Consultation on Licensing of Dog, Cat and Rabbit Breeding Activities in Scotland

I don't think an arbitrary number as a threshold for licensing is the answer. I work in rescue and some of our biggest headaches have been caused by people who would not call themselves breeders, and who would be completely under the radar of this legislation. For instance, the couple who let their pet, unregistered Redacted texthave a litter once a year by their Redacted text Redacted text. The resulting puppies are sold at £50 each and we are now seeing second and third generations of this "family". They are all large, unruly creatures in irresponsible homes.
On the other hand, I know dedicated breeders who are true enthusiasts of their chosen breed. By and large they can have anything between none, and 4 litters in a given year - depending on bitches' seasons, ages, campaigning in the showring etc. Their standards would probably exceed licensing requirements but I know many are worried that by becoming licensed, they will be officially classed as a business and therefore their mortgages, local authority rates, bank accounts, insurances etc will all be affected.
Finally, I have severe doubts about how effectively this will be policed/enforced. Local authorities are already struggling financially and many are failing to enforce existing legislation due to lack of staff. It seems to me that only hobby breeders will be made accountable. Casual backyard breeders will still be under the radar and larger commercial breeders are already licensed anyway (and continue to operate with poor conditions and with questionable ethics)

No - why should they?

Four litters are enough for any breeding bitch or queen. I don't know enough about rabbits to comment.

Dogs and cats are not herd animals and should not be kept in such large numbers. They need individual attention (especially dogs)

OBVIOUSLY a person with animal welfare offences (even spent ones) should not be able to become a licensed breeder. I am not sure why other criminal convictions should be taken into account - although I suppose a breeder should be a trustworthy person.

I think membership of an accredited scheme such as the Kennel Club's Assured Breeder Scheme, while not perfect, should be mandatory for anyone getting a licence. The ABS inspection is far more thorough than any by a local authority.

I have little faith in the efficiency of Local Authorities. And "reasonable costs" - what does that mean? Who will decide what is reasonable? Is this going to turn into a money-making exercise for cash-strapped L.A.'s?

I would say central Government should set the scale of fees as local authorities and authorised inspectors are less likely to be impartial.
I would urge the government to work in partnership with the Kennel Club who already have a UKAS accredited scheme in place, that they subsidise, with thorough inspections that last over three hours. This would reduce the burden on local authorities.

Smacks of Big Brother. Why would a national list be necessary?

Yes I have comments! I think we should tread very carefully here. Data protection laws apply. I think any application for information should be assessed individually and carefully on a "need to know" basis. No organisation should have carte blanche right of access. Yes I think there should be a charge as assessing the application and granting access will both cost in terms of time.

As long as the "enforcement agencies" are fair, knowledgeable, fully-trained, unbiased and without their own agenda. Not a campaigning animal welfare organisation.

KC Assured breeder scheme.

Legislation needs teeth to be effective

Absolutely. Breeding breeds with physical traits that cause discomfort or pain needs to be closely monitored, as should the new fad for "rare" colours in some breeds that are known to be genetically linked to various diseases.
All breeding animals should have the relevant health tests as decreed by the Kennel Club.
A word of caution here though - breeding is still more an art than an exact science, so it has to be remembered that many factors have to be considered when planning a mating. A dog is more than a bunch of certificates. The tests enable experienced breeders to make informed choices. Black and white rules may have an adverse effect longer-term by reducing the gene pool for the breed.

I would qualify my answer by advising caution. "Likely to cause" should open to interpretation. Take guidance from the experts with different viewpoints. Don't, for instance, just decide on an arbitrary score for hips above which a dog can't be bred from. Hip dysplasia is multi-factorial. Instead the bigger picture needs to be considered - parents' scores, grandparents' scores, sibling scores etc. There is also an environmental influence. The mode of inheritance is not fully understood. And the way scores are reached is not 100% reliable. So to set a cut-off could be counter-productive to the overall breed - you could have a bitch with a score slightly above the published breed average who excels in every other area, lost to the gene pool. Yet another who has average hips could have several siblings with clinical hip dysplasia and who will produce it herself. I agree absolutely that breeding from untested animals is wrong. Also breeding dogs with excessive skin or foreshortened faces, or British Shorthair cats with diaphragm problems should just have an outright ban.

I think the Scottish government should form a working party made up from different areas to advise and develop a strategy. Yes, include the SPCA but there are also other experts in animal welfare. Association of Dogs and Cats Homes can advise on independent Scottish members. Vets and even experienced breeders should be involved. Breeds each have their own Breed Council, and most Scottish breed clubs will have their own breed health representative to Breed Council.