Cynulliad Cenedlaethol Cymru

Huw Irranca-Davies, Deputy First Minister and Cabinet Secretary for Climate Change and Rural Affairs. Jackie.

Bore da. Good morning. I'm Jackie Price. I head up the greyhound ban Bill team in the Welsh Government.

And Elizabeth.

Good morning. Elizabeth Thomas, legal services.

You're all very welcome. Thank you so much. We'll go straight into questions, if that's all right. I wonder if you could help us: the greyhound racing industry has said that, in their opinion, the Bill does not promote greyhound welfare across their lifetimes and it—and I'm quoting here—

'is not a serious piece of animal welfare legislation',

and it rather takes an animal rights view. How would you respond to that, please?

No, we would disagree. The legislation is very much focused, as you know, on the prohibition of greyhound racing in Wales. However, there is a wider regulatory and licensing regime. So, those trainers and keepers of greyhounds who may continue after this to choose to race greyhounds—for example, on licensed tracks in England—will be subject to the GBGB licensing regime, which includes whole-welfare considerations of those racing greyhounds. Even if we ban it, even if we take forward the prohibition in Wales, they will still be subject to the licensing regime of GBGB. We also have, of course, the animal welfare regime here in Wales itself, which is in terms of all animals, their whole-life considerations.12

We've also made clear to the committee before that, if there was a need to go further, beyond this piece of legislation, which is very much focused on the prohibition of greyhound racing, to look at that wider, all-life aspect of greyhounds, then it is within our devolved competence and within the consultations that we've done on animal licensing more generally to do that, if we need to. So, we disagree with that point, that actually this is in any way to the jeopardy of the welfare of greyhounds, because all those things remain in place. But I don't know, Elizabeth or Jackie, if there's anything you want to add to that.

Well, yes, just to support what you've just said, that the consultation responses and publicly available data still highlight that regulation alone will not prevent the harm and fatalities associated with racing. So, this reinforces the position that a ban is the most effective way to safeguard greyhound welfare in the future.

We do recognise, by the way, and we've said this before to the committee, Cadeirydd, that the licensing regime, in terms of the keeping and training of animals within the racing industry, we've welcomed that, but GBGB's own statistics show very clearly the unacceptable level of injuries and fatalities in greyhound racing.

Could I check with you on that? Thank you very much for those responses. One of the difficulties that we have experienced when gathering evidence on this is that the evidence surrounding animal welfare issues, when it comes to greyhound racing, is contested by different sides, and some parts of it are incomplete. We've got some contradictory statements that are based on the same data sets—well, not the same data sets, but different interpretations of the same data. Could I ask why you haven't undertaken a comprehensive study of welfare issues across all stages of racing dogs' lives when preparing this legislation, please?

Again, I'll turn to my colleagues in a moment, but first of all, because we have already a regime of animal welfare within Wales. We did a consultation on licensing as well, which gives us the opportunity, if we need to, to go further, but it focuses on the whole life, not just of greyhounds, but of other animals, including companion animals as well. For us, the compelling issue here goes beyond that whole life, vitally important as that is, because that's always been our focus in Wales, is on having animals who have a good life for the whole of their life, and we have powers to go further if we need to on that. But this is to do with the practice and the impacts on greyhound injuries and fatalities from greyhound racing within Wales. Elizabeth or Jackie.

Yes. This isn't a new topic, as I think we've said in this committee before. I mean, prior to Valley being granted GBGB licence, and due to the perceived concerns over standards at their independent track, there has been—. Hope Rescue launched the Amazing Greys project in 2018, just to improve the conditions of the racing greyhounds. That's where Cut the Chase came in behind that, looking at the evidence that's been presented. And since they've been a GBGB track, from the aggregated data that we're getting from GBGB in relation to all of the greyhound tracks in England and Wales, no matter which way you look at the statistics, dogs are being injured and dogs are dying.

And it's probably worth, Chair, reflecting on what we heard from the respondents to the consultation as well, where, even those who were in favour of licensing, also the majority of them expressed support for a move towards a ban as well, so they also saw the difference between that whole life, and that is important, because even if, with the will of the Senedd, we move to a prohibition on greyhound racing in Wales, we still have to consider properly those whole-life impacts on the welfare of greyhounds, both in terms of rehoming, but also those people who may well continue to say, 'Well, I am going to keep, train and race, outside of Wales, my greyhounds.' In which case, we absolutely do need to focus on the welfare of those greyhounds while in Wales, but that comes through the licensing regime of GBGB, because there are responsibilities on an owner—not just the track, but on the owner—through that licensing regime, but also our own licensing and welfare regulations here within Wales as well. But, as I say, there is the ability—. It's not within this legislation; this legislation is to do with the prohibition of racing greyhounds in Wales. But we could, if we needed to, actually go further and look at additional regulations to do with the keeping, owning and training of greyhounds within Wales, separate from this legislation, if there is a need to do that. So, we're very focused on the whole-life aspect of it.

Okay. Thank you. Jackie.

Just one more thing from me though, we know that there are contradictions between stakeholders. Officials are considerate of those arguments, and we would look to fact-check all available evidence that is submitted to us. 

Thank you. Llyr.

But surely that should be done before you bring a Bill forward. 

Well, as it's coming in we're fact checking. There will be arguments. These statistics that are being used, the emphasis is slightly different, depending on who's using them.

Indeed, but we're scrutinising a Bill that's been put in front of us based on, presumably, a set of data that you've used as an underpinning evidence base. But you're telling us—and we've had it clearly through evidence—that the data that's being bandied around is hugely contested, and what I'm hearing is that that's still work in progress for you. 

Well, it isn't, because—

Well, that's what I've just heard.

I understand that there are different views expressed, and we've seen them expressed to the committee as well, but you cannot take away the underlying fact that we have an unacceptably high level of injuries and fatalities through greyhound racing, which is the focus of this legislation. There is undoubtedly more that we could—. This isn't that Bill, Llyr, though. This isn't that extension of licensing—another proposal that may come in a future Senedd—to do with an additional layer of regulations around greyhound keeping and training and so on within Wales, if they choose to operate outside of Wales with actually running their greyhounds. But in the focus of this Bill, the prohibition of greyhound racing, it's very much on what we absolutely know from GBGB's own figures.

So, why have you gone so narrowly on this Bill then? If you're sort of recognising that there are bigger issues out there, should you not have taken a step back to do it once and do it properly? 

No, because the great thing about devolution is that we can go on the evidence that we currently have; we can move ahead. Curiously, I had this put to me in the Senedd yesterday, in a different policy context: 'Why do you always go on to the nth degree, to get 100 per cent, absolute categoric, or 110 per cent categoric assurance of the evidence, before you make a policy decision?' So, I understand why now. I'm now being challenged the other way. 'Can you please get 110 per cent before you do?' Actually, we have very, very robust evidence of why there's a need for this legislation. But we also, within the devolved competence, if we need to in future, can go further in that whole-life thing. We already have very good provision there in regulation, with animal welfare and whole-life aspects of the good life of any sentient being, to act on that in Wales.

Could I ask, on exactly that point then, GBGB have—? Well, they've presented figures to us that would highlight that the track fatality rate in greyhound racing in 2024 was 0.03 per cent. Well, British Horseracing Authority data for jump and flat racing shows a fatality rate that is, in what's been presented to us, noticeably higher at 0.25 per cent in the same year. Now, I should say that it isn't immediately clear if these are directly comparable, but those are the data that have been presented to us. So, why would the Welsh Government decide to ban greyhound racing, but not consider banning horse racing, based on the damage being done to sentient beings? 

I think there are red herrings being put forward here. The focus of the consultation we did asked specific questions about greyhound racing, and asked for evidence and views on greyhound racing. And that's exactly what we focused on. It's interesting, as we have some contestation over the level of injuries and level of fatalities, there is no contestation whatsoever that there are high levels of injuries and fatalities within greyhound racing, and that's the sole focus of this legislation. As I've made clear, crystal clear, before, the entire focus of this is on greyhound racing, not other types of racing, although I understand that some people might want to drag it wider than that. This has nothing to do with horse racing or anything else. It is the categoric, clear evidence that there are what we deem in Welsh Government, and which I think is well supported by animal welfare organisations out there as well, unacceptably high levels of fatalities and injuries with greyhound racing. That's entirely what this is about and nothing else. 

Thank you for that.

I'm interested in the approach the Welsh Government has taken. We've discussed this already, Deputy First Minister, at another committee, and I'm trying not to rerun an edited highlights of that committee this morning. But you said earlier in answer to the Chair that regulation would not achieve policy objectives, and the only possible alternative was to move straight to a ban. I think I'm paraphrasing you correctly there. But you've got no basis on which to say that. You've got no evidence base to show that regulation can never work. 

The absence of a piece of legislation that is specifically to do with greyhound racing, which is where the calls are focused, Alun, within the consultation but also, and without rerunning, previously the Senedd debates here and the petitions that inspired those debates, the cross-party support—

Yes, but we have petitions every week of the year.

Indeed.

The Government doesn't move straight to a ban on the basis of that. 

A petition on its own does not move legislation forward. But a petition that commands cross-party support, clear cross-party support, but also is backed up by what we heard in the consultation, is also backed by the GBGB statistics themselves, enables Welsh Government to bring forward a proposal of the best way to deal with the issue.

Now, the question is, 'Should it be regulation or legislation?' There is an absence of any clear legislation around greyhound racing. The focus of the responses to the consultation was on greyhound racing. We only have the one track, but we do recognise, Alun, that in banning greyhound racing we need to make sure as well that we do not have greyhound racing that then appears in a farmer's field somewhere, being run out of the back of a four-wheel drive.

I understand all of that. I appreciate all of what you've just said. But nothing that you said, of course, answered my question.

Which is—?

The issue I have is that the Government is moving immediately to a ban, which is an extreme position. Banning a currently legal pastime or activity is a terribly extreme position to take in any liberal western democracy. And my suggestion is to you—and you've answered already that there is no possible form of regulation that could work, short of a ban, and therefore a ban is justified—

Correct.

—and I'm saying to you that I've seen no evidence at all for that statement.

Well, I would dispute that. I would dispute that, and it is perfectly within the imperative of a Government to look at the evidence that has come forward from a consultation, the views expressed by Senedd Members in our elected Parliament, and the evidence of injuries and fatalities, which I keep coming back to as the defining issue here, which has moved this policy position. And by the way, regulation was tried in New Zealand and failed, which is why they brought forward legislation. The benefit of a piece of legislation is that it's clear, focused and it's on the primary statute book. So, that's why—

I'm not questioning your right to bring forward the legislation. You clearly, as a Government, have the right to bring forward this legislation, but we have the right to test it as well.

Indeed.

And my question to you, which you still haven't answered—it's my third time of asking, Deputy First Minister; you're usually far more open than this—is that you have brought forward no proposals on regulation short of a ban that demonstrate that regulation cannot work. Therefore, the argument that regulation can never work is entirely fact-free.

One of the reasons in the choice of bringing forward legislation, very focused legislation, on this issue, was because we did draw on what had been looked at, what had been explored internationally. New Zealand, who are bringing forward a proposal on a ban in legislation, primary legislation, had also considered regulation. It did not give the clarity that they wanted, including on the issues that we just talked about, which is the ban on the racing of greyhounds, but also it does leave open, I have to say, regulation that could go further into that whole-life thing. But it's a choice of which vehicle you use.

It is a choice, and I want to test you on that choice. Can you outline to the committee the conversations that yourself and your officials have had with the greyhound racing industry, or authority in its wider sense, that outlined all the options of regulation that you debated and discussed with them, that led you to believe that regulation would not be appropriate? 

We've had engagement with GBGB and with the Valley stadium. Jackie.

In the animal welfare sphere, we've been talking to GBGB since before the ban was announced, but there was this train running in relation to the Cut the Chase coalition, who were pushing initially for regulation, but because they had regulation in England, they had GBGB tracks in England and still dogs were getting harmed, still dogs were dying, they changed their emphasis from legislation to protect the animals to pushing for a ban, and they have been presenting evidence to committees. That's what instigated the petitions.

But again, you're not answering my question, I'm afraid, Jackie. The question was about your engagement with GBGB or other representatives of the industry about regulation. I understand that you've talked to people who wanted to ban it, I understand the Government's done that, and I understand the Government's talked to Members here, and I'm glad to hear that the Government values the views of backbenchers. I'm glad that's on the record. But let us look hard at the question I've asked you repeatedly, which you've failed to answer, which is about the exploration of regulation short of a ban. And so far, you haven't been able to answer that very straightforward question.

I can answer it very directly for you. I don't think GBGB and we would agree on whether we use regulation or primary legislation to enforce a prohibition on greyhound racing. I don't think there'd be agreement.

But regulation short of a ban is what I'm talking about.

Right, okay. Well, we're in a different place, Alun—that's clear and categoric.

But you haven't demonstrated the evidence that regulation cannot work.

Go back to the consultation responses from people who are involved in this sphere who made very clear that regulation alone would not deal with the injuries and fatalities that arise from greyhound racing. It was very clear in the consultation. This Minister is very much, based on those responses, from good organisations, I have to say, who look at the animal welfare considerations here, who have made very clear that regulation on its own would not do it—. New Zealand looked at this. They made the clear decision that in terms of a prohibition on greyhound racing, that was the most effective way to deal with the unacceptably high level of mortality. 

I understand that people who favour a ban will have made the case for a ban through the consultation, and I've got no issue with that.

And they provide evidence for those arguments.

And they clearly will do that. I've no issue with that. That's perfectly fair and reasonable, and the right thing for them to do from their perspective. I've no issue with it. My question was to you as a Government. That's a different question, which you're still not answering.

We considered regulation and discounted it as a way forward.

Where is the evidence for that consideration?

We considered regulation in my discussions with officials.

Where is the evidence for it—the evidence that you went through a process of active consideration of regulation short of a ban to enable this stadium to continue to operate, albeit under strict regulation? Where is the evidence for that process?

This came directly out of the consultation responses, which made clear that there was a consensus that regulation would not work in dealing with the primary issue that we're focused on.

There wasn't a consensus, because clearly the industry didn't agree with it. There was a consensus amongst people who wanted a ban that a ban would work. 

And they wanted the ban for a particular reason, Alun, which was to prevent the injuries and fatalities that arise from greyhound racing. So, we're probably arguing from completely different angles.

I'm not arguing. I'm just asking a question that I'm trying to get an answer to.

Regulation was considered, but I discounted it as a Minister because it does not serve the purpose that we are trying to do here.

And the process that led to that decision?

The process was my engagement with the evidence that we heard, the arguments that we heard, and then with a very good team of officials to discuss what are the options here. If our focus is on dealing with these issues, the unacceptable high levels of injuries and fatalities, how do we deal with it? Would regulation work? The answer is 'no'.

But you didn't give regulation an opportunity to work, either. 

Jackie.

We did consider regulation in the consultation; that was one of the questions.

I know you considered it in the consultation, but that wasn't the point—

I understand now what you're saying, I think.

The point I made was you introduce regulation—very strict regulation—with the objectives that you set for that regulation in terms of fatalities, injuries, and the rest of it, you put that to work, you let it run for a year, 18 months or whatever, to see if it can work, and if it doesn't work, you move ahead to a ban—

Now I understand what you're saying.

—which I think would be reasonable, by the way; I've got no issue with that. But what you've done is said, 'Actually, we're not going to do any regulation at all, we're going to go straight to a ban'.

Now I understand exactly what you're saying: why don't we take a phased approach that tries regulation for a period and then moves to a ban if it isn't satisfactory? The evidence here of the licensing of GBGB tracks, and a regulatory approach that was also explored by New Zealand, was quite compelling in that regulation does not deal with the fundamental issue that we are talking about. It will lead to better licensing, better regulation of an activity that leads to injuries and deaths at an unacceptably high level of greyhounds.

So, would regulation work? No, it wouldn't. Did we consider it? Yes, we did. Did we discount it? We did, because the evidence, and my analysis of what we have seen internationally, but also the views we have seen expressed, was that it would not serve the purpose we are trying to do. We could do that for 18 months, we could do it for three years, for five years. Credit to GBGB for imposing a licensing regime and more stringent conditions across the tracks that they operate in England and Wales and so on, but it has not dealt with that fundamental issue of the mortality and injuries of greyhounds. It simply hasn't. So, my pushback to you, Alun, is the purpose behind this legislation to deal with that fundamental issue. Would regulation do it? No, it would not. 

Is there a level of mortality that you would find acceptable in any sport? 

There are various sports where there is mortality within animals, and I also have to say within humans as well, and not only mortality, but injury. But you're asking me a philosophical question as opposed to, I have to say, a focus on greyhound racing, which this legislation is about. 

On the basis of your previous answer.

In a committee that is focused on scrutinising the prohibition of greyhound racing in Wales, you'll excuse me if I don't enter into a wider philosophical argument about my views on boxing or whatever else.

It's a fundamental question. 

I'm a big rugby supporter, and we've had some tragedies within rugby as well. I'm a supporter of rugby, so draw from that what you will. And my three boys have played rugby. But rather than get into a wider philosophical argument, I'm very focused on the purpose of this legislation.

But your argument is, in pushing this forward, that regulation would not achieve the objective of reducing fatalities and injuries—and I accept that. So, the question is is there a level that is acceptable. I think that's a perfectly fair question to ask Government: if you are saying we're going to ban something because of the inherent danger of it, to say, actually, is this a philosophical policy decision of Government, or is this simply a response to lobbying and the Liberal Democrat demands for our budget?

I've repeatedly used the phrase this morning, 'the unacceptably high level of injuries and fatalities'. That is our conclusion as the Welsh Government. But also, I have to say, the conclusion that the Senedd has reached in a majority position as well. And on top of that, the clear data that we have, which is from GBGB. That is exactly why we've reached the conclusion on greyhound racing in the way that we have.

Just before Alun carries on—. Forgive me, Elizabeth, but did you want to come in there? No. Llyr wanted to come in.

What I heard now is that regulation doesn't reduce injuries or fatalities. Well, it does, because when Valley came under the remit of GBGB licensing, those figures did drop. You may say they're still too high, and I understand that and respect that, but that's not to say that further regulation from Government could drive it down further. And I come back to the same point that Alun was making: you either tell us at what point it becomes acceptable, or you say there is nothing that can rectify or justify that. And if that's true in this context, then heaven knows where that stops. 

If the committee would like to put forward an acceptable threshold for fatalities and injuries on greyhounds, then please put that—

No, it's the Government that needs to do that.

It's your legislation.

But if you have a view on that as a committee, we'd be interested to hear that, because our argument—

Well, if you have a view as a Government, we'd be interested to hear that as well.

Our view is there is an acceptably high level of injuries and fatalities in greyhound racing.

Unacceptably. 

Yes, indeed. It's the same conclusion that the New Zealand Government came to, and I think others will come to in due time as well. The data is very clear on this. The point was raised in our discussion—sorry, I've forgotten who raised it; Llyr raised it—the issue of Valley stadium and the stats showing that, under licensing, the number of fatalities have gone down. We welcome the licensing regime. The question is, overall, is the level of injuries or fatalities that may occur at Valley stadium in the future going to go down, stay the same, or increase.

One of the interesting aspects of the licensing regime that Valley stadium is under now is that it has led to an increased number of race events. So, it's gone from one upwards. If you extrapolate that, I have no reason to believe—. Unless Valley stadium produce alternative evidence to you that they are different from other tracks in the UK, the more events you have, then the more the fatalities are and the injuries are. So, even under a licensing regime—. And I understand that views are being put forward, 'Well, could we just continue with the licensing?' We disagree with that fundamentally.

I'm not saying continue with existing licensing—you could improve. What I'm trying to show is that the trajectory is downwards following regulation. This is self-regulation, albeit accredited by the United Kingdom Accreditation Service. If Government was to implement stronger regulation, do you not believe that that would continue to fall?

The evidence shows that the damage comes to greyhounds from track racing, and track racing particularly where there's curvature of track, where, on those bends, that's where you see the greatest number of injuries and fatalities.

And that's not disputed.

So, how would you regulate that?

Well, yes, okay, but your—

The evidence from New Zealand and elsewhere has shown clearly that regulation would not affect that.

So, you're telling us basically that your view, or Government policy, is zero tolerance when it comes to any injuries or any fatalities in greyhound racing. 

Our argument in terms of this legislation is that track racing, as defined within the legislation, is not acceptable, and should not be acceptable within Wales.

Just before I go back to Alun, could I check—? You've told us that because GBGB regulation means more races at the Valley track, that will see increasing numbers or an increasing propensity towards injuries and fatalities. Could you point us towards the evidence base for that, please, or would you be able to send it to us?

Yes, I'm happy to do that, because we can look at one year of evidence and we can also look at trend information. Jackie.

Just to be clear, before they were GBGB affiliated, there is no data, not publicly available, on mortality rates or injuries or anything like that for the Valley track. Hope Rescue, as I said earlier, did do an assessment based on the number of dogs coming out of Valley that needed to be rehomed and the conditions that they were in. Yes, the regulations that GBGB put in place have improved the standards from breeding, training, racing and beyond. That's not disputed. We did, prior to the DFM taking up this role, look at should Wales license the track. The non-GBGB tracks in England are licensed by the Department for Environment, Food and Rural Affairs, our counterparts in England. We looked at that. We would be criticised for going further than GBGB have gone in their licensing regime, because they believe that what they have put in place has improved the lives, and it has. If we were to go harder on that licensing, to license the track, it would have shut them down. There's no way they would have been able to still continue under the licensing conditions that we would have had to put in to make them better than GBGB's licensing conditions, if that makes sense.

Where's the evidence for that? You just made a statement, a very clear statement, that if you imposed the sorts of regulations that perhaps others have been asking for, then that would have the effect of closing down the stadium. And I'm just asking whether you've got evidence to sustain that. 

To go further than the GBGB licensing conditions, it would not have been commercially viable to continue.

I understand what you said, and I'm asking for the evidence to sustain that.

I can help on that, because if we were to go down the line of a more stringent licensing regime, what would that look like? If we accept that on everything we know, not just from here, but other countries who have looked at this, that the injuries and fatalities of greyhounds come from racing following a mechanically propelled lure around a track that normally has curvature within it—. So, if we licensed to say, Alun, Llyr, that our new licensing regime in Wales would say, 'Okay, we're going to take away the mechanical lures, we're going to take away the curved track, you can only race in a straight line', et cetera, et cetera, there is no—. Under that licensing regime, it would be doing exactly the same thing as a prohibition on greyhound racing would be doing, because—

You're giving particular examples—

—it makes it unviable, and commercially unviable as well. 

That might be the case. I'm interested in the evidence that you have to sustain the statement that your officials have been making. There must be evidence to sustain that argument, and the committee would be very happy to receive that in writing if it exists. I'm sure that you can create a number of different scenarios that provide that, but I'm looking at the evidence that you have available to you to make you believe that regulation is not a viable option in economic terms. 

But are you suggesting that we could put forward an alternative regulatory structure that still allowed mechanical lure around a curved track racing to happen in Wales?

I'm suggesting that, in terms of the way in which the Welsh Government legislates, you move in a proportionate way, whereby banning an activity is the final step and not the first step and that you look at the alternatives to a ban before you examine a ban.

So, if we brought forward regulation that regulated, in effect, 'You will not have mechanical lures, you will not have curved tracks', and so on—

You're giving me examples—

But it's very specific, because we're talking about greyhound racing and why injuries and fatalities occur. So, would you be content—? That would not be regulation of an existing track. Valley stadium would not be able to operate under that—

And I'm asking you for the evidence to sustain that, and taking the same view as Caerphilly council has, of course, as you'll be aware, and I think Animal Licensing Wales, which said that a ban is fine, they've got no issue with a ban, I think both have been clear about that, but they would prefer a graduated and proportional approach, and I'm interested—

Towards a ban.

Towards a ban, potentially. And I've got no issue with a ban, if—

It wasn't potentially; the views were for a ban.

I've got no issue with that, if that is the destination that you arrive at, having exhausted all other possibilities. And it appears to me that you haven't exhausted all other possibilities, you've just moved straight to a rather draconian piece of legislation in the first instance, without examining the opportunity to regulate the industry and the activities prior to introducing this legislation. 

GBGB are already regulating, and there's a better standard than there was previously before licensing the industry—

I accept that. 

—and that has led to some improvements. It still has an unacceptably high level of injuries and fatalities. 

It's not GBGB that is in front on the committee this morning. 

There is no regulation here on a path to dealing with the ultimate aim of eradicating that unacceptably high level of injuries and fatalities. I cannot see what you're putting to me that is a regulatory approach to that.

And you have a zero-tolerance attitude as a Welsh Government to any injuries and any fatalities in greyhound racing.

No, you've just put words in my mouth directly. I've said repeatedly, and it's clear from the data, Chair, that this is a demonstrably unacceptably high level of injuries and fatalities for greyhounds, and if we—

Absolutely, and you've declined to give us what you would regard as an acceptable level.

Because there isn't a threshold level. 

So, therefore, you accept the zero tolerance. 

No. No.

That's my only possible—

No. Every Minister, yourself included when you were a Minister, comes to a very balanced judgment, based on the evidence available. And I come back to the point that was made before. Previously this week, I've been challenged on a different policy area to say, 'Why don't you just make a decision, because you can see that the evidence is very fairly stacked up here?' In this case, I've made the decision. When I came into this post—and I know we've had this discussion previously, Alun—this was in my in-tray. I wanted to consider this properly and I went through this, and my judgment is, as backed by Cabinet, by Welsh Government and by a majority in the Senedd, that the evidence is compelling enough to make a move for a prohibition on it. We cannot regulate this effectively. GBGB has tried to do that in licensing. If I was to regulate a straight track, no mechanical lures, to avoid those injuries and fatalities, that would be, in effect, a ban on greyhound racing.

I don't think we're going to get any further. 

Could I check—? You told the Legislation, Justice and Constitution Committee that the budget deal with the Welsh Liberal Democrats was not pertinent to the Government's consideration of the legislation. Would you be able to tell our committee the date on which the decision was made to proceed with the ban, and when the budget deal was finalised, please? Because it's a point that's been raised with us, so it's something that we have to—

Yes, indeed. I don't know if I have the dates with me, but I can write to you subsequently. 

Thank you.

So, the budget statement in its entirety, in all aspects of it, was made subsequent to my decision on this. I think I've described to the committee before the timeline of my consideration of this over the previous year, followed by my statements in February, followed by additional statements, which led on that clear path to me making the final call on a policy basis on this matter, as we've discussed today, to move forward with legislation on a ban on the prohibition of greyhound racing in Wales. There was a statement made subsequent to that to do with the budget negotiations, but it has no bearing on the policy decision that I've made. But just to be clear, within the budget considerations, in the totality of that statement, it was referenced and it was pertinent to those wider budget considerations, but my policy decision as a Minister is my policy decision as a Minister, based on the discussions we're having today on this legislation.

I don't know if we have the dates of where the statement—. But we can drop you a note today on the dates on that.

Thank you very much. That's really helpful. Thank you.

Thank you very much, Chair. I want to move on to the economic impact of the ban and move to employment and retraining, because a representative of the Valley stadium in Caerphilly, who's a member of the implementation group, indeed, told us that there has not been one word mentioned in the implementation group or outside on funding or retraining. Can you detail how the group is considering the economic impact of the ban, particularly in that regard, on employment and retraining, and when you expect those proposals to come forward, Cabinet Secretary?

Thanks, Gareth. Could I, helpfully, put an ask, an offer, to Valley stadium themselves here, which is to help furnish us, furnish the implementation group, with the granulated information on the number of people who are employed, contracted, permanent, part-time, contracted out, franchised out, whatever, who are actually employed at the track? Because that will help us significantly in the discussions that are going on in the implementation group about reskilling and retraining.

The reason I say that is, as of this moment, we are still not clear on the number of people who are actually employed at the track, as opposed to a headline figure. I think the figure that's been said orally to you as a committee, or it might have been said elsewhere, is about 85 people. We have no granular detail whatsoever on that at the moment. We have repeatedly asked Valley stadium for that information. It can be provided, by the way, in a number of ways. If there are issues of commercial confidentiality or so on, there are ways in which this can be done. But we need it, Gareth, in order to then decide what do we need to do in skills and retraining. We also need it, by the way, in order to do a more detailed impact assessment. We have headline figures, which we've based our impact assessment on, but I repeat that call to Valley stadium to present that information in one form or another to the implementation group, because then we can work this out.

Okay, yes.

Gareth—. Forgive me, Gareth. Sorry to interrupt you. Mick just wanted to come in on a quick supplementary before we come back to you.

Just on that, that's a pretty fundamental request, for that sort of granular data. 

It is.

Just for information, how long ago, how many times, has it been asked for? Have you been given any indication as to why that information is not being provided, or have you been told it is just not available?

I'm sort of having to interpret what the problem is in bringing that information forward. It's been asked for repeatedly, not simply since the establishment of the implementation group, but in discussions prior to this with officials, that that will help us build a much more granulated impact assessment as well, which we really want to do. So, we have a good impact assessment, based on what's been given to us as headline figures, but I come back to that basic one, which is pertinent to Gareth's question as well. There's a sort of ballpark figure of 85 people. Well, how many of those are not actually employed at the track, but are contracted out or are on, I don't know, zero-hours contracts or whatever? Who knows? And we really don't have that. How many of those are working in other jobs, and this is an additional job that they do when the track event is going on? We don't have that. So, we're keeping on asking, with the implementation group, for it.

If there's anything that has been given to you that would help us with—. But we will continue—. It's great, I have to say, that Valley stadium are on the implementation group, because we really need them on there to talk about future potential uses of that location as well. But, as of this moment, we really want to hear from them with the detail of exactly who is employed, on what basis, doing what jobs and then, Gareth, we come back to your point of, 'Here are the skills and training that we can provide.' At this moment, if you look at—. Sorry. If you look at Companies House data for the most recent iteration, it's interesting that the description in Companies House, which is in black and white, as opposed to oral, headline ones, is that there's one employee. I'm sure that's not the case, by the way, but we do need that detail from Valley stadium.

Thank you for that. We'll go back to Gareth.

Thank you, Cabinet Secretary. I think that's a fair point. And I think, obviously, if it's not the case that Valley stadium have been forthcoming with that data, then you should be able to access it. I do agree with that. But what I am keen to find out more about is whether you and the Welsh Government are indeed exhausting all of those avenues and taking a proactive approach in trying to find that data and find those figures. Because you've told us before that the Welsh Government do have a very good track record in Wales when it comes to such transitions in terms of reskilling for other employment. So, are you able to elaborate on any figures on re-employment rates in previous transitions that you might have presided over, or indeed, the Welsh Government generally, where you can, perhaps, track those figures, and say, 'Well, we do have a good track record of this. This is our record. Engage with us, and we can do the same thing for the Valley stadium when this ban comes around'?

Gareth, more than happy—. We've already said that we'll write to the Chair and to the committee with one aspect on the chronology of decision making around the policy. We're more than happy to share with you, then, the success of what we've done before in these types of transitions with ReAct and other employment and training support, because we're ready to do this, Gareth. We really are ready, and we're geared up to do it, and we have a good track record in doing it, but we need to know what we're working with. And on that basis, what we do need is—. And we appreciate that, from Valley stadium's point of view, there may be some sensitivities, commercial sensitivities, but there are ways in which this can be presented so that we can engage with some of that and then refine not only our impact assessment, but also our modelling for the skills and training. So, we need things such as commercial, contractual, employment, financial data. We need things such as attendance figures as well, those sort of aspects. And we've just got a lack of substantiated facts and clarity at the moment to do that work. But it can be provided. That would be my offer to Valley stadium—I think, through the implementation group, they can find ways to protect sensitivities and then we can do it. But, Gareth, more than happy to go back from this and provide to you the support that is standing by ready, should it be needed, and also some of the examples of what we've done before to manage these types of transitions in a very different sphere.

I think that would be very helpful. Thank you, Cabinet Secretary.

Something we do have more awareness on, in terms of figures, is that Sports Information Services Limited told us that a conservative estimate of £15 million would go to the Valley stadium over five years for media rights, with the vast majority of that money benefiting the local community. What do you anticipate that the Welsh Government will be able to do to mitigate that kind of loss, given that it's a significant amount of money, given it's the only track in Wales, to mitigate that sort of loss, which is said to have a benefit for that local community in Caerphilly?

We've got a similar issue here, Gareth, as well, in that what we've got is headline figures that have been put, sometimes orally, but without any granular detail or substantiation below them. We need to know—we need to know—what those contracts are, how long they are, how many years they are, how soon they expire, in order for the implementation group to take really considered views on the way forward, and, for us, I have to say, to also deal with bringing forward, as I've said to the committee before, future iterations of the impact assessment. So, a headline figure or something that's presented orally is not sufficient for us to actually get into that detail. Again, my appeal would be, even respecting sensitivities—commercial sensitivities—we need to have that shared with us by Valley stadium, so we can really make an assessment of it. At this moment, we've just got ballpark figures, so I can't respond in substance to your point, Gareth, because of that. 

I fully understand the need for commercial sensitivity in many ways. Do you think that's the only reason why they might not have been forthcoming with categoric information, within what we spoke about originally around employment and retraining, but then, equally, in the second question, in terms of this £15 million to the local community? Are there any other reasons that you may have been able to come to as to why this information has not been forthcoming so far? It's very subjective, isn't it, in that sense, and perhaps we do need to see figures and what the Welsh Government can do better to attract those figures. Yes, we can ask—the Welsh Government could certainly ask, sorry—for this information to be provided. But do you think there are any other, or do you think there are any additional exercises that the Welsh Government can do to find this out, or perhaps work more collaboratively, work closer together, to find this information and work on more of a collegiate sort of approach to it? I know, as a default, they wouldn't be perhaps of the same opinion on this ban as to what the Welsh Government will be. But, nonetheless, given the progress it's making, is there more that the Welsh Government can do to engage with that to get more tangible figures on the table, so we know what we're dealing with, essentially?

Gareth, thank you for that question. We haven't been offered any other reasons why the information and the detail that is needed hasn't been forthcoming, and we cannot force Valley stadium to provide the information. In the collegiate and collaborative approach, that's exactly why we set up the implementation group with the independent chair, so that we can gather this information and it can be discussed within the group. So, I can't speculate, Gareth, as to the question you asked as to why it may not be forthcoming. I would simply say, 'Is the Welsh Government doing everything to offer the opportunity and the ways in which this information can be shared?' Yes. The implementation group is very much that collegiate partnership approach to sharing information. Why has it not been provided? I don't know, but the offer is there and it can be provided in different ways so that the implementation group can engage with it.

And can I also say why this is really important as well? You'll have noticed, and it's come up in previous sessions of this committee and elsewhere, we provided a window—it's a three-year window—in terms of the implementation date of the ban, effectively. That is for a very good reason, because if there are, for example, contractual arrangements that need to be worked through, whether it's in employment or whether it's actually in commercial contracts, then the implementation group, if it has that information shared with it, can actually come to a considered and measured judgment as to how soon a ban can progress or whether it needs to be further down that window span. But we need that information to be shared. So, Gareth, can the Welsh Government do any more? We can't force. We've provided the space where this information can be shared in a partnership approach. And we repeat that gentle ask to Valley stadium: the sooner we can have this information on contracts, on commercial contracts, on employment, all of this, then the better and faster we can proceed with the work of the implementation group.

Okay. Thanks. I appreciate that response. So, I just want to move on to the phasing of the ban, and animal welfare charities have said that an early ban will make rehoming easier, with many calling for a ban within 12 months for animal welfare purposes. How do you respond to that sort of notion of an early ban? 

This comes back to, or it's reflecting back on, an earlier point made by your colleague on the committee, Alun, because we haven't set a defined date within this that it will come in—the ban will come into place on this date in this year. We've set a window, and the implementation group will bring forward the recommendations about how fast we can progress to a ban.

Now, I appreciate the animal welfare charities out there would want to see a ban tomorrow. I think what we've taken is a very pragmatic approach. They're on the group as well, by the way—the implementation group—some of the key partners and stakeholders, including the local authority as well. They're on the group as well. They can come to a very measured, considered view as to how fast we can move to a ban, but I want to leave it to them, Gareth, not for a Minister to say, 'Let's just respond to one group, who are saying, "Let's do it tomorrow"', or another—

That's probably where I'd rephrase it and say, 'Well, how much would those factors play a part in that decision making?' You say you'll be led, obviously, by the likes of those animal welfare charities, but, ultimately, this Bill is being driven by the Government, driven by you in the relevant departments. You're the Government and, ultimately, it will be your decision. I think the question's probably more on how much that would play a part within that decision-making process of when that ban would take place, and how much of a factor those would be within that process. What would a likely ratio look like within that decision-making process? That would be the ultimate question.

It's going to play a significant part. That's the reason we've set it up very transparently. If the implementation group brings forward a recommendation that says a ban can be brought into place in 2027, and we've weighed up all the material consideration of contracts—commercial contracts, employment contracts—we've looked at the aspects of reskilling, and the future repurposing of the location for another productive use, et cetera, and not leaving it derelict, then that will be heard fully by the Minister sitting in this seat. It'll also be heard by the Senedd, this committee, and others. If, however, they come forward and say, 'On our considered view, it shouldn't be in 2027; it needs more time', we've given them a window, Gareth. Now, this is not going to be something done in secret and then me just going randomly, 'Well, I disagree with that. I'd like to do it within six months', or, 'I'd like to take three years'. It will be informed by the implementation group, and that is, really, why we need real input into it by the stadium, by the local authority and by others. That group, by the way, is wholly representative of the people who are operating the current site. The local authority's interest in this includes, by the way, not only the employment, but also what the future use of this site may be, and how they can work with this operator, or a future operator, in making good use of that site. The implementation group is of primary consideration here in what the timing of an effective ban would be, and the way in which it's taken forward in a very practical, properly considered in the round way. It's unusual in legislation, Gareth, as you know, to give a window, but we think their work is going to be fundamental to when a ban is implemented.

I'm slightly confused in some ways, because there are examples, in terms of Swindon, for example, where it was announced in March that the closure was taking place, and that's going to happen in December—next month—for example, which could be regarded as a fairly short time frame. The evidence that you gave to Alun earlier on in the session is that this is very much driven on an animal welfare basis, where you've said that they would close a racetrack tomorrow. You're alluding to elements of flexibility in 2027. I think it would be good for us as a committee and, indeed, all relevant stakeholders, to have some more concrete data as to what the Welsh Government are thinking, within a deliverable time frame, with all those elements you've raised. But I certainly don't think it would be harmful in any way to share that, given that others haven't. So, how do you respond to the difference in responses from you, but then also, when we've seen those examples in Swindon, where the time frames have been fairly small—in six months, in some cases?

The real difference here is that, in the Swindon example, or if you go back years within Wales, to the closure of other tracks, they've been closed because of things such as commercial viability and decisions of the operators. Some of them have closed literally overnight, with no consideration of the animal welfare implications of rehoming greyhounds, and so on. This is a different one. This is actually designed so that we can take a planned and pragmatic approach. We do not need to—although it might be that the implementation group says we can—move rapidly to a ban. It might be that the implementation group says 'no'. In a planned approach to this, we need to put things in place—the retraining that you mentioned, the skills, the dealing with commercial contract information et cetera, the future use of the land, the issue that this land, actually, is on or adjoining a flood plain as well. So, what will that mean? How do we work through that? The difference between a Swindon, Gareth, or a Skewen or whatever, is those closed by the operators closing them or walking away from them. This is, actually, a much more planned approach to it that involves all the stakeholders and talks about future use, and how we move from where we are now to a prohibition of racing, not only at that stadium, by the way, but wider across Wales. This is a planned approach, so I think it's right to give the implementation group, who have all the stakeholders on there—the relevant stakeholders—the ability to consider what would be the appropriate timing of the implementation of a final ban.

Okay. Thank you. No further questions.

Diolch yn fawr. In our initial scrutiny at the start of Stage 1, I asked you a few questions about definitions in the Bill, and I'm coming back to that now, really. I asked you whether you felt a definition of 'greyhound' is required, and you said 'no' and that you believe that's sufficiently clear. But we have had evidence, particularly from academic witnesses, that maybe a broader definition of 'sighthounds' should be used, so that you avoid the potential consequence of cross-bred dogs being run, because they might technically not be classified as greyhounds, but they do share significant characteristics. I'm just wondering whether you have any views on that, or whether you have changed your mind.

We do, and and we do appreciate we could have brought forward a very different piece of legislation that is not focused on what we're trying to do, which is the prohibition of greyhound racing in Wales. We could have brought forward a Bill that was a prohibition on sighthounds. We could have extended it to go beyond into other areas. But, actually, the issue here is a very specific one in terms of greyhounds, and the commercial imperative behind greyhound racing is a breed of dog that is widely recognised on a type of track and a type of event that is widely recognised, that has commercial buy-in beyond the track itself, very often, in terms of tv rights or broadcasting or gaming, and so on. So, extending to things like sighthounds might be something a future Government want to look at, but, actually, for the purpose of this and the consultation we ventured on, it is greyhound racing that is the issue in hand, and greyhound racing is the one that we focused on.

We did, Llyr, just to reassure you, consider in our deliberations as we brought forward the legislation, 'So, what about sighthounds? What about whippets? What about different ones?' Crikey, it is an inadvertent consequence of this that we could have terrier racing, or whatever. Now, curiously, by the way, there is another factor within this, which I don't know if we discussed previously when it was in front of the committee. There are, for example—and you'll be familiar with this; I'm very familiar with this—rural fairs, agricultural fairs, where there is not competitive racing, not commercial, not gaming, but there is a charitable fundraising event of some terriers running in a straight line or whatever. The owners take them—it's their domestic animal, it's their farm animal, or whatever, and it's one day for a bit of fun. We're trying not to capture that, either. But, look, sighthounds would be another piece of legislation, which was not explored in the consultation. Greyhounds is what we're focused on.

Fair enough. Okay. Diolch yn fawr. Similarly—[Interruption.] Oh, sorry, did you—?

I was just going to add to that that the industry itself, when they were giving evidence, said that such a shift would be commercially unviable, and that it would require a systematic transformation of a global industry to use any other dog than what is recognised as a greyhound.

Fine. Diolch yn fawr. So, the definition of 'greyhound racing', then, as as well was another one that was raised. Now, obviously, it's—and you've reiterated this—behind a lure around a circular track, but we have heard from animal welfare charities that they would potentially have issues with straight tracks as well, because of the surface et cetera. I'm just wondering, again, is that something that you have reflected on? 

Yes, we really considered this very carefully when we brought forward the proposal, because what we're focusing on is the recognisable characteristics of greyhound racing, and where the injuries and the fatalities happen, and it's often very much on a track that has curves within it. They run round a track, which is why it's described in the legislation as 'around a track'. It doesn't say curve or curvature, but it says 'around a track'. This is a definable characteristic of the commercial aspects of greyhound racing. Now, could alternative racing be set up that was straight line with a mechanical lure? Well, no. Mechanical lures are ruled out. Could somebody come up with—?

A mechanical lure is only ruled out if it's in a circular—

Indeed, indeed. Absolutely.

So, it could be allowed. 

Yes, yes. Indeed, indeed. But the whole commercial basis of greyhound racing as we know it, as was consulted on, as has been expressed by all those animal welfare charities, is very much on a definable type of racing. But, just to make it clear, this Bill also captures even if that was set up in a farmer's field somewhere, illicitly set up. So, it still captures that within it. So, we're very aware of what could be a consequence, that somebody—some fool somewhere—decides to run illicit greyhound racing of similar characteristics. Well, that is captured within what we have. It is not considered in any way a likely outcome that somebody will set up a straight track, mechanically-lured operation, because there is no commercial demand out there from punters who turn up or from the gaming industry for that. The whole industry is based around a track that greyhounds run around at speed with a mechanical lure.

Okay. Another potential consequence, of course, would be, if it was banned in Wales, that those dogs from Wales just travel further into England to race. And an unintended consequence of this Bill could be that you don't actually address the problem, you just move it to somewhere else.

Indeed. You're absolutely right. I think it would be reasonable to expect that some of those trainers, keepers, racers currently within Wales—if, with the will of the Senedd, we move to a prohibition of the track within Wales and any other tracks emerging—they will choose to continue to race at other tracks in England. In which case, two things are pertinent. One is the existing animal welfare regulations we have over the transport of live animals, which apply to greyhounds as well. The other aspect of this, of course, is that they will still be subject to that wider licensing regime of GBGB, which we've welcomed, because it also looks at that wider welfare consideration of greyhounds when they're being trained, when they're being transported, et cetera, et cetera. And it's perfectly within our devolved competences, if we saw something emerge that was of concern to us beyond the regulations we already have on transport of live animals, which apply to greyhounds, that we could go further if needs be.

We don't anticipate it will be a major problem, but it's perfectly conceivable, I would agree with you, that some trainers will say, 'Well, if they're shutting the operation of tracks here in Wales, we will do—', as they currently do, Llyr; this is not going to be new. 'We race in Caerphilly. If that option is taken away, we will continue to race, as we do with our dogs already, in other tracks as well.' This is not going to be a new phenomenon, and it's not new either, not in terms of Wales or England or Ireland as well, where dogs actually move already.

Yes, okay. Can I just ask a slightly different question, coming back to, maybe, some things that were said earlier? We know that 85 per cent, or 84, 85 per cent, of dogs come from Ireland, don't they, into this country. We also know, or we've had evidence, that between 10 per cent and 20 per cent of those are unaccounted for after 12 months. Did you consider addressing these issues at that end, rather than introducing a ban on racing here in Wales? Because those dogs will still be coming through Wales, I presume, to wherever they end up.

You take us on to a very important—even though it's separate from the legislation we have in front of us—a very important issue, which is to do with the lifetime course of those greyhounds that are involved in the industry that are not accounted for at the end. Now, it's not within this legislation. This legislation is very much focused on the stadia. If we were to do a piece in future that looked at that—what happens to those greyhounds that, in effect, disappear, they're not rehomed and whatever—then I think that would probably necessitate a piece of work between the Government in Ireland, ourselves, and also UK Government as well, to look at that piece, because it is a pertinent piece, but it's not within this legislation. But I agree with you, when we look at animal welfare considerations in Wales, we always take the approach of saying, 'How do we improve the whole life lot?' And if we have greyhounds or other animals, because, yes, there have been previous illustrations, curiously—. No, I don't want to go there, but there have been previous examples in other animal welfare considerations where other animals, not dogs, have disappeared out of the system entirely, including animals that have actually been chipped and licensed and suddenly disappear from the system. So, the question becomes: well, where are they going? But it's beyond the remit of this legislation.

Diolch. Thank you.

Just a couple of questions on the offence itself. I'll try and combine them, perhaps, into one question. It's very narrowly drafted in terms of who actually commits the offence. There have been suggestions that these should be broadened out and include, for example, trainers, owners, attendees, those who facilitate and participate within it. Some of that already exists with regard to legislation relating to hare coursing, and just, really, what consideration has been given to that and to the narrowness of the legislation. I suppose only because it raises any issue of the ability to enforce, but also to ensure that legislation is actually effective and, I suppose, broadening it out, really, to, if you're saying that this is something that shouldn't happen, it should be unlawful, those who actually facilitate and participate to make it happen, whether there should be a much broader definition, I suppose, of who the offence actually applies to.

I'm worried here about being interrogated by a former Counsel General, and with your legal background as well. But what we've tried to do, Mick, to give you some assurance on this, is we've tried to take a very practical approach to the legislation, so that the enforcement is clear and deliverable. So, the way we've done that is, rather than go after every punter in the field who attends an event, which could be an inordinate amount of resource and, basically, chasing wild geese, to go after the organisers and the operators. But, as defined within the Bill, those could be the organisers and operators in terms of the people who've identifiably put the event, the illegal event, together, and whether that is in an organised stadium or in a field somewhere in the middle of nowhere. But it also extends to issues of premises as well, which are quite interesting. And within those premises, we've anticipated, in a very practical way, that that should encompass, for example, somebody who's sitting in the back of a four-wheel drive jeep—just in case this were to happen, we would identify that and be able to go after that individual.

We think this is a fair, practical and proportionate approach to doing it, because you go at source: those who've organised and who are operating. Rather than, in a more broad-brush approach, go after all those who attend and so on, go at source, because that's where the problem would be: the organisers and the operators who are criminally, then, if this is to proceed, operating illegal greyhound racing within Wales. We don't think it'll be difficult to identify either, because whether it's in a field in the middle of nowhere, when the police and enforcement agencies arrive, or whether it's in a stadium that is more easily seen as a track, whatever, those individuals who are organising and operating, I think will be able to be identified and held to account.

So, you make a very significant distinction. It is very much focused on a sport that is in a particular location, although there are many peripheral aspects to it in terms of transport and the training. But we've seen with other legislation to do with welfare, for example, fox hunting, the number of ways around it, the complications that have existed. Just, as I say, you've given consideration to the efficacy of the offence, and you've basically ruled out broadening it, although, of course, hare coursing—. What would be the distinction between hare coursing, which does have a broader remit? It might be worth—just your view on that.

Well, interestingly, there is a relevance here, because greyhound racing, as we've discussed previously this morning, is a definable type of activity that has a commercial buy-in, including with the gaming industry, because it has certain characteristics: those mechanical lures around a track—and this could be in a field—that is discernible, it looks like a track and so on. Hare coursing is very different in its characteristics.

Hare coursing, as you know, is a major issue and it is often run by criminal cartels, in effect, who will move around the country as they're chased out of one area to another, but different, because, in hare coursing, they're not looking for a definable track or a mechanical lure; it is a big space of—it's sounds as if I'm very familiar with this, but I am through my role in terms of wildlife crime—big open tracts of land with good sight lines. Very often, in mid night, a group of jeeps will roll up and cause mayhem for the farmers and the landowners, and they'll arrive in a big, open stretch of common land or whatever, and they will race and they will bet and they will disappear. There's no track, there's no lure, it is much more—what would the word be—undefined in its characteristic, and the commercial viability of greyhound racing and the attractiveness and commercial imperative are very different from the serious criminality and gaming that goes on with hare coursing, which, frankly, can turn up anywhere, in any space, in a big open space of land and let the dogs run. They also need somewhere where there are hares, which is why it's certain types of land. But it's very, very different from what would be recognised as greyhound racing.

So, that's why we think—not 'think', that's why we strongly believe—. And we have tested this amongst ourselves: could we have real confidence that, if somebody turned up in a field somewhere, let alone in a stadium, we could identify straight away, 'This is greyhound racing. Those are greyhounds, there's a mechanical lure, there's a track of some discernible thing here, and those are the people sitting around there with the walkie-talkies or whatever, they are the organisers'?

Okay. Thank you.

Okay. Just quickly, I know that we're brief on time, but, just before we come back to Llyr, could I just check—? You've said a few times that it would be very easy to identify the organisers of an illicit race. If this were, as you say, in the middle of nowhere—. You just referenced walkie-talkies; other than that, how are you so confident that it would be possible to identify who the people were who had organised the event?

I think it's a very practical approach. Whether it was in the middle of a field or whether it was in a stadium, those individuals who are literally organising the event, who are directing operations, who are guiding people here, there and everywhere, who have a four-wheel drive parked in the corner of a field—. I'm not saying that this would happen, because we think that the chances of this happening are extremely limited, because the whole basis of the commercial operation of greyhound racing is based within those licensed stadiums now. That's where it happens. There is nothing that happens of this ilk. Hare coursing is a very different thing. It's underground criminality. But it would not be difficult to identify those individuals, if it were to be in a field, who would be the ones—. And we will, of course, be engaging with enforcement agencies on this as well.

Okay. Mick has a very brief supplementary before we go to Llyr. 

Just a very short one. I suppose that what it comes down is that one is amenable to and dependent upon being able to commercially participate with the online, with the gambling. Let's put it down: this is about the gambling industry. If that disappears, then the whole commercial viability is effectively gone and what you are into then is illegal localised sport.

Yes.

Yes. Okay. That's fine. Thank you.

Diolch. Llyr.

Diolch. Animal Licensing Wales, of course, are at the heart of much of the enforcement work that happens in this space, and they told us that they'd like to see fixed penalties in the Bill, rather than unlimited fines. They say that fixed penalties have been successful in other legislation as a proportionate enforcement mechanism. They say that that wouldn't overburden courts, and subsequently would result in better welfare outcomes. So, I'm just wondering what you think about their view.

Jackie.

Yes, the fixed penalty system that Zoe was talking about in the evidence that she gave is in relation to how they operate animal welfare breaches in England, and the local authorities there have adopted the fixed penalty system. That's not something that has been brought forward to us to implement directly in Wales. We have been working with Animal Licensing Wales—since their inception, actually—and we've been financially supporting them, as I'm sure you know. They've been doing great work in upskilling, training and making sure that all the local authorities are working off the same set of rules and guidance so that it's proportionate across the stream. It's not something that we would rule out. Anything that helps with enforcement and making sure that people are compliant would be a good thing, but it would be down to being approached officially via the Senedd to take that forward.

But you have chosen unlimited fines as your approach. 

Yes.

Which isn't what Animal Licensing Wales would prefer.

No, indeed. We'd be interested in the views of the committee, but we think that's proportionate to the seriousness of operating illegally after this prohibition, if this prohibition on greyhound racing passes.

There have been calls for robust guidance if the unlimited fine approach is adopted. Is that something that you fully intend to bring forward if that was the outcome?

Yes, indeed, and there's a role for the magistrates within that as well.

To issue the fine. It's unlimited deliberately in the legislation, Liz, isn't it?

Yes.

So that the magistrate can determine what level of fine they impose.

Yes, and clearly they would need guidance on that, wouldn't they?

Yes, in line with sentencing guidelines.

Yes, okay. Diolch.

Have you had any engagement with the Sentencing Council on this? Because that obviously isn't a devolved matter.

Have we done that yet?

No, we haven't had any engagement with them.

But we will need to, Mick, subject to the legislation being passed.

The final questions are with Mick as well.

It's really just to do with the enforcement, and obviously local government is very important. We noted that in some of the submissions—. I think Caerphilly council also wondered why there might not be a power to seize, take into custody suffering dogs and so on. So, I'm just wondering what your thoughts are on that.

But also, the burden of this is going to fall on local authorities, and I'm just wondering what your engagement has been, what have been the challenges there, what issues have been specifically raised, and how you see that working.

And of course, the key issue for local authorities is going to be the engagement between, I suppose, the obtaining of intelligence and information, et cetera, engagement with police and so on, but also resources. I'm just wondering what your thoughts are on the resource implications for this.

The first thing to touch on is that, subject to this legislation passing, we're going to be in a transition period and we need to make sure that the animal welfare officers with the local authority, the animal licensing regime, in concert with the licencing the GBGB put in place, is fully complied with, and that if there are any—in this transition period, subject to the legislation passing—infringements, they are properly dealt with and resourced. Caerphilly County Borough Council officers have been fully engaged in Valley stadium over recent times, but going back some time as well, and continue to be so.

If we proceed with this prohibition, then clearly, we've considered the resource implications. Bearing in mind what we've discussed only a few moments ago about the defining characteristics of greyhound racing in a stadium, or something that looks like a track, and so on and so forth, it would be pretty identifiable. So, the major implications there are for policing, animal welfare enforcement, and so on.

We have increased the funding of our Animal Licensing Wales team in recent times, and we'll continue, subject to the next Government as well, of course, but continue to fund that in place. But we are not anticipating, I have to say this, if this legislation passes—beyond the transition period for Valley stadium, whatever that may be—stadiums or tracks to suddenly pop up over the place that we will need to pursue in their scores or dozens around Wales. We anticipate this will be the end of greyhound racing on tracks within Wales, in which case the resource implications, short of an eventuality such as an illicit track suddenly popping up somewhere, are going to be minimal. Jackie.

We have engaged directly with the local authority in Caerphilly, as well as the Welsh Local Government Association, through the implementation group and prior to the implementation group being set up. This engagement has been facilitated through that local government partnership scheme, which has enabled us to enter into that dialogue. The impact assessment that has been published, as well, does take into account the information we've had from the WLGA and local authorities in relation to the enforcement of this Bill.

Thank you. That concludes my questions. 

Diolch. I think that concludes our questions. I don't see any further questions from Members.

Diolch, Cadeirydd.