Submission to consultation on proposed changes to live animal transport

To Whom It May Concern

We write to highlight the existing gold standard in animal transport to and from the Northern Isles, established through work by those in the farming community who put animal welfare at the heart of their work.

We have serious concerns regarding the scope for potentially significant and dangerous unintended consequences for the farming industry in the Northern Isles as a result of changes to live animal transport regulations that may well emerge from the consultation exercises launched by both the UK and Scottish Governments.  It is no exaggeration to say that some of the proposals being considered present an existential threat to the future of livestock farming in Orkney and Shetland, which remains an ‘anchor’ industry within both local economies.

At the outset, we would want to make absolutely clear that ensuring the highest standards of animal welfare are maintained and monitored is the collective ambition of the individuals and businesses that make up the island livestock industry in the Northern Isles. As NFUS Orkney have observed, “It is in no one’s interest to transport animals unfit for the journey undertaken.”

Recognition of this fact has driven the improvements seen in the way in which livestock is transported from Orkney and Shetland to the Scottish Mainland over recent years. The development and deployment of bespoke cassettes for transporting animals represented a step change and addressed earlier welfare concerns that the farming community itself had highlighted. We understand that members of the Farm Animal Welfare Committee were invited to inspect the current facilities and operation of livestock transport on the Aberdeen route a few years ago. Despite the horrendous weather conditions that coincided with the FAWC visit, we further understand that no concerns were identified or raised at that point, including by the Orkney vets in attendance.

It is quite clear that local farmers and farm businesses make every effort to ensure that best practice is observed. It is in their interests to do so apart from anything else. However, there is nothing that livestock producers in the Northern Isles can do about the location of Orkney and Shetland in relation to the Scottish mainland and the markets they supply. The inherent nature of cattle and sheep farming in the islands means that the transport of animals is essential, both within Orkney and Shetland and between the islands and the Scottish mainland. The duration of these journeys is also difficult to avoid or even influence. As stated earlier, however, the arrangements currently in place have been designed to highest standards and, as far as we are aware, have not given rise to any serious welfare concerns to date. For example, as highlighted by NFUS Shetland in their consultation response, the purpose built Livestock Container system in place has worked well, as observed by the FWAC.

This is not to say that the farming sectors in Orkney and Shetland, as well as the service provider, in this case Serco Northlink, will not continue to explore any options that might allow for a process of constant improvement. Their track record to date provides confidence that this will indeed happen. However, the introduction of some of the measures that have been mooted could have the perverse effect of actually negatively impacting upon animal welfare during transit from the islands – in particular, measures around temperature and holding arrangements.

In this context, we note with concern the following proposals, in response to which local representatives of the farming sector in the Northern Isles have highlighted serious questions and difficulties:

  • Proposed maximum journey times, and the lack of clarity around the calculation of transport time. NFUS Orkney state that:

“Without exact details of what constitutes travel time (in particular whether “neutral time” is retained) and how time at auction markets are dealt with it is not possible to comment in detail but there is the potential that if these proposals are implemented, as presented, that it makes livestock farming impossible in Orkney leading to huge environmental, social and economic consequences.”

  • Proposed rest periods, and the potential for new animal welfare concerns developing if new holding processes need to be introduced in sites that may not be suitable. For example, it is unclear whether there is actually enough land at say, Thainstone, to do without raising welfare concerns and increasing the chance of spreading disease.
  • The definition of “neutral time”, and the exclusion of ferry transit time from this definition.
  • Temperature restrictions, prohibiting journeys where there is an outside temperature of 5-25°C, unless the vehicle is able to regulate the internal temperature within this range for the duration of the journey by means of a thermo-regulation system, and that this temperature range should be 5-25°C.
  • Weather condition restrictions, citing Force restrictions for sea passages which have no bearing on existing experiences of sea passages to and from the islands for example when FWAC observed a sailing where gusts of up to Force 10 were experienced , and the need to account for other variables when determining whether a journey will impact animal welfare.
  • Added complications for cross border transport.
  • The impact of new costs and bureaucracy around new arrangements, and the potential for these costs to be imposed on short journeys and long journeys alike.
  • The current definition of a ‘calf’, which fails to account for the definition of the difference between a weaned calf and a baby calf.
  • Headroom requirements that are speculative and fail to account for current arrangements for transport from the islands which have not been associated with any animal welfare concerns.

We would like to draw attention to the submissions that have been made by NFUS branches in Orkney and Shetland, which set out in more detail the repercussions for island producers and the communities overall should the sort of restrictions that are being envisaged actually be brought into force. Indeed, it has been calculated that were the wind speed and temperature restrictions in place over the course of the last year, only two livestock sailings would have been permitted from Orkney to Aberdeen over that period. While we accept the serious welfare issues that can arise from over-heating, we are not aware of any local or national veterinary input suggesting concerns that might justify the restrictions being considered as part of these consultations. Nor indeed, as mentioned earlier, are we aware of FAWC representatives expressing any such concerns at the time of their visit to Aberdeen to witness the livestock shipment operations for themselves.

It may well be that there are aspects of livestock transport elsewhere in Scotland and the UK that require to be addressed by amended regulation, tighter restrictions and the setting of higher standards. Unfortunately, however, the way in which these consultations are framed runs the serious risk of impacting upon livestock shipments in the Northern Isles, for no good reason but to disastrous effect. No island impact assessment has been carried out, leaving our island communities deeply exposed to the effects of a one-size-fits-all approach.

That is not acceptable, nor is it even necessary in terms of meeting the wider objectives underlying these consultations. We would therefore urge extreme caution in the development of any future proposals and seek reassurance that the concerns set out here, and in the submissions from industry representatives in Orkney and Shetland, will be taken fully into account.


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