The former Animal Welfare Committee (AWC) which provided expert advice to SCoPI requested that animal welfare standards be: ‘clear, essential and verifiable.’ To complement these criteria, the four main decision-making principles used for policy analysis in the welfare standards development process are that they are:
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Desirable for animal welfare, and preferably supported by science;
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Feasible for industry and government to implement;
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Important for the animal welfare regulatory framework; and
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Will achieve a valid, intended outcome for animal welfare.91
In relation to the proposed standards and feasible alternatives the following overarching policy objective is identified:
To minimise risks to cattle welfare and unnecessary regulatory burden in a way that is practical for implementation and industry compliance.
The main criterion for evaluating the proposed standards and the feasible alternatives is net benefit for the community, in terms of achieving this policy objective. As part of the evaluation, there will be a need to ensure that the benefits of the proposed standards justify their costs, and that they take into account the expectations of the Australian and international communities.
In accordance with the COAG guidelines, an RIS is required to identify feasible alternatives to the proposed standards. Conversely, an RIS is not required to identify alternatives which are not feasible, or where there are no significant cost burdens being imposed.
Having no standards at all is not a feasible option, because jurisdictions already have their own standards as part of the base case; and it is outside the scope of this RIS to consider changes to individual state or territory standards.
Similarly, public education campaigns as an alternative to national standards are likely to be ineffective and therefore not a feasible alternative. The behaviours that need to be changed are displayed by only a small percentage of farmers who are unlikely to be more influenced by public education campaigns than by enforceable standards.
As discussed in Part 2.1.2 of this RIS, there is a lack of information in the market place, as consumers of beef and dairy products are not aware of the welfare status of the cattle used to produce the products they are buying. However, even if such consumer information were available, the market share for other animal welfare-related products indicates that only a small percentage of consumers would be likely to be influenced in their purchasing decisions. Thus better consumer information is not a practical alternative to welfare standards and guidelines.
At the SRG meetings in 2009 and 2010, alternative positions and views were expressed by governments, industry and animal welfare organisations regarding the need to consider various practicable alternatives, resulting in a provisional list of variations to the proposed standards. This list was prioritised to seven variations by the Animal Welfare Committee, on the basis of contentious issues that might provide further improvements in animal welfare, but before the costs of such improvements had been estimated. In arriving at the variations to be examined, the same four main decision-making principles used for policy analysis in the welfare standards development process (refer to Part 2.2. of this RIS) were used to assess the potential suitability of the variations for further analysis. The public consultation seeks the views and advice of interested parties in the further formulation of variations to the existing proposals. Selected additional variations may be investigated and reported in the decision RIS.
The feasible alternatives together with the proposed national standards will from here on be referred to as ‘options’. The options to be evaluated in terms of costs and benefits are:
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Option A: converting the proposed national standards as currently drafted into national voluntary guidelines (the minimum intervention option);
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Option B: the proposed national standards as currently drafted with the intention of them being made mandatory;
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Variation C1: pain relief for all spaying
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Variation C2: banning flank spaying/flank webbing
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Variation C3: banning permanent tethering
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Variation C4: banning the use of dogs on calves
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Variation C5: banning caustic dehorning
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Variation C6: banning induction of early calving except for veterinary requirements
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Variation C7: banning electro-immobilisation.
Information on the meanings and impacts of these options and variations is given in the evaluation of costs and benefits in the next part of this RIS.
4.0 Evaluation of Costs and Benefits 4.1 Introduction
This part of the RIS identifies the relative costs and benefits for the proposed national standards and each of the other options, as identified in Part 3.0, in comparison with the ‘base case’. The ‘base case’ is used as a reference point for measuring the incremental costs and benefits of each of the options, including the proposed standards. Each of the options is assessed in relation to how well the underlying policy objective identified in Part 2.2 of this RIS is likely to be achieved.
Where data exists, discounted92 quantitative estimates of costs and benefits are provided over 10 years of implementation. Whilst it is expected that the standards would be reviewed every 5 years, a 10-year analysis is conducted to effectively capture their full impact, taking into consideration implementation lag times. A detailed discussion of the estimation of costs is provided in Appendices 2 and 3 to this RIS. All data used are sufficiently certain, and robust assumptions are stated. However, where cost and benefit data or assumptions is not available, then a quantitative measure is not possible and the assessment is made using qualitative criteria about the achievement of the policy objective. All costs and benefits reported are incremental to the base case (refer to Part 4.2 of this RIS).
The costs and benefits of Options A, B, and C (the practical alternatives) are evaluated by using the following criteria (I to III) to compare the effectiveness of each option in achieving the relevant part of the policy objective:
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Animal welfare benefits;
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Reduction in regulatory burden; and
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Net compliance costs to industry and government.
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