AVS has opened up a Public Consultation for Proposed Revised Licensing Standards for Pet Breeders and Boarders at https://form.gov.sg/#!/60cfff4dc694c200110fb388
Please lend your voice and provide your feedback on the points raised.
The full text of our feedback is set out below:
A. PROPOSED LICENSING APPROACH
The Cat Welfare Society (“CWS”) supports the call for mandatory licensing for all commercial breeding and boarding activities. The primary purpose of such licensing must be to protect the welfare of the animals being bred and their offspring.
We are however concerned about the omission of breeders specifically who carry out such activities on a “small scale” or “non-commercial basis”. This group of breeders, more commonly and accurately known as backyard breeders, are one of the greatest contributors to breaches in animal welfare.
There are numerous instances of these backyard breeders putting up their home-bred litters for sale as this article shows – https://www.channelnewsasia.com/news/singapore/adopt-kitten-adorable-pets-in-demand-backyard-breeders-avs-11499252
When the demand does not keep up with the supply, we see situations such as this case of 94 cats in a three room flat arise – https://www.straitstimes.com/singapore/94-cats-rescued-from-3-room-sengkang-flat-ava-investigating
We therefore respectfully request that the mandatory licensing requirement be extended to all individuals who breed animals, whether commercially or non-commercially within homes or other non-farmland areas, to protect the welfare of the animals in questions.
We also have the following specific queries:
- How does AVS define a “commercial sale”?
- How will AVS define an accidental breeding?
- How will AVS verify that an individual only breeds one litter a year at his residential premises? If there is more than one litter a year, will there be an automatic presumption of an intention to breed within the premises?
- How will AVS verify that the individual has given the offspring away as opposed to selling the offspring off?
- What is the definition of “advertising” in this context – will social media posts or text messages be considered advertising? Will an advertisement lead to an automatic presumption of a commercial sale to reduce the evidential burden?
- If an individual refuses to neuter his animals of different sexes, short of the animals being separately contained within the house, how does AVS propose to deal with the case of multiple “accidental” litters? Would AVS consider requiring the sterilisation of at least one of the sexes of the animal in question to ensure no further breaches of the law?
B. PROPOSED REVISED LICENSING STANDARDS FOR PET BREEDERS
On the subject of the revision of licensing standards for pet breeders, we request clarity on why cat breeders have been omitted from the need for licensing standards.
Cat breeders should be held to a high level of scrutiny, the same way that dog breeders are. The four key areas set out in the feedback form should apply equally to cats.
We also have the following specific questions:
- Does AVS conduct proactive monitoring without notice to obtain a true indication of the welfare of the animals within the breeders’ control?
- Will AVS be prescribing a timeframe for “prompt veterinary advice” and “immediate veterinary attention”?
- How will AVS verify that no in-breeding has occurred?
- What is the remedy for an animal that is found to have chronic and untreatable genetic conditions? Will the parent animals be required to be retired from breeding?
C. PROPOSED REVISED LICENSING STANDARDS FOR PET BREEDERS
On the subject of the revision of licensing standards for pet breeders, we request clarity on why cat breeders have been omitted from the need for licensing standards.
Cat breeders should be held to a high level of scrutiny, the same way that dog breeders are. The four key areas set out in the feedback form should apply equally to cats.
We also have the following specific questions:
- Does AVS conduct proactive monitoring without notice to obtain a true indication of the welfare of the animals within the breeders’ control?
- Will AVS be prescribing a timeframe for “prompt veterinary advice” and “immediate veterinary attention”?
- How will AVS verify that no in-breeding has occurred?
- What is the remedy for an animal that is found to have chronic and untreatable genetic conditions? Will the parent animals be required to be retired from breeding?