VERY IMPORTANT CONSULTATION DOCUMENT - PLEASE RESPOND!! This could have such a big impact on our industry

26^th January 2021

NSA NEEDS YOU TO HAVE YOUR SAY: Members will no doubt be aware of the active Defra and Welsh Government consultation on ‘Improvements to animal welfare in transport’ with responses required by 26th February. A similar consultation is being conducted by Scottish Government with a similar closing date .NSA will be responding in detail, but is also encouraging as many members as possible to take part to ensure a high number of responses are made. NSA appreciates the length of this consultation and if you cannot face the whole thing, we’d suggest you respond to the key areas below. NSA highlights its recommendations:

1. Banning of live exports for slaughter/fattening (Q5-9) – NSA does not feel it would be right to suggest which way you respond to this. Our response will state that while we would not oppose measures to ensure high welfare conditions in lambs live exported for slaughter or further finishing, we do not believe it is right to close the door on this trade. In terms of welfare conditions in transport, there is no difference in requirements for transporting breeding and slaughter stock and we cannot see the justification for banning one class of animals. NSA would welcome proper and consistent enforcement of the regulations. 
2. Maximum Journey Times (Q10) – The key point for many farmers is what constitutes a journey. For sheep sold through markets or collection centres a journey currently starts when sheep leave there to travel to an end destination. Defra is proposing that a journey starts from when sheep leave the farm, including the time spent at market/in a collection centre, and also the onward journey. If the proposed 21-hour limit is reached animals would need to be rested for 48 hours before continuing. While this is a suggestion from FAWC they also accept there is inadequate research or evidence to support making this change. NSA would encourage a response that states you understand there is no evidence to support this proposal. NSA urges you to respond to Q13 and Q14 if this directly impacts your business.
3. Temperature ranges (Q19) – A ban is proposed on all journeys where external temperature fall outside 5-30^oC (with a variance tolerance built in). Our industry prides itself on being outdoor and extensive in nature, with sheep that are known to cope well with temperatures of -10C. It would also be completely impractical and cause unmanageable problems at abattoirs. NSA does accept that heat stress can be a problem but encourages a response that says this proposal is unnecessary, impractical, and that there is no evidence of any benefits to sheep welfare. NSA urges you to respond to Q20 if this directly impacts your business.
4. Headroom (Q27) – The consultations are proposing a minimum headroom of 22cm for sheep which would result in many of our livestock trailers and lorries not meeting minimum requirements. No account is taken of breed or age variation and few trailers or decks are variable in their settings. Adequate ventilation and air flow are important for good welfare but there is insufficient research or evidence to make any decisions on this without further work. NSA encourages responses that suggest no decisions should be taken until further evidence is available. NSA urges you to respond to Q29 if this directly impacts your business.

It has been confirmed that journeys of less than 65km are exempt from the proposals, but they apply to all journeys in excess of 65km, including pedigree sales and shows. It is worth noting that the data used to advise these proposed legislation changes stems from limited scientific evidence that is incomplete. Joint industry efforts are currently being made to extend the consultation deadline to allow industry to work with Defra to carry out vital impact assessments. 
The current deadline is 26th February, so please complete your response soon at: https://consult.defra.gov.uk/transforming-farm-animal-health-and-welfare-team/improvements-to-animal-welfare-in-transport/