European Federation of Thoroughbred Breeders' Associations
Fédération Européenne des Associations déleveurs de Pur Sang Anglais
Letter to the European Commission on the Animal Welfare in Transport review
Andrea Gavinelli
Unit D5, SANCO
European Commission
B-1049 Brussels
Belgium
20.5.2008
Dear Andrea Gavinelli,
Our Federation had the pleasure of working with your colleague Mr Denis Simonin during the drafting of the Animal Welfare in Transport Regulation several years ago. I hope we can continue with you and your team the same positive working relationship which we enjoyed with him for the upcoming review of this Regulation.
The European Federation of Thoroughbred Breeders’ Associations supports the European Commission’s aim to improve the welfare of livestock in transport, and in particular the conditions of transport for slaughter horses.
We understand the Commission intends to review this Regulation by starting with loading densities and travelling times, and therefore we will focus our comments in this initial letter to those items in particular.
Travelling times
We, together with our other equestrian colleagues involved in transporting horses, stress the need to maintain the important derogations for registered horses from travelling time regulations. This allows for the current widespread practices of travelling racehorses and bloodstock (including mares in last 10% of gestation and young foals) throughout Europe and neighbouring continental countries. These horses are travelled in vastly superior boxes fully adapted to long distance journeys. Their high monetary value means it is of paramount economic importance that their welfare is maintained to a high standard during any travel. There is simply no advantage in arriving at a competition, bloodstock sale or stud with a valuable horse injured or exhausted, and this is an extremely important self regulatory mechanism in our sector in terms of welfare during transport. Indeed, reverting to the 2003 proposals, and without a derogation for registered horses, having our animals travelling for 8 or 9 hours and then having to remain confined in the lorry for 12 hours ‘rest’ without being unloaded would be hugely detrimental to their welfare, and, indeed, makes these transport operations impossible.
The European thoroughbred breeding and bloodstock sector is completely dependent on the ability to travel their horses across Europe, particularly as international thoroughbred regulations do not allow Artificial Insemination (AI) or any other genetic manipulation. Over 27,000 mares are used for breeding with around 25,000 foals being born each year. The total turnover of thoroughbreds sold a year is over 800 million euros, with a further turnover of 172 million euros in stallion bookings. 126,000 people are directly employed in the industry. Taking the wider racing industry, where racehorses travel frequently to competitions throughout Europe, this is responsible for over 400,000 full time jobs, 100,000 races a year on 500 racecourses, and holds three out of the five biggest races in the world in terms of sporting attendance. Betting turnover in Europe on horseracing is over 35 billion euros, with a significant amount being returned to national government coffers in taxes on bets. When one adds to that the huge volume of sports horse movement, the need to maintain flexibility in registered horse travel becomes evident.
Stocking densities and space allowances
Space allowances relating to mode of travel
We would stress the absolute need for liaison and discussion with the industry before any change in the present Regulation regarding space allowances. For example, the purpose built containers for horses to travel by air are designed specifically for welfare and safety, and so are the purpose built horse boxes for road travel.
Travelling of registered foals together for long distances
We would strongly request in the review of this issue, that the problem encountered with the 2005 Regulation in the travelling of thoroughbred foals is resolved. It is industry practice worldwide in the bloodstock world to travel Thoroughbred foals (by this we mean weaned animals between 6 and 16 months of age) in pairs, and sometimes up to four together. The reason for this is for their safety and comfort. To confine them as this stage of their life in single stalls for journeys over 8 hours will upset, cause stress and often result in injury. This problem affects thousands of foals, with over 7,000 travelling each year throughout Europe and neighbouring European countries.
A failure to be able to transport foals this way will have a profound negative impact on the whole of the EU thoroughbred breeding industry, and in particular, the smaller breeders. Foal sales are a significant part of the 800 million euro turnover in sales a year. These are high-value bloodstock – most travelling in groups of up to four together for the sales season in November, but some private sales sending foals abroad as early as September or as late as March of their yearling year. In addition many owners keep their mares in an EU country, or neighbouring continental country, where they have chosen preferred resident stallions but transport their foals back to the owners’ country once they are weaned.
We would appreciate the opportunity to be involved during any changes or discussions relating to equidae, and stand ready to assist with any further queries or clarification you may need.
Yours sincerely,
Mr Joseph Hernon, Chairman
EFTBA
257 Avenue le Jour se Leve,
92655 Boulogne Cedex,
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Tel: +33 471 58 49 17
Fax: +33 471 48 41 15
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