Do you agree with the Scottish Government’s position on transportation of animals by sea and proposed course of action? Please provide any further relevant information.
It is the view of the Scottish Government that specific consideration should be given to the particular issues and challenges which apply to animals undergoing sea journeys.
We agree that animals should not be transported by sea during severe weather or sea conditions. We should also, however, take into account the design of the vessel involved and recognise that transport in various weather conditions may benefit the welfare of animals that need to be moved from islands to better conditions as part of the normal seasonal pattern of livestock movements.
Given the changeable nature of sea and weather conditions, and other factors that may affect the availability of ferry services, we agree that those wishing to move animals over the sea should have effective contingency plans for their animals in case of delays, and that these plans and the associated contingency venues and premises should be approved by the relevant devolved authority.
Where sea journeys take place we agree it is important that effective ventilation and temperature control are provided, and that natural ventilation should be provided as far as possible instead of mechanical ventilation. Where mechanical ventilation is provided this needs to ensure that the right temperature range is provided during all parts of the journey.
In most cases animals travelling by sea remain on their road transporters and this time currently counts toward total journey time. The Scottish Government will consider reviewing the concept of “neutral time” for animals transported unloaded in conditions equivalent to farm accommodation in livestock vessels or cassette systems, taking into account the practical experience gained in operating the cassette system in Scotland over many years and any relevant future research.
FAWC has recommended that more funding is provided for further research to enable maximum journey times at sea to be set. We would support further research here, subject to the consideration of other research priorities, and would also support other evidence gathering relating to how the welfare needs of animals on longer sea journeys can be addressed.
We agree with FAWC that suitable training should be required for anyone transporting livestock and horses, including captains and pilots, on the requirements of any new transport legislation.
Of the 313 responses to this question, 36.7% were in favour of the Scottish Government’s position on transportation of animals by sea and proposed course of action. 50.2% were not in favour and 13.1% did not express a view.
The small majority who were not in favour of the proposed course of action answered from a number of differing perspectives. Some one-third of both animal welfare organisations and their individual supporters provided a negative answer from the viewpoint of banning all sea transport on the basis of banning live exports and on reports of shipping accidents and incidents reported in the past. Additionally, the welfare organisations tended to agree with FAWC, particularly in terms of the wind strength.
A second strand of negative responses from individuals recognised the importance of sea transport of livestock to the island communities, and stressed the “multitude of factors that can impact on the conditions that need to be taken into account”. Many who commented in these terms also suggested that the discretion on when a ship sails should rest with its captain.
Responses suggested there to be 2 main types of sea transport experienced by livestock from the islands. In the Northern Isles the cassette system “designed so animals are not on livestock lorries … and animals have full access to feed and water to ensure maximum comfort” (Quality Meat Scotland). Transports to and from the Western Isles involve the livestock remaining on the “livestock vehicles … designed for travel by road” (Highland Council).
Many respondents agreed that animals should not be transported in rough sea conditions but “strongly disagree with the measurement of Beaufort Wind Force 6 or above as a reasonable deciding factor” (unnamed organisation). It was noted that wind speed of that scale was common in the Northern Isles, with the Institute of Auctioneers and Appraisers in Scotland citing information for 2020 provided for them by Northlink Ferries which showed “329 days when the wind speed exceeded force 6 on the scale in the geography covered … also shows little correlation between wind speed and wave height which seems to have a much larger impact on vessel movement”.
An unnamed organisation also supplied a comprehensive list of other environmental, geographical and technical factors which could affect vessel movement “including but not limited to: Wind direction; Sustained wind speed vs wind gusts; Tidal flow; Direction of vessel travel with respect to direction of sea and swell; Exposure of route; Size of vessel; and any ride control or roll stabilisation devices on the vessel”.
With regard to a proposed review of ‘neutral time’ respondents from the Northern Isles considered that “removal of the 'neutral time' definition would make the movement of livestock to and from the islands virtually impossible” (Orkney Auction Mart) and strongly rejected a need for review on the basis that the cassette system in use in the Northern Isles was “specifically designed in collaboration with all parties interested in the welfare of animals on journeys between the Northern Isles and Aberdeen (in terms of stocking density, water and feed provision, inspection provision, temperature and humidity and cleansing and disinfection) to comply with all the relevant regulations and has been proven to provide an excellent system” (NFUS Shetland).
A number of animal welfare organisations considered that the concept of ‘neutral time’ should not be supported as “time spent on these ferries may not be equivalent to road or other transport, it is also not equivalent tofarm accommodation … and the welfare implications should be explored more” (OneKind).