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Animal Concern Advice Line News

Welsh Government Consultation on Mobile Animal Exhibits

September 30th 2017: The Welsh Government is seeking submissions to their consultation on Mobile Animal Exhibits. The closing date is 8th October and you can read our submission here:

Consultation on Mobile Animal Exhibits,
Animal Welfare & By–Products Branch,
Welsh Government,
Cathays Park
Cardiff CF10 3NQ

Dear Sir or Madam,

I would be grateful if you would accept this submission to your Consultation on Mobile Animal Exhibits, a subject which I have been dealing with for nearly 40 years. I make this submission on behalf of the charity Animal Concern Advice Line (details above) and we agree to our submission being made public.

I would like to make some general points before answering your questions as laid out on your Consultation Response Form.

Rather than simply License and regulate them I would like to see many of the uses to which animals are put banned by law. I have campaigned against the use of animals in travelling circuses since the 1980s and I believe the use of all animals, both domestic and exotic (few animals in circuses are actually from the wild having been captive bred for generations), should be banned.

Travelling circuses are restricted by the amount of equipment they can carry and the amount of space they can provide for their animals. Some circuses pitch up for two or three days and only provide their animals with nothing more than travelling cages or very small tented stalls. After three days the animals are loaded back into their lorries and transported maybe a hundred miles or more by road and perhaps ferry to their next venue.

At Perth I saw a bear which was literally mad and far too distressed to perform in the Big Top. It was living out its existence in a cage on the back of a box van.

I once sneaked behind the scenes at the Christmas circus at the SECC in Glasgow and photographed elephants chained by two legs in a tent on the tarmac car park. Apart from performing in the ring I reckoned they were chained 23 hours a day. When I questioned owner Bobby Roberts about this live on a BBC Radio debate he was proud to tell me I was wrong and the week before his elephants had been taken for an hour long walk around the SECC site. Apart from performing in the ring that one hour walk around a car park was the only exercise they had been given in nearly a week.

Another year, acting on a tip–off from a Government employee, I went to an old farm on the outskirts of Glasgow and found that, between the end of his summer/autumn tour and the start of the Christmas circus in Glasgow, Bobby Roberts was keeping all his animals in a semi–derelict barn. The animals were kept there for circa 12 weeks and at least one, a camel I believe, had died. The elephants were chained in windowless stalls where their tails touched the rear wall and their trunks the front wall. If a zoo kept animals like this they could have been prosecuted but because this was a travelling circus they were exempt from such legislation. This situation went on for two or three years until the barn was demolished. That year the animals were kept inside an old warehouse in the east end of Glasgow.

Another year and at a summer circus (in Bellahouston Park Glasgow) the animals (camels, a zebra and some horses) were kept in small tented stalls where they literally did not have enough space to turn around.

At another circus in Perth I witnessed a troupe of Samoyed dogs being taken from the big top and loaded into cages in the back of a windowless van. When I criticised the circus for keeping dogs in darkness in cages in a van I was rebuked and corrected. The van was not dark inside as it had a translucent roof.

Unlike dogs taken out for the day to a dog show or police dog agility display, or horses taken to a one or three day event, and then taken home afterwards, that windowless van was not just a means of transport — it was where these dogs lived for perhaps eight months of the year. Keeping dogs under such conditions is every bit as wrong as keeping elephants chained in stalls on a tarmac car park. I urge the Welsh Assembly to consider banning the use of all animals in all circuses.

At Ingliston, Edinburgh and Queens Park, Glasgow an Italian touring circus appeared with various animals including big cats and a hippo. The circus left Edinburgh early under a hail of criticism and turned up in Glasgow without the necessary entertainments license. I paid them an undercover visit and had I wanted to I could have released the animals which were left overnight unguarded in unlocked beast wagons at the side of the road in a built–up area. Conditions at that circus were so bad that when I appeared before the very pro animal act Glasgow City Council Licensing Committee I was able to persuade them not to give this circus a Public Entertainments Licence.

Legislating to keep exotic/wild animals (or better still all animals) out of travelling circuses in Wales would be a progressive and welcome move.

I also have serious concerns over commercial travelling mini zoos which take a variety of animals out on the road to provide entertainment disguised as education. These shows are often hired as birthday party entertainers, attractions at shopping centres and even by schools. I am sure some of these commercial mini zoos are no more than animal hoarders looking for a way to make money out of their animals. Indeed a recent animal cruelty prosecution in Scotland proved this to be the case with an animal hoarder who charged £80 an hour to take his animals, which included lethal venomous snakes, to children‘s‘ birthday parties:

One of the first mini zoos appeared in Scotland in the 1980s. The owner dressed as a cowboy and had an American drawl. He was in fact a Scot who kept his animals, including reptiles requiring heated accommodation, on an allotment in a shed with no power supply.

People who had seen his show raised their concerns with us. One was that the animals (which included rabbits, Guineapigs, chickens, snakes, lizards, insects and large spiders) were being constantly handled by very excited, noisy young children. Posing as a potential customer we contacted the owner and asked if the animals got stressed by all the handling. His ludicrous reply was that the animals didn't have any feelings and didn't mind being picked up and handled. Despite this basic ignorance about animals he described his show as “educational”!

Animals can become stressed and dangerous through over-handling or mishandling. Most animals can bite and scratch and some spiders can fire barbed hairs from their backs. These hairs lodge in the skin or eyes and cause irritation or worse.

Many animals carry zoonotic diseases and parasites which can be passed to humans through simple contact. Potentially lethal E–coli is probably the best known of the diseases but there are many others. For instance reptiles can carry several strains of salmonella which can be passed to people who handle them. It is very important that people who handle animals and birds wash their hands afterwards, especially before eating food. Kids' birthday parties and mini zoos are perhaps not the most hygienic of combinations.

At one shopping centre it was not until after I raised the issue with the mall owners that hand washing facilities were provided by a visiting petting zoo.

One other area of major concern I discovered when first dealing with this issue is that, unless they are working in a school, children's entertainers do not have to undergo any background checks as to their suitability to work with children.

Bird of prey displays are also of concern. I find it very distressing to see a variety of owls, hawks, falcons and eagles chained to perches for hours on end in car parks or inside shopping malls. Youngsters are encouraged to pay to have their photograph taken with the birds, people are urged to sponsor a bird and collecting cans are shaken to incite you to donate towards the upkeep of the birds.

You would be forgiven for thinking you are supporting a bird rescue charity when you are in fact giving money to commercial falconers who charge large sums of money for falconry lessons or for taking part in falconry hunts or for providing an avian pest control service for local councils and private landowners.

Falconry displays should be licensed, their methods of raising money regulated and the health of the birds monitored.

Another problem with both travelling mini zoos and falconry exhibits is that they encourage children to want exotic pets. The international trade in exotic animals is cruel, a threat to wild animal conservation and poses problems when unwanted exotics are abandoned by their owners. A classic example is the dumping of turtles into canals, ponds and lakes by owners who did not realise their fifty pence size pocket money pet would grow as big as a dinner plate.

Yours faithfully,

John F. Robins,
Secretary to Animal Concern Advice Line

I will now answer your questions as laid out on your Consultation Response Form.

Consultation Questions


1. We have proposed the following definition of a MAEs: ‘Individuals, groups or commercial enterprises that travel to exhibit domestic and/or wild animals, for entertainment, therapy, educational and/or other purposes'. Do you agree with this definition? If no, please explain why.

No. This could suggest that MAEs are the people involved as “Individuals, groups or commercial enterprises” and not the animals. Exhibit suggests a stationary display and not animals made to perform. Perhaps this would be better worded as:

…. the following definition of a MAEs: Individuals, groups, charities, commercial enterprises or other bodies that travel with domestic and/or wild animals to use those animals in exhibits, for entertainment, for therapy, or educational and/or for other purposes'

This would include charities such as the RSPCA who take animals into schools to educate pupils on how to care for animals and on which animals are not best suited as pets.

2. Do you consider that the display of animals in MAEs has a positive or negative impact on the development of respectful and responsible attitudes towards animals in children and young people?

Definitely not in every case. A knowledgeable, well–trained RSPCA Officer taking a few rescued animals into schools could be a good thing.

Having an ignorant person who knows little about animals trying to make money by doing presentations could be very detrimental by teaching that animals don't have feelings and can be used for any purpose we like.

Watching animals performing silly tricks in circuses is extremely negative.

3. It is a mandatory requirement of licensed zoos to undertake conservation measures, including promoting public education and awareness in relation to conservation. Should MAEs be required to undertake similar activities?

The conservation value of zoos is dubious to say the least. Most animals in zoos are there to attract paying punters, not to restock what is left of “the wild”.

4. The health and safety of the people who interact with MAEs, and the animals involved, is of concern to us. If you own or work for an MAE, what measures do you take to minimise the risk of injury or disease, both to humans and the animals?

I don't work for an MAE but you will see in my submission above that I don't think MAEs do enough to protect the public. Indeed if you read the article on the following link you will see that some MAEs present very real and serious danger.

5: Do you consider that any MAEs, circuses with animals, or both, which are based in or exhibit their animals in Wales, should be licensed or registered?

Licensed? YES Registered? YES

Although I'd rather they were totally banned.

6: If you consider that MAEs and/or circuses should be licenced or registered, do you think that they should pay a fee for the licence or registration? If yes, please explain why.

If you must allow them they should be registered and licensed and realistic fees should be levied to cover the cost of inspections of base holding premises, animal transport facilities and temporary accommodation while on the road.

7. The proposed definition of an MAE is very broad. Do you consider that there should be any exemptions included in any licensing or registration scheme?

I don't think there should be any exemptions. Indeed it may be necessary to leave any legislation open for amendment to include things like sheep racing. I was recently involved in having Scottish and Welsh sheep racing events banned due to the inherent health and welfare risks they posed to the animals.

8. At present there are no circuses based in Wales but they do visit. The Cabinet Secretary for Environment and Rural Affairs has not dismissed the possibility of Wales banning the use of wild animals in circuses. Do you consider that such a ban should be considered?


Please give your reasons for this:

I believe (for reasons detailed above including suffering caused to dogs in travelling circuses) that all animal acts should be banned from travelling circuses. If it is decided to only ban some animals from travelling circuses and mobile animal exhibits then you must choose your definition carefully. The Scottish Government ignored my advice and proposed banning “wild” animals from circuses and this has caused problems with the passage of the proposed new legislation through the Scottish Parliament. Are bears, elephants, lions or tigers which are fifth or sixth generation captive bred “wild” animals? Perhaps a better word would be “exotic” — though in the village I grew up in a sheep in a tutu would have been regarded as exotic. A better description would be “non–native species” though to cover the use of native raptors in falconry exhibits a fuller definition might be required. Perhaps you could ban the use of “non–native species and non–domestic native species of mammals, reptiles and birds.”?

I'd much rather you kept it simple and banned all animals from performing in travelling circuses or appearing in mobile animal exhibits.