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Submission Guide to the Draft Greyhound Racing Regulation 2019

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Mehreen Faruqi 9 Jul 2019

The NSW Government has released the draft Greyhound Racing Regulation 2019, which will replace the Greyhound Racing Regulation 2018.

While we all want to see an end to the Greyhound racing industry, we must ensure that as many lives as possible are saved by enacting stricter regulations while this cruel activity is allowed to continue. The greyhound racing industry are trying to roll back even the modest animal welfare gains that have been put in place since the backflip.

Overall, whilst the draft regulation is an improvement on the 2018 regulations as it will expand the range of people regulated by the Greyhound Welfare and Integrity Commission, it fails to meet a number of key transparency and accountability measures such as reporting of deaths and clearly establishing a puppy bond. 

You can read The Greens NSW submission.

You can read the draft regulation and the regulatory impact statement, before you make your online submission. You can choose whether or not to have your submission made public.

Please consider using the submission guide text below as a starting point when you make a submission. It is important to make your submission by 11.59 pm, Friday 19 July 2019.

Make an online submission

Submission guide text

1. Functions and reports of the Greyhound Welfare and Integrity Commission and Greyhound Racing NSW

Part 2 of the proposed Regulation includes a number of annual reporting requirements for the Commission and GRNSW to promote increased industry transparency and accountability.

The Annual Reporting requirements for both the Greyhound Welfare Integrity Commission (GWIC) and Greyhound Racing NSW (GRNSW) on animal welfare and integrity matters are unacceptable and are designed to prevent the public knowing how many dogs are killed by this industry. Both of these bodies are established in law and given the amount of public money the NSW Government gives to the industry, they should be required to be much more transparent.

We know hundreds of dogs are killed each year after suffering treatable injuries or being deemed as ‘unsuitable to be rehomed’. As a minimum, GWIC must be required to report the number of greyhounds killed each year and for what reason and GRNSW should report the number of dogs that fail the industry ‘Greyhounds as Pets’ program, and track what happens to those greyhounds.

2. Registration of greyhounds, industry participants and trial tracks

Divisions 1 and 2 of Part 3 relate to the registration of greyhounds, industry participants and trial tracks, which is the responsibility of the Greyhound Welfare and Integrity Commission under Greyhound Racing Act 2017 (the Act).

Provisions relate to applications, conditions of registration and requirements to provide information to the Commission. Division 4 of Part 3 relates to the registers which will be kept by the Commission and the Commission’s ability to share information with specified agencies.

The proposal to expand the definition of greyhound racing industry participants to include providers of health services to greyhounds and others who have contact with racing greyhounds is strongly supported. Dogs in the care of many of these new categories of participants are at risk and stringent monitoring by the Greyhound Welfare and Integrity Commission is required. The NSW greyhound racing industry must pay the cost for GWIC utilising these expanded powers, not the taxpayer.

The proposed register of greyhounds does not deliver the NSW Government’s promise for lifetime tracking of greyhounds. The ability for owners and trainers to register their dogs as ‘adopted’ to themselves or a close associate takes advantage of a loophole where GWIC no longer monitors the animal, which can then be killed. The regulation must include a mechanism for lifetime tracking of a greyhound so the public can establish what happens to greyhounds once the industry no longer wants them.

3. Registration of greyhound racing clubs

Division 5 of Part 3 contains provisions related to the registration of greyhound racing clubs, which is the responsibility of Greyhound Racing NSW under the Act.

No comment.

4. Penalties

Penalty notice offences are set out in Schedule 1 of the proposed Regulation. Penalty notice offences form part of a suite of disciplinary options, which include disciplinary action under the NSW Rules of Racing and offences under the Act.

The penalties provided are completely inadequate and not in proportion with the offences as detailed in the Greyhound Racing Act 2017. Penalties must be significantly increased and should be used in parallel with, not as a replacement for, prosecution.

5. Other issues

Other issues included in the proposed regulation include the miscellaneous provisions of Part 4, related to delegation, certificate evidence, information exchange and the repeal and saving of previous instruments.

The proposal for information sharing between the greyhound racing bodies and animal welfare bodies, law enforcement and other Government agencies and bodies is strongly supported. This power is important to allow greyhound racing participants who engage in animal cruelty, live baiting or other criminal acts to be identified and prosecuted and to save the lives of animals who are at risk. 

The Regulation fails to clearly establish a puppy bond, as was promised by the NSW Government.

The Regulation should include the clear provision for introduction of a Puppy Bond.  In conclusion, the Greyhound Racing industry has proven time and time again that it is unable to reform and whilst this regulation is a tiny step forward, it will not prevent the deaths and suffering  of thousands of dogs. The only solution is to ban greyhound racing in NSW. 

Greens NSW Submission to draft Greyhound Racing Regulation 2019
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