Horse SA Letter to Minister Tony Bourke MP re Horse Disease Response Levy Bill 08

The Hon Tony Burke MP Minister for Agriculture, Fisheries and Forestry PO Box 6022 Parliament House CANBERRA ACT 2600 Friday March 7th, 2008

Dear Minister, Re: Horse Disease Response Levy Bill 2008 Horse Disease Response Levy Collection Bill 2008 Horse Disease Response Levy (Consequential Amendments) Bill 2008 Horse SA is a not-for-profit industry advocacy body based in South Australia. The organisation, has a focus on key issues of horse health & welfare, horse keeping & the environment, trails & public land, road safety, community, industry and workforce development. Our organisation is writing to you, to respectfully provide some information in order that the Minister does not become embarrassed and have your first bill in the new parliament fail in the ‘dash for cash’. Normally, in our day to day role, Horse SA interfaces between the government and horse organisations and owners on a range of regulatory & voluntary compliance issues. However, we find we are unable to undertake our normal services to facilitate the introduction of the new bill (Horse Disease Response Levy Bill 2008), as we have not been engaged in any part of the process of its development, we only became aware of it’s introduction through a general media broadcast. Therefore, our action has been to empower horse organisations and owners on how to provide direct feedback through MP’s and Senators and to engage their respective State & National horse organisations. This has been a lost opportunity for the Minister. Horse SA cannot support any Bill that has not demonstrated transparency in it’s development, or due process, including a sound consultation process, independent evaluation for equity and capacity to collect or pay the tax, and an effective, accountable communication strategy. In addition, Horse SA cannot provide a “collective view” as we do not have adequate information, or opportunity, to undertake normal consultative processes with our members. Horse SA has a corporate (not a general membership) understanding of the Emergency Animal Disease Cost Sharing Agreement (EADRA) and why it is needed. EADRA participation is supported. EADRA, however this has not been signed. Does the proposed Levy Bill put the “cart before the horse?” It is noted in Parliamentary papers that by having the Levy Bill passed, that this will give the Australian Horse Industry Council (AHIC) confidence to sign up to EADRA. No mention has been made of the annual membership fee to Animal Health Australia – is this part of the mix? The level of understanding around EADRA by various horse organisations, of which there are over 90 national and many more state-based groups, depends very much on the capacity or interest level of relevant groups to engage in general industry issues outside of their core business. Broad understanding of the issues surrounding the Bill, achieved through consistent communication, clear messages and identified benefits, are not widely understood. Horse SA encourages organisations that do understand EADRA, and the resulting agreement for government to recover costs spent responding to any type of emergency disease, to remember their voting power at each election. While underlying principles may be sound, (and be applicable to other animal industries) there is considerable scope to debate, review, argue, negotiate and otherwise participate in a pro-active manner to ensure that the best result is achieved. There are several areas that concern us:

1. Due government process (this appears to be seriously lacking)

2. Equity. Most horses are not registered with any group. The minority will be paying for the majority. Cost recovery is not being borne equally across the (horse owning) community.

3. Capacity. What sort of risk assessment was undertaken to evaluate the skills, ability, (mainly volunteer) personnel, technology (some still do not have computers) to collect the tax? Is the government going to pay for extra staff, volunteer training or computers to meet compliance?

4. Lack of an “All of Government” approach. This seems against the government’s own policy. If so much time and effort is going into collecting a tax, yet no capitol gain is made from knowing where all the horses are, and which horse is which, then no learnings have been forthcoming from the Equine Influenza response.

Much of the EI response cost would have been on actually “looking” for those horses not registered with any organisation, from hiring helicopters to staff door knocking. Failure to address equity through choosing the “easy option” of picking horse registration bodies as taxation collection points adds the cost of looking for horses again to any future responses.

More cost (and future prolonged levy repayment period) for horse owners could be averted by a cross-portfolio approach. Environment & Water, Regional Planning & Infrastructure, Workforce Development & horse industry SME’s are just a few areas that could all be addressed through some forethought in information and/or tax collection. By not adequately considering these factors, the horse industry is still on the back foot and unable to effectively negotiate or be a competitive industry sector like the other animal groups.

1. A social justice policy statement based on capacity to pay needs to be provided.

2. “Future proofing” the Bill is also not evident. Australia is an active participant in the international horse meat marketplace. As abattoirs upgrade to meet EU or International standards, the point of origin for each horse will need to be validated as part of Australia’s commitment to improved food supply chains. Has the Minister adequately considered this aspect, especially as it is situated within your portfolio area. Revisited, the Minister has an opportunity to ensure that loved horses do not end up in the human food chain, as in the UK. There will be other considerations not mentioned.

3. The definition of Horse needs to include donkey, mule and zebra

4. The definition of a national horse body needs to be clarified further or a new definition devised. Some horses are registered through a state branch and the “national body” oversees rules & regulations, but does not technically register horses. This narrows the taxation collection base further. It should also be noted that further narrowing can be found through state based organisations, which register horses, but do not have a national body. These two scenarios considerably increase the taxation burden on the few individuals who are left to pay.

In closing STOP. Put the building blocks in place first. Horse SA understands to be in the game (that is, recognised by government) that you have to be a player, but not when the rulebook is taken from another sport, another era, another social economy and only a precious few are invited to play - with most being dis-engaged spectators, or worse still, in the “outer” as a millstone around the community’s (horse industry’s) neck through not registering horses. Horse SA looks forward to a reply from the Minister’s office in relation to our concerns.

Yours truly,

Julie Fiedler Executive Officer

Hi Horse Deals, thought your readers may find this letter interesting, I found it on the Horse SA website www.horsesa.asn.au they have some great info re this bill.