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Griffin Centre, Genge St, Civic ACT

GPO Box 2259, Canberra ACT 2601

We live and work on stolen land and acknowledge its Traditional Owners. We pay respect to Elders, past, present and emerging, and recognise that sovereignty has never been ceded.

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 on proposals to change the law affecting animals. Below are the submissions the Animal Defenders Office (ADO) has made since its inception in December 2013.

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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.

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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.

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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!

ADO Animal Legal Centre - Submissions
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.

 

ADO Animal Legal Centre - Submissions
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.

 

ADO Animal Legal Centre - Submissions
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.

 

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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.

 

ADO Animal Legal Centre - Submissions
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.

 

ADO Animal Legal Centre - Submissions
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.

 

ADO Animal Legal Centre - Submissions
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.

 

ADO Animal Legal Centre - Submissions
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.

 

ADO Animal Community Legal Centre - Submissions
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.

ADO Animal Legal Centre - Submissions
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!!

ADO Animal Legal Centre - Submissions
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.

ADO Animal Legal Centre - Submissions
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.

ADO Animal Legal Centre - Submissions
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.

ADO Animal Legal Centre - Submissions
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.

ADO Animal Legal Centre - Submissions
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.

ADO Animal Legal Centre - Submissions
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.