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Animal Welfare Kept Animals Bill

The British and Irish Association of Zoos and Aquariums (BIAZA) response to the Rural Affairs, Islands and Natural Environment Committee, 8 November 2021

Introduction to BIAZA

The British and Irish Association of Zoos and Aquariums (BIAZA) is a conservation, education and scientific wildlife charity, which acts as the principal professional organisation representing the responsible zoo and aquarium community in the UK.

BIAZA zoos and aquariums have global impact, participating in over 800 conservation projects, 1,400 research projects and contributing millions to conservation in the field. With over 35 million visitors being welcomed annually, BIAZA zoos and aquariums are recognised as offering a fun and safe way to learn about animals. Together the community delivers formal education sessions to more than 1.2 million students.

BIAZA and its members are a powerful force in the care and conservation of the natural world. Collectively, they endeavour to inspire people to protect our planet’s rich biodiversity, deliver high quality environmental education, training and research whilst achieving the highest standards of animal care and welfare.

The Animal Welfare (Kept Animals) Bill’s proposals relating to zoos and aquariums

Schedule 5 of the Bill contains a series of amendments to the Zoo Licensing Act 1981. Under paragraphs 4-14 of Schedule 5 of the Bill the current conservation requirements are moved from the Act to the Secretary of State’s Standards for Modern Zoo Practice (SSSMZP) granting the Secretary of State greater powers to define these requirements, and flexibility to specify different standards depending on the type of collection e.g., a large zoo, as opposed to a small aquarium. These zoo standards are currently being reviewed and, following consultation with the sector and Defra’s Zoos Expert Committee, are expected to be finalised in spring/summer 2022.

The Bill also aims to increase the importance of the Secretary of State’s standards by further amending the Zoo Licensing Act to include a condition that zoos must adhere to them as a condition of their licence (as opposed to the current requirement to “have regard” to them) (Schedule 5 paragraph 11).

Another notable change is to transfer appeals involving licensing decisions from the magistrates’ court to the First-tier Tribunal. (Schedule 5, paragraph 17).

BIAZA’s response to the Bill

BIAZA welcomes the increased focus on animal welfare, and we support the government’s ambition to further enhance the conservation requirements for zoos and aquariums contained within the Bill. BIAZA members are the best zoos and aquariums in the UK, and we believe that all zoos should aspire to achieving the greatest possible conservation impact. That is why BIAZA has led on improving conservation outputs within the sector.

By removing conservation from the primary legislation, the Secretary of State will be granted greater powers over the content of the standards and the requirements that zoos and aquariums must adhere to. This means the Secretary of State and/or the relevant Minister within Westminster will have the flexibility to set standards and make changes that will not be subject to parliamentary scrutiny or consultation with the sector and, therefore, may not take into account any circumstances that affect Scottish zoos and aquariums.

We would like to seek assurances that mechanisms will be put in place to ensure there is full transparency and accountability regarding setting and amending, not only the new conservation standards, but the entire content of the Secretary of State’s Standards for Modern Zoo Practice. This could be achieved through:

• Enhancing the role of Defra’s Zoos Expert Committee (ZEC) and providing clarity on the role it plays in advising on proposed changes to zoo licensing requirements. We would like to see ZEC having similar powers to the Scottish Animal Welfare Commission, whereby it publishes independent advice to which government must then respond.
• Clarification of how parliamentarians in all devolved nations will be able to scrutinise decisions
• Formal arrangements for ongoing consultation with BIAZA and leading zoos and aquariums

The conservation work of zoos is broad and far reaching. Zoos and aquariums globally contribute more than $350 million annually to species conservation programmes in the wild, making them the world's third largest funder of species conservation after World Wildlife Fund (WWF) and The Nature Conservancy. UK zoos and aquariums contribute 10% of this global zoo total. Zoos and aquariums receive no direct public subsidy and generate their funds for conservation from visitor revenue. However, provision of funding is just one aspect of zoo and aquarium conservation work. BIAZA zoos and aquariums support over 800 projects in 105 countries, providing direct conservation action for 488 species of animals and plants. This conservation action includes provision of skills, expertise and equipment, research, advocacy and sharing of knowledge which can only be gained through work with zoo and aquarium animals.

It is essential that the standards recognise this full breadth of conservation work undertaken by zoos and aquariums. If the metrics by which conservation is to be measured are too restricted, we risk losing this critical work. Some examples of this conservation work include:

• The Royal Zoological Society of Scotland (RZSS) leads on vital native species conservation such as the Pine hoverfly conservation programme and Scottish Wildcat conservation
• RZSS also host a ‘frozen ark’ contributing to the preservation of genetic materials of endangered species
• Calderglen Zoo is undertaking incredible work breeding and reintroducing dormice into grassland habitats in the UK
• Five Sisters Zoo, in collaboration with others, has provided important facilities for veterinary checks to be undertaken on Scottish beavers.
• Scientists at the Zoological Society of London (ZSL) are conducting world-leading research into Chytridiomycosis, a fungal disease (discovered by ZSL) which is devastating amphibian populations worldwide and has already caused the decline of over 500 species, including 90 presumed extinctions. ZSL experts are also leading the world in the connection between wildlife exploitation and the transmission of zoonotic diseases, such as COVID-19, Ebola, SARS COVID and hundreds of others that are a natural part of the natural world
• Many BIAZA zoos are connecting countless school children and families to the wildlife on their doorsteps from rarely seen native species such as red squirrels to running beach cleans

Good zoos play an irreplaceable role in education, connecting people with nature and inspiring them to live more sustainable lives. BIAZA zoos and aquariums deliver over 1,200,000 formal education sessions, leaving no doubt that zoos and aquariums play an outsized role in the education of the nation in the knowledge, care and respect for the natural world. Inspiring the next generation of conservationists is one of our core objectives and a means by which we contribute to global conservation efforts.

Conservation will always be at the very heart of what good zoos do and there are many metrics by which we should judge the conservation efforts of an exceptional zoo. This must be recognised by ministers during the passage of the Kept Animals Bill. Conservation must include activities as diverse as gene banking, technological research, education for visitors and schools, breeding programmes and habitat management.