and that what needs attention are the pitifully low penalties for animal cruelty offences in NSW - the lowest financial penalties in the country.
Our submission (lodged 8 July 2018) should be available on the Committee's website in due course. You can find out more about the inquiry here.
Constitutional recognition of Aboriginal and Torres Strait Islander peoples
The ADO is founded on principles of social justice and fairness. We aim to pursue justice for all sentient creatures, but believe this can take place only in a country where justice has been achieved for its First Nations peoples. For this reason, on 11 June 2018 we made a submission to the inquiry by the Joint Select Committee on Constitutional Recognition Relating to Aboriginal and Torres Strait Islander Peoples. In doing so, the ADO has respectfully accepted the invitation in the Uluru Statement from the Heart to walk with Aboriginal and Torres Strait Islander peoples in this ‘movement of the Australian people for a better future’. Our submission in support of the Uluru Statement is #104 on the Committee's website here.
Inquiry into trade in elephant ivory and rhinoceros horn
The ADO has made a submission to the Parliamentary Joint Committee on Law Enforcement’s inquiry into the trade in elephant ivory and rhinoceros horn. Our submission supports strengthening ‘existing legislation and administrative arrangements, including through agreements with the states and territories, to reduce the domestic trade in elephant ivory and rhinoceros horn products’ and closing ‘domestic markets for elephant ivory and rhinoceros horn products’ (as per the inquiry's terms of reference). Our submission was lodged in June 2018 and is Submission #55 on the inquiry's website here.
Review of Marine Order 43 - live export vessels
The Australian Maritime Safety Authority (AMSA) recently sought public comments on revisions to Marine Order 43 (Cargo and cargo handling – livestock) 2018, which sets the standards for the safe operation of livestock carriers. In our submission we express our opposition to the live export trade, and call for an immediate phase-out of double-tier vessels. Our submission on the revised Marine Order was lodged in June 2018 and is available here.
Management plan for wild peafowl in Canberra
Peafowl (ie peacocks and peahens) are introduced species but have not been declared an environmental ‘pest’ in any Australian jurisdiction. The ACT Government has released a draft management plan for a colony of 25-30 peafowl who have roamed free in a Canberra suburb for several decades. Over that time the population has remained stable. Now, however, the Government wishes to remove the entire ‘party’ (yes, that’s one of the official terms for a group of peafowl, along with ‘ostentation’ or ‘muster’), and is contemplating killing them. The ADO has several concerns about the draft plan and the broader regulatory framework. Our submission setting out our concerns was lodged in June 2018 and is available here.
Update: in a win for the peafowl, the ACT Government has announced it will not remove the peafowl from their home range in suburban Canberra. Instead it will work with the local community to develop an agreed approach to living with the birds. More on the Government's announcement here.
Code of practice re disturbing flying-fox camps in NSW
The NSW Government is ‘deregulating’ human interaction with wildlife. The latest attempt is to abolish licences for people wishing to disturb flying-fox camps in NSW. Instead, anyone wishing to interfere with flying-fox camps will simply be asked to comply with a proposed code of practice. The ADO raised several concerns about the draft code in our submission, lodged in June 2018. Our submission is available here.
Australian Animal Welfare Standards and Guidelines for Poultry
The ADO was amongst the many thousands of Australians who registered their serious concerns about the national draft Animal Welfare Standards and Guidelines for Poultry. The ADO does not support the keeping of poultry for commercial purposes. However, while it remains legal to do so in Australia, we argued in our submission that the poultry standards and guidelines require significant improvement before they can claim to ‘enhance animal welfare arrangements in all Australian states and territories’ for commercially kept poultry. See what our arguments are based on in the submission we lodged on 26 February 2018, available here. The draft Standards and Guidelines are available here.
ACT Government's proposed 'Animal Welfare and Management Strategy'
The ADO commends the ACT Government for committing, through its draft Animal Welfare and Management Strategy 2017-2022, to promoting animal welfare. The ADO strongly supports the strategy’s vision that ‘the ACT become an Australian leader in animal welfare and management practice’. The ADO also applauds the strategy’s recognition that animals are sentient beings who have the ability to experience a range of sensations and emotions including pain, fear and joy. Our submission on the draft strategy outlines several other commendable aspects of the strategy, as well as some areas that could be improved.
The ADO's submission (lodged 24 May 2017) can be found here. The strategy is available here.
ACT Controlled Native Species Management Plan for Eastern Grey Kangaroos
The ADO has serious concerns about the ACT Government's Eastern Grey Kangaroos: Draft Controlled Native Species Management Plan (the draft plan). The Government prepared the draft plan after the ACT Minister for the Environment radically changed the legal status of Eastern Grey Kangaroos (EGKs) in the ACT with no public consultation or scrutiny. Our concerns about the lack of transparency in this process, and about the significant flaws in the draft plan itself, are set out in our submission to the Government on the draft plan.
The ADO's submission lodged in March 2017 can be found here.
Hawkesbury City Council's proposed ban on wild animal circuses
The ADO commends Hawkesbury City Council for considering a ban on wild animal circuses, and for putting the Council's proposed circus policy out for public consultation. The ADO lodged a submission. In our submission we expressed our support for the proposed ban on circuses 'using' wild animals. We also suggested that future consideration be given to banning circuses with any wild animals whether or not they use them (as is the case in the ACT), banning any animal circus, and supporting a state-wide ban under NSW law. A state-wide ban would stop circuses setting up on private land to get around councils' bans on setting up on council land.
The ADO's submission (lodged 3 February 2017) can be found here.
*Update* In early May 2017 Hawkesbury City Council voted to ban circuses using wild animals from setting up on Council land!!
Development application for new intensive piggery in Harden NSW
In January 2017 the ADO lodged objections to a development application in the nearby shire of Harden in NSW. The application proposes to build a new intensive piggery that would house up to 25,113 ‘SPU’. That’s ‘standard pig units’ in factory-farm language; or ‘animals’ as we know them. It would consist of 21 sheds, where these ‘units’ (pigs) would spend their entire lives. Some of the housing in which the female ‘units’ would be kept is so inhumane that it is banned across the border in the ACT. The piggery would require almost 42,000 litres of clean water a day to run.
The ADO's updated objections (lodged 3 January 2017) can be found here.
The ADO's original objections (lodged 5 February 2016) to the proposal can be found here.
Development application for new intensive piggery in Harden NSW
In January 2017 the ADO lodged objections to a development application in the nearby shire of Harden in NSW. The application proposes to build a new intensive piggery that would house up to 25,113 ‘SPU’. That’s ‘standard pig units’ in factory-farm language; or ‘animals’ as we know them. It would consist of 21 sheds, where these ‘units’ (pigs) would spend their entire lives. Some of the housing in which the female ‘units’ would be kept is so inhumane that it is banned across the border in the ACT. The piggery would require almost 42,000 litres of clean water a day to run.
The ADO's updated objections (lodged 3 January 2017) can be found here.
The ADO's original objections (lodged 5 February 2016) to the proposal can be found here.
Victoria's Draft Action Plan on Animal Welfare 2016-2021
The Victorian Government is reviewing how its animal welfare laws and approaches, and the way it enforces the rules, can be improved. As part of this review the Government published a Draft Action Plan for Animal Welfare for public comment.
On 11 October 2016 the ADO made a submission about the Draft Action Plan. There are aspects of the Plan which the ADO welcomes. However, we have several concerns about the Plan in its current draft state. We discuss the positive and negative aspects of the Draft Plan in our submission.
The ADO's submission about the Draft Action Plan can be found here.
Productivity Commission's Inquiry into the regulation of agriculture and farm animal welfare
The Australian Government has asked the Productivity Commission to undertake a public inquiry into the regulation of farm businesses and farm animal welfare. Among other things, the inquiry will look at the feasibility of establishing an independent body to develop farm animal welfare standards, and to enforce animal welfare laws in the agricultural sector.
The ADO made a submission to the Inquiry about its draft report released on 21 July 2016. The ADO submitted that while animals continue to be farmed in Australia for human consumption, an authority that is independent from agencies that regulate agricultural businesses must be established to avoid any real and perceived conflicts of interest. The ADO also submitted that the independent authority must have monitoring and enforcement functions as the current enforcement of animal welfare laws in the agricultural sector is extremely inadequate. The ADO also made several other recommendations to better protect farm animals.
The Productivity Commission handed its final report to the Australian Government on 15 November 2016. The release of the final report by the Government will be the final step in the process.
The ADO's submission to the Inquiry can be found here.
Proposed changes to regulation of commercial kangaroo shooting in NSW
An ‘exposure draft’ of the NSW Biodiversity Conservation Bill 2016 (the Bill) has been released for public consultation. The Bill proposes a ‘risk-based approach’ to regulating human interactions with wildlife. It will allow people to carry out certain 'lower risk' activities that harm wildlife without obtaining a licence. The government has categorised kangaroo shooting as a lower-risk activity because it is ‘unlikely to harm wildlife populations or impact on animal welfare’. This would mean that commercial kangaroo shooters will no longer need a licence. Instead they would only need to comply with a code of practice: the Draft Code of Practice for Commercial Kangaroo Harvesting in NSW (the draft code). The draft code also advocates that the current ban on skin-only killing be lifted. This activity has been banned in NSW for decades.
The ADO lodged a submission on the draft code in late June 2016. The ADO disagrees with the assessment of kangaroo shooting as 'lower risk', as both kangaroo populations and animal welfare are highly at risk from the kangaroo industry. In our submission we recommend that the draft code not be adopted and the ban on skin-only killing remain in place. If kangaroo shooting is to be allowed at all under NSW law, it should be treated as a high-risk activity requiring significant monitoring and enforcement measures.
The ADO's submission is quoted in the Government's 'Summary of Submissions Report' (p42).
The ADO's submission on the draft code can be found here.
Bill to ban importation of primates for medical research
In January 2016 the ADO lodged a submission on the 'Prohibition of Live Imports of Primates for Research Bill 2015'. The Bill was introduced into the Australian Senate by Greens Senator Lee Rhiannon.
The ADO commends the Bill for its proposed ban on the ‘cruel and inhumane primate trade for experimentation’, and argues that its concern for both biodiversity conservation and animal suffering makes the passing of the Bill essential.
The submission also discusses why future legislation should ban the use of animals for research purposes altogether.
The ADO's submission about the Bill can be found on the Australian Senate's website here (submission No.3).
NSW Special Commission of Inquiry into Greyhound Racing
In July 2016 the NSW Government made the momentous decision to phase out greyhound racing in NSW. The decision was based on the findings of the Special Commission of Inquiry into the Greyhound Racing Industry in NSW. The Inquiry found intolerable animal cruelty in the industry.
Like many animal protection organisations around Australia, the ADO has advocated for a ban on greyhound racing in the ACT and beyond. As part of this campaign, the ADO lodged a submission on the Inquiry's 'Governance and Social Contribution Issues Paper' in January 2016.
In our submission we express our opposition to the greyhound industry on animal welfare grounds, and submit that the welfare problems inherent in the industry cannot be adquately dealt with through 'regulation'. We also pointed to the social discord fostered by the industry in the form of problem gambling, and questioned whether any social contribution by the industry is acceptable when the industry is the source of so much animal suffering.
The Commission's Report quotes the ADO's submission on several occasions.
Click here for the ADO’s response to the Commission's Issues Paper.
ACT 'Pest' Animal Declaration
In November 2015 the ACT Government invited members of the community to have their say on proposed changes to declared 'pest' animals in the ACT. The changes would affect the legal status of certain deer species, cats, certain fish species, European wasps and red foxes.
The ADO does not oppose changing various animals’ status in law. The ADO does, however, recommend against the use of lethal or inhumane 'control' measures that may be permitted by a change in status.
Click here for the ADO’s submission on the proposed changes.
ACT 'Pest' Animal Declaration
In November 2015 the ACT Government invited members of the community to have their say on proposed changes to declared 'pest' animals in the ACT. The changes would affect the legal status of certain deer species, cats, certain fish species, European wasps and red foxes.
The ADO does not oppose changing various animals’ status in law. The ADO does, however, recommend against the use of lethal or inhumane 'control' measures that may be permitted by a change in status.
Click here for the ADO’s submission on the proposed changes.
Free-range egg labelling inquiry
In 2015 States and Territories called for a national standard on free-range egg labelling. In October the Commonwealth Government published a consultation paper in which it outlined various proposals for creating national standards for free-range eggs or all eggs.
The Commonwealth Treasury will use submissions made about the proposals to assess the advantages and disadvantages of introducing a national labelling standard.
Click here for the ADO’s submission in the Government's consultation paper.
EPBC Act amendments - standing to challenge government decisions
In August 2015 the Abbott Government introduced the Environment Protection and Biodiversity Conservation Amendment (Standing) Bill 2015 (the Bill). The Bill sought to limit community organisations' ability to challenge government decisions affecting the environment.
Access to courts to challenge government decisions affecting the environment or animals is a fundamental aspect of our democratic society and an important way to keep governments accountable. The Senate Committee inquiring into the Bill is due to report by the end of February 2016.
The ADO's submission recommending against the amendment can be found on the Australian Senate's website here (submission 127).
NSW Biosecurity Bill 2015 - an 'ag-gag' law?
The ADO made a submission on the Biosecurity Bill 2015 (NSW) while it was debated in the NSW Legislative Council in early September 2015. The Bill proposed new offences that could apply to animal activists who enter commercial animal facilities and who would be deemed ‘biosecurity risks’ under the law. It also proposed to grant broad powers to government officials to confiscate footage and other potential evidence.
The Bill was passed into law on 22 September 2015 (Biosecurity Act 2015 (NSW)) but as of January 2016 was not yet in force.
Click here for the ADO’s comments on the Bill.
Commonwealth ag-gag law:
Criminal Code (Animal Protection) Bill 2015
In February 2015 Senator Chris Back introduced the Criminal Code Amendment (Animal Protection) Bill 2015 (the Bill) to the Australian Senate. The ADO made a joint submission with the Northern Rivers Community Legal Centre, Lawyers for Companion Animals, and Far West Community Legal Centre to the relevant Senate Committee about the Bill. The joint submission’s main concerns are that the Bill targets those who witness animal abuse rather than those who perpetrate the abuse, and that the Bill may deter whistleblowers. The report on the Bill by the Senate Committee was released in June 2015. The Bill is still before the Senate (Jan 2016).
Click here for the joint submission.
NSW pet breeding practices
The ADO was invited to make a submission to the inquiry into Companion Animal Breeding Practices by the NSW Parliament’s Joint Select Committee. In late August 2015 the Committee tabled its report. Unfortunately it does not recommend a ban on selling animals in pet shops. The ADO’s suggestion in favour of a ban or of selling only shelter animals is quoted in the report (5.26). The report also recommends that a common database for reports of animal cruelty and outcomes of prosecutions be established by 1 March 2016, which the ADO supports.
The ADO’s submission can be found on the Committee’s website here.
The Committee’s report is available here.
Review of NSW Greyhound Racing Act 2009
In response to the recent damning investigation by 4 Corners into Australia’s greyhound racing industry, the NSW Office of Liquor, Gaming and Racing extended its review of the Greyhound Racing Act 2009. In its submission the ADO recommends a ban on greyhound racing, on the grounds that it is not possible to provide for adequate animal welfare standards within an industry that is designed to generate profit from the use of animals for ‘sport’. Failing a complete ban, the ADO makes specific recommendations in relation to the many animal welfare concerns inherent in the industry.
Click here for the ADO’s submission on the review of NSW's Greyhound Racing Act 2009.
ALP consultation on animal testing for cosmetics
In 2014 the Australian Labor Party ran a national consultation on phasing out the importation, manufacture, sale and advertising of cosmetics or cosmetic ingredients tested on animals. The ALP also called for submissions on whether or not such a 'ban' should be implemented. Volunteers from the Animal Defenders Office attended the Canberra consultation forum and subsequently lodged a submission expressing support for a ban on animal testing of cosmetic products and ingredients.
Click here for the ADO’s submission on animal testing for cosmetics.
WA shark cull
This submission is made in response to the referral of a proposal to the WA Environment Protection Authority under section 38 of the Environmental Protection Act 1986 (WA). The proposal involves the deployment, management and maintenance of drum lines off the Western Australian Coast, as part of measures announced in December 2013 by the Western Australian Government to deal with the so called "threat" of sharks in the area.
Click here for the ADO’s submission.