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Consultation on Licensing of Activities Involving Animals CaH 31 10 23

Renfrewshire Council · 31 October 2023
Back to Communities and Housing Policy Board — 31 October 2023 and its agenda

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___________________________________________________________________
To: Communities and Housing Policy Board
On: 31 October 2023
___________________________________________________________________
Report by: Director of Environment, Housing & Infrastructure
___________________________________________________________________
Heading: Consultation on Licensing of Activities Involving Animals
___________________________________________________________________
1. Summary
1.1 On 18 August 2021, the Regulatory Functions Board approved a report
outlining new and revised duties regarding certain animal licensing activities
under the Animal Welfare (Licensing of Activities Involving Animals)
(Scotland) Regulations 2021. 
1.2 Scottish Government have now launched a consultation exercise on the
extension of the Animal Welfare (Licensing of Activities Involving Animals)
(Scotland) Regulations 2021 – proposing to licence further commercial animal
related activities, and to replace existing legislation covering animal boarding
and riding establishments. Under these regulations, the Local Authority where
the premises are located is considered to be the relevant licensing authority,
with one specific exception where Scottish Ministers are the licensing
authority. 
1.3 The consultation seeks views on proposals to extend the current licensing
regime to include sectors such as dog walking, dog grooming, providing livery
services and businesses offering canine fertility services.  Any new licensable
activities will have mandatory general and activity-specific conditions attached
– these conditions are proposed to be detailed within the Regulations. 
1.4 The proposal allows for fees to be set locally, which will enable Local
Authorities to recover reasonable costs relating to the processing of
applications, inspections and enforcement activities. There will be resource
implications for the Council, should the provisions of the Regulations be
enacted in full and at this stage these are not fully understood, as the Council
has no information on specific numbers of traders currently operating in
Renfrewshire who will require to be licensed.

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1.5 It is proposed (as is currently the case for existing licensable activities) that
Licences will be issued for either 1, 2 or 3 years and their duration will depend
on a number of factors including previous compliance, confidence in
management of the activity, or whether the licensee is already operating to
higher standards than the minimum set. 
1.6 The response to the consultation was collated from the experience of relevant
services within the wider Climate & Public Protection service including
Environmental Health, Trading Standards & Licensing and the Community
Safety Partnership Hub (Animal Warden).   The response was due to be
submitted by 26 September, and a copy of this response this has been
included in Appendix A.
___________________________________________________________________
2. Recommendations
It is recommended that the Board: 
2.1 notes the consultation proposals, and homologates the submitted response,
as detailed within Appendix A, and
2.2 requests a further report is brought to a future meeting of this Policy Board,
when the regulations have been finalised with an update on implications for
the Service.
_________________________________________________________
3. Background
3.1 The Scottish Government introduced new legislation in 2021 (the Animal
Welfare (Licensing of Activities Involving Animals) (Scotland) Regulations
2021) to regulate certain activities involving animals, which included dog, cat
and rabbit breeding; the sale of animals as pets; animal rehoming premises
and animal welfare premises.
3.2 To improve animal welfare across other areas of currently unregulated
activities, and to modernise legislation which covers certain activities, the
Scottish Government are collating views on a number of areas which they
intend regulating through extension of the 2021 Regulations. This is in
response to a number of concerns raised about potential harm to animals
subject to being in such premises which are detailed throughout each part of
the consultation document. Concerns include, mistreatment, abuse, illegal use
of medicines, overworking and animals being kept within unsuitable
conditions. There are also concerns within some licensable activities of
humans being subject to unsafe practices, putting them at risk as well as the
animals eg, horse riding establishments mis-matching inexperienced riders
with unsuitable horses.

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3.3 New licensable activities include:
 Commercial dog walkers,
 Dog groomers,
 Livery services of all kinds,
 Canine fertility businesses, and
 Greyhound racing (currently only two operational tracks in Scotland).
3.4 The consultation document further proposes to revoke the Animal Boarding
Establishments Act 1963 and the Riding Establishments Act 1964, both being
considered as outdated and not fit for the purposes of licensing such
establishments. Establishments currently licensed under these Acts will
require to transition across to the proposed new licensing regime. It is
possible this may have implications for their business model, in terms of the
premises and staff qualifications and training.
3.5 It is proposed that licensable activities involving animal boarding and riding
establishments will be updated, as follows:
 Catteries and dog kennels,
 Commercial day boarding of dogs,
 Home boarding of dogs,
 Equine activities including horse riding, donkey hire, donkey riding,
pony parties. 
In Renfrewshire, there are around 48 businesses licensed for these activities
under the current legislative regime.
3.6 Board members will note that the response is generally supportive to the
proposals to extend what is considered as a licensable activity under the
Regulations. However, in terms of dog fertility services, the consultation
response recommends that whilst the introduction of a mandatory licensing
scheme is supported, the regulation of this would be better served through an
amendment to the Veterinary Surgeons Act 1966, making it an offence for any
person to engage in canine fertility services unless they meet the
requirements of that Act. This position is predicated on the level of knowledge
and detail of fertility practices required to regulate such activities (and what is
deemed to be medical interventions) being outwith the scope of knowledge
and training of Local Authority officers.
3.7 It is recognised within the consultation response that the proposals - whilst
likely to improve standards in sectors which will be subject to licensing - will
also require a greater input for Inspecting Officers and Local Authorities. This
will place a significant burden on Officers and will require competencies out
with normal enforcement capabilities including animal condition scoring. A
recommendation is made throughout the response that funding to effectively
resource this licensing system is provided by the Scottish Government. It will
be challenging to effectively resource this significant additional work with the
existing resources available to the Local Authority to regulate current animal
licensing services.

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3.8 A further report will be brought to a future meeting of this Policy Board, when
the regulations have been finalised, with an update on implications for the
Service.
___________________________________________________________________
Implications of the Report
1. Financial – minimal impact, as any reasonable costs incurred from the
licensing process are recoverable from the owners of the supply.  
2. HR & Organisational Development – None. 
3. Community/Council Planning – 
 Our Renfrewshire is thriving – regulation of animal welfare and licensing
of persons involved in activities which are subject to a licence will ensure
that operators maintain high standards, are effectively regulated and will
reduce the negative impacts on legitimate businesses from unlicensed
operators. This will provide confidence for businesses and the public
providing or using these services.
4. Legal – None.
5. Property/Assets – None. 
6. Information Technology – None.
7. Equality & Human Rights – 
(a) The Recommendations contained within this report have been assessed
in relation to their impact on equalities and human rights. No negative
impacts on equality groups or potential for infringement of individuals’
human rights have been identified arising from the recommendations
contained in the report. If required following implementation, the actual
impact of the recommendations and the mitigating actions will be
reviewed and monitored, and the results of the assessment will be
published on the Council’s website.
8. Health & Safety – None. 
9. Procurement – None.
10. Risk – None.
11. Privacy Impact – None.
12. COSLA Policy Position – N/A.
13. Climate Risk – N/A.
_________________________________________________________

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List of Background Papers
(a) Background Papers – Minutes of the Regulatory Functions Board of 18
August 2021, Agenda point 8
_________________________________________________________________ 
Author: Colin Hunter, Environmental Health Manager - Public Health  
Email:  colin.hunter@renfrewshire.gov.uk

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Appendix A 
Renfrewshire Council response to the
‘Licensing of activities involving animals’ Consultation 
Full consultation can be viewed at:  https://www.gov.scot/publications/licensing-
activities-involving-animals-consultation-document/ 
 Licensing of commercial dog walkers 
Q1.  Do you agree that dog walking businesses should be subject to a
statutory licensing scheme? 
Yes, Renfrewshire Council supports the introduction of a statutory licensing scheme
for dog walking businesses. Renfrewshire Council has seen an increase in the
number of dog walking businesses over recent years and this has raised concerns
as these are unregulated; dog walkers have been seen with too many dogs to be
safely controlled and being walked in unsuitable environments, often off-lead, which
can pose risks to members of the public, their pets and livestock. Whilst the Council
has a voluntary responsible dog walkers scheme, this is for the general community
and does not include commercial dog walkers and therefore does not bring any
degree of control over dog walking businesses. 
The licensing of dog walking businesses is likely to place additional, significant
burden on local authorities and Renfrewshire Council would recommend funding is
provided by the Scottish Government to allow effective resourcing of a licensing
system for the multiple proposed areas within this consultation document. Without
this funding, it is difficult to see how Renfrewshire Council will have sufficiently
trained Officers to undertake these additional, onerous duties. 
Q2.  If you do not support the introduction of statutory licensing, what
controls, if any, would you otherwise recommend? 
N/A 
Q3.  Do you think that license applicants should be required to hold
recognised, relevant qualifications (for example, in dog behaviour, canine first
aid, animal welfare)? If yes, what level of training do you consider appropriate? 
Yes, Renfrewshire Council would support a requirement that persons in control of
dogs as part of a business have some level of training in dog behaviour, canine first
aid and animal welfare as it will not be possible to demonstrate an understanding of
responsibilities without such training.  The Council has not explored what training is
available for business operators and their staff, however a formal qualification
demonstrates a commitment to learn and develop skills appropriate and necessary
to care for dogs in the course of a business.

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Q4.  Do you agree that the licensing authority should, where appropriate, be
able to stipulate on any licence granted the maximum number of dogs that can
be walked at any one time? 
Yes, it is considered essential that a facility to limit the number of dogs per
responsible person is available within the licensing process and Renfrewshire
Council consider that to exert proper control over dogs, this should be a maximum of
four dogs per responsible person. 
Q5.  Are there any further controls or measures that you would like to see
introduced as part of a licensing scheme for dog walking businesses? 
Renfrewshire Council would recommend and support a full expense recovery model
to fund the proposals for licensing dog walking businesses, including provisions to
introduce a charging scheme for processing a licence application, issuing the licence
and the investigation of complaints and non-compliance with licence conditions. 
Q6.  Do you support the proposal that applicants for a dog walking business
licence are required to demonstrate that they maintain an acceptable level of
record keeping and have clearly set out and established standards of service
and care?  Please provide reasons for your answer. 
Yes. Renfrewshire Council supports this proposal which will be in line with other
animal licensing requirements and will allow local authority enforcement officers the
ability to access information where required as part of the inspection and complaint
investigation process. 
Q7.  Do you know of any challenges or negative consequences that may arise
from the introduction of statutory licensing for dog walking businesses? If
yes, what are they and how best could these be addressed? 
No. 
Q8.  Are you aware of any examples of how any of the proposals above may
impact, either positively or negatively, on those with protected
characteristics?  These are: age, disability, gender reassignment, marriage
and civil partnership, pregnancy and maternity, race, religion or belief, sex and
sexual orientation. 
No - the introduction of a licensing scheme for dog walking will not have any adverse
impact on those with protected characteristics.

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 Licensing dog groomers 
Q1.  Do you agree that dog grooming businesses should be subject to a
statutory licensing scheme? 
Yes. Renfrewshire Council supports the introduction of a statutory licensing scheme
for dog grooming businesses. The significant increase in the popularity of such
businesses has seen a rise in numbers and it is noted that there is minimal
regulation of dog groomers. It is understood and well documented that dog grooming
businesses often offer other services which are outwith the scope of grooming but if
undertaken by untrained staff, could give rise to injury, infection and suffering for
dogs eg anal gland draining. The introduction of a mandatory scheme, with a
requirement for public liability insurance, meeting model standards of operation and
requirements for training/qualifications will see an improvement how dogs are looked
after when in the care of a business. 
The licensing of dog grooming businesses is likely to place additional, significant
burden on local authorities and Renfrewshire Council would recommend funding is
provided by the Scottish Government to allow effective resourcing of a licensing
system for the multiple proposed areas within this consultation document. Without
this funding, it is difficult to see how Renfrewshire Council will have sufficiently
trained Officers to undertake these additional, onerous duties. 
Q2.  If you do not support the introduction of statutory licensing, what
controls, if any, would you otherwise recommend? 
N/A 
Q3.  In your opinion, should any future licensing scheme apply to dog
groomers only or should it apply more widely, for example to all pet animals? 
The licensing scheme should be introduced for all pets who may be subject to
grooming activity, unless there is another scheme already in place to regulate this. 
Q4.  There is currently no requirement for dog groomers to hold any
qualifications (although many do). Do you think that holding a recognised
qualification should be a requirement under any future licensing scheme?  If
yes, what qualification as a minimum should be required? 
Yes, qualification should be required.  Renfrewshire Council would support a
requirement that persons in control of dogs as part of a business have some level of
training in dog behaviour, canine first aid and animal welfare as it will not be possible
to demonstrate an understanding of responsibilities without such training.  The
Council has not explored what training is available for business operators and their
staff, however undertaking qualifications demonstrates a commitment to learn and
develop skills appropriate and necessary to care for dogs in the course of a
business.

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Q5.  Are there any further controls or measures that you would like to see
introduced as part of a licensing scheme for dog grooming businesses? 
Renfrewshire Council would recommend and support a full expense recovery model
to fund the proposals for licensing dog grooming businesses, including provisions to
introduce a charging scheme for processing a licence application, issuing the licence
and the investigation of complaints and non-compliance with licence conditions. 
Q6.  Are you aware of any examples of how any of the proposals above may
impact, either positively or negatively, on those with protected
characteristics?  These are: age, disability, gender reassignment, marriage
and civil partnership, pregnancy and maternity, race, religion or belief, sex and
sexual orientation.  If yes, please explain your answer. 
No. 
 Licensing of livery services 
Q1.  Do you support the proposal to introduce statutory licensing for operators
of livery yards? 
Yes. Renfrewshire Council supports the introduction of a statutory licensing scheme
for operators of livery yards. The introduction of a mandatory scheme, with a
requirement for public liability insurance, meeting model standards for operation and
requirements for training/qualifications will see an improvement in how equines are
looked after when in the care of a business. 
The licensing of livery yards is likely to place additional, significant burden on local
authorities and Renfrewshire Council would recommend funding is provided by the
Scottish Government to allow effective resourcing of a licensing system for the
multiple proposed areas within this consultation document. Without this funding, it is
difficult to see how Renfrewshire Council will have sufficiently trained Officers to
undertake these additional, onerous duties. 
Q2.  If you do not support the introduction of statutory licensing, what
controls, if any, would you otherwise recommend? 
N/A 
Q3.  Should licensing apply to all livery services, regardless of type or scale? 
Yes. given the concerns raised within this consultation document it would be
considered prudent to require all livery services to be regulated to the same
standard, providing consistency across the industry and will also allow liveries to
amend their business model, without falling foul of licensing requirements.

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Q4.  Are there any further controls or measures, beyond those set out above,
that you would like to see introduced as part of a licensing scheme for
operators of livery yards? 
Renfrewshire Council would recommend and support a full expense recovery model
to fund the proposals for licensing livery businesses, including provisions to
introduce a charging scheme for processing a licence application, issuing the licence
and the investigation of complaints and non-compliance with licence conditions. 
Q5.  Do you know of any challenges or negative consequences that may arise
from the introduction of statutory licensing for livery yards? If yes, what are
they and how best could these be addressed? 
No 
Q6.  Are you aware of any examples of how any of the proposals above may
impact, either positively or negatively, on those with protected
characteristics?  These are: age, disability, gender reassignment, marriage
and civil partnership, pregnancy and maternity, race, religion or belief, sex and
sexual orientation. 
No 
 Licensing canine fertility businesses 
Q1.  Do you agree that businesses offering canine fertility services should be
made subject to a statutory licensing scheme? 
Yes. Renfrewshire Council supports the introduction of a statutory licensing scheme
for canine fertility businesses. The introduction of a mandatory scheme, with the
proposed future licensing requirements will see an improvement in the welfare of
dogs whilst in the care of a business operating within this sector. The requirement for
persons to meet a fit and proper test will assist in removing unsuitable persons from
operating within this sector however, there are concerns that the level of knowledge
and detail of fertility practices, what is deemed to be medical interventions which only
RVCS registered veterinary surgeons are permitted to undertake and the detail
around illegal practice is outwith the scope of knowledge and training of local
authority Officers. It is considered that canine fertility services (as described within
the consultation document) would be better regulated through an amendment to the
Veterinary Surgeons Act 1966 making it an offence for any person to engage in
canine fertility practice unless they meet the requirements of that Act. 
Where it is decided that the licensing of canine fertility services rests with local
authorities, it will place additional, significant burden on them and Renfrewshire
Council would recommend funding is provided by the Scottish Government to allow
effective resourcing of a licensing system for the multiple proposed areas within this
consultation document. Without this funding, it is difficult to see how Renfrewshire
Council will have sufficiently trained Officers to undertake these additional, onerous
duties.

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Q2.  If you do not support the introduction of statutory licensing, what
controls, if any, would you otherwise recommend? 
N/A 
Q3.  If you do support the introduction of statutory licensing, which services
should be regarded as "canine fertility services" and therefore require a
licence? 
The type and level of services provided by a canine fertility business could be
extensive and in terms of what is required to be covered by a licence would depend
on whether a veterinary surgeon is named as being associated with the business,
and whether they are present to undertake/supervise suitably qualified staff to
undertake procedures.
Given the level of knowledge and understanding of what is involved with related
procedures this question should specifically be directed to veterinary surgeons. They
will have a greater understanding of how invasive the fertility procedures are, with a
knowledge of what adverse health impacts an unqualified/trained person carrying out
procedures can have on a dog. 
Q4.  Do you support the proposal that any veterinary surgeon named as being
associated with a canine fertility business needs to be present during any
inspection undertaken, or arranged by, the licensing authority when the
authority so requests? 
Yes. this will ensure that businesses have a legitimate veterinary surgeon in place
and can discuss issues which may arise during an inspection of the business by the
appropriately appointed inspector for this purpose. 
Q5.  Do you support the proposal that as part of the licence application
process, canine fertility businesses would be required to submit evidence of
the health screen testing undertaken for all dogs used by the business,
including testing to assess a dog’s temperament? 
Yes, Renfrewshire Council would support this requirement to ensure dogs
undergoing any treatment service offered by a business is healthy and will not suffer
as a consequence of the treatment. 
Q6.  Should screening also include veterinary certification of health and
genetic suitability of all dogs/semen and bitches used for breeding whether or
not owned by the business? 
Yes, Renfrewshire Council would support this requirement to ensure that dogs not
considered suitable are not used within any breeding programme, regardless of
whether the dog is under the ownership of the business. If a dog is not healthy or
genetically suitable for breeding, the ownership of this animal is largely irrelevant and
for the purposes of regulating canine fertility businesses any fit and proper person
working within this field would not breed from such dogs.

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Q7.  Do you support the proposal that as part of the licence application
process, canine fertility businesses would be required to provide information
on any stud dogs owned by or intended for use by the business (for example
ownership details, microchip number, where kept)? 
Yes, Renfrewshire Council would support this requirement which would form part of
a reputable businesses’ operating plan and record keeping to demonstrate puppy
lineage, and suitability for being used to breed. It is expected however, that new
businesses may not have such information at the time a licence application is made
but could be a condition that such records are provided annually to the licensing
authority. 
Q8.  The current licensing framework to which we propose to add canine
fertility businesses, allows for licences to be granted for a period of 1 to 3
years, depending on assessed risk. Do you agree with the proposal that canine
fertility businesses are instead required to renew their licence annually, due to
the higher animal welfare risks associated with such businesses? 
Renfrewshire Council would support the requirement that licences for canine fertility
businesses are licenced on an annual basis as it is accepted that such businesses
are open to abuse and placing the welfare of animals within their care at risk. It is
recognised that organised crime is increasingly becoming involved within this market
which places animals at even greater risk. 
Renfrewshire Council would recommend and support a full expense recovery model
to fund the proposals for licensing canine fertility businesses, including provisions to
introduce a charging scheme for processing a licence application, issuing the licence
and the investigation of complaints and non-compliance with licence conditions. 
Q9.  Are there any further controls or measures that you would like to see
introduced as part of a licensing scheme for canine fertility business? 
No. 
Q10.  Are you aware of any examples of how any of the proposals above may
impact, either positively or negatively, on those with protected
characteristics? These are: age, disability, gender reassignment, marriage and
civil partnership, pregnancy and maternity, race, religion or belief, sex and
sexual orientation. 
No. 
 Greyhound Racing 
Q1.  Do you agree that operators of greyhound racing tracks should be made
subject to a statutory licensing scheme? 
Whilst Renfrewshire Council supports the introduction of a statutory licensing
scheme for greyhound racing tracks and acknowledging there are only two such
tracks within Scotland, there is no further comment which the Council would wish to
raise in respect of this.

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Q2.  If you do not support the introduction of statutory licensing, what
controls, if any, would you otherwise recommend?  
N/A 
Q3.  Do you support the proposal to require veterinary presence when
greyhounds are racing to allow pre and post-race health checks of dogs and
ensure prompt veterinary care of any injured dog? 
N/A 
Q4.  The current licensing framework to which we propose to add canine
greyhound racing allows for licences to be granted for a period of 1 to 3 years
duration, depending on assessed risk. Do you agree with the proposal that
greyhound tracks are instead required to renew their licence annually, due to
the higher animal welfare risks? 
N/A 
Q5.  Do you know of any challenges or negative consequences that may arise
from the introduction of statutory licensing for greyhound racing? If yes, how
best could these be addressed? 
N/A 
Q6.  Are you aware of any examples of how any of the proposals above may
impact, either positively or negatively, on those with protected
characteristics?  These are: age, disability, gender reassignment, marriage
and civil partnership, pregnancy and maternity, race, religion or belief, sex and
sexual orientation. 
N/A 
 Animal Boarding (including day care) 
Q1.  Do you support our proposal to revoke the 1963 Act and bring animal
boarding under the scope of the 2021 licensing framework?  Please explain the
reason for your answer. 
Yes. Renfrewshire Council supports the 1963 Act being revoked and replaced with a
new modern and more flexible licensing scheme for the boarding of animals. The
proposed improvements to the licensing scheme will see an improvement in how
animals are looked after when in the care of a business.   
Whilst LAs currently licence animal boarding establishments, it is recognised that the
new licensing requirements will require greater input for inspecting officers/Local
Authorities and is therefore likely to place additional, significant burden on them and
Renfrewshire Council would recommend funding is provided by the Scottish
Government to allow effective resourcing of a licensing system for the multiple
proposed areas within this consultation document. Without this funding, it is difficult
to see how Renfrewshire Council will have sufficiently trained Officers to undertake
these additional, onerous duties.

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Q2.  Are there specific conditions or measures that you would like to see
included in any future licensing scheme for animal boarding? 
Renfrewshire Council would recommend and support a full expense recovery model
to fund the proposals for licensing animal boarding establishments, including
provisions to introduce a charging scheme for processing a licence application,
issuing the licence and the investigation of complaints and non-compliance with
licence conditions. 
Q3.  Do you know of any challenges or negative consequences that may arise
from revoking the 1963 Act and licensing instead under the 2021 licensing
framework? If yes, what are they and how best could these be addressed? 
No 
Q4.  Are you aware of any examples of how any of the proposals above may
impact, either positively or negatively, on those with protected
characteristics?  These are: age, disability, gender reassignment, marriage
and civil partnership, pregnancy and maternity, race, religion or belief, sex and
sexual orientation. 
No 
 Licensing of riding establishments and wider equine activities 
Q1.  Do you support the proposal to revoke the 1964 Act and bring riding
establishments under the scope of 2021 licensing framework instead?  Please
explain the reasons for your answer. 
Yes. Renfrewshire Council supports the 1964 Act being revoked and replaced with a
new modern and more flexible licensing scheme for riding establishments. The
proposed improvements to the licensing scheme will see an improvement in how
equines are looked after when in the care of a business. 
Whilst LAs currently licence riding establishments, it is recognised that the new
licensing requirements will be more onerous on both businesses and will require
greater input for inspecting officers/Local Authorities. Whilst Renfrewshire currently
use veterinary services to inspect horse riding establishments, there are currently
only a handful of these within the area and the burden on veterinarian staff is
relatively low. There is concern that extending this to additional areas for regulation
could increase this burden which may result in veterinary support being less likely to
be provided. This is likely to place additional, significant burden on them and
Renfrewshire Council would recommend funding is provided by the Scottish
Government to allow effective resourcing of a licensing system for the multiple
proposed areas within this consultation document. Without this funding, it is difficult
to see how Renfrewshire Council will have sufficiently trained Officers to undertake
these additional, onerous duties.

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Renfrewshire Council would recommend and support a full expense recovery model
to fund the proposals for licensing equine activities, including provisions to introduce
a charging scheme for processing a licence application, issuing the licence and the
investigation of complaints and non-compliance with licence conditions. 
Q2.  Do you support the proposal to extend statutory licensing to other
riding/equine activities such as those discussed above (donkey hire, pony
parties etc)?  Please explain the reason for your answer. 
Yes. given the concerns raised within this consultation document it would be
considered prudent to require all riding/equine services to be regulated to the same
standard, providing consistency across the industry. 
Q3.  If riding establishments and other equine activities were in future
regulated under the 2021 licensing framework, what conditions of licence
would you support or like to see included? 
No. 
Q4.  The 2021 licensing framework, to which we propose to add riding
establishments, allows for licences to be granted for a period of 1 to 3 years
duration, depending on assessed risk. Do you agree that local authorities
should be able to licence riding establishments that operate to consistently
demonstrable high standards for periods of more than 1 year? 
Yes. However, as this is a new licensing regime and will have many new conditions
which establishments will require to be compliant with, Renfrewshire Council would
consider issuing any new licence under the 2021 licensing framework for one year
initially, thereafter considering compliance with the new framework conditions could
be assessed, alongside prior compliance under the previous Act (if it is a riding
establishment) to thereafter consider potential to extend the licensed period to a
longer period, up to the maximum three years. 
Q5.  Do you think there should be any exemptions from the licensing system
for certain types of equine activities or businesses, and if so, which ones and
why? 
No - all establishments meeting the definition within the future framework should be
required to be licensed. 
Q6.  Do you know of any challenges or negative consequences that may arise
from revoking the 1964 Act and licensing instead under the 2021 licensing
framework? If yes, what are they and how best could these be addressed? 
No. 
Q7.  What other measures do you think could be taken to improve equine
welfare in Scotland, and how could they be integrated into a modern licensing
system for equine activities? 
Renfrewshire Council has no opinion in respect of this question.

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Q8.  Are you aware of any examples of how any of the proposals above may
impact, either positively or negatively, on those with protected
characteristics? These are: age, disability, gender reassignment, marriage and
civil partnership, pregnancy and maternity, race, religion or belief, sex and
sexual orientation.  If yes, please explain your answer. 
No.