DEFRA claim they wrote their regulations to improve animal welfare, but they achieved the exact opposite of those objectives.
"There are five less catteries and kennels in our area than there were in 2019 and not one of the remaining establishments is in any position to expand, manage or accommodate the overflow - so the only people able to provide alternatives are more expensive, less reliable, unlicensed, untrained and uninsured start ups with no overheads and no comeback if something goes wrong.
DEFRA wrote rules and regulations that aren't fit for purpose and can't be applied with any consistency - and while they now refer to our representatives as "stakeholders" they hold regular meetings in order to pretend to be fixing their mistakes - but they refuse to do anything that would be an admission of their own incompetences and refuse to get involved in individual cases or with educating individual councils.
While in some parts of the country there are catteries waiting for licenses and multiple reports of catteries being closed or down-rated by the utterly destructive acts of unfettered stupidity by licensing officers.
Putting lazy and incompetent licensing officers in charge of deciding when or how individual catteries function is no longer tenable.
The same licensing officers who are constructively forcing people out of business are also allowing current licenses to run out on existing businesses because they don't appear to have a clue how important it is to have valid insurance - and there are other businesses who are ready to open and these foot-dragging incompetent licensing officers don't think giving new businesses their license is important either!
Our businesses rely on not making any minor or consequential errors and providing the perfect service for every customer - and DEFRA wrote the wrong regulations for the wrong bureaucrats to enforce with the authority to downgrade our rating for not filling in a form properly - when these same over-zealous illiterate morons don't have the capacity to organise an inspection or get any of the basics right and still face no consequences!”
--Cat Whisperer
DEFRA has no legitimate claim to govern this sector and in three years have given our industry's representatives the ludicrous New Labour title of "stakeholders" while they pretend to be conducting a "review" into the consequences rather than their own incompetence - their mistakes decimated a decades old UK industry and their only aim appears to be to keep as many regulations in place as possible by refusing to acknowledge that the entire document and every syllable has had widespread negative consequences.
Local authorities do not have the resources to track down the burgeoning mass of rogue and unlicensed operators that were created by DEFRA's inept decisions and subsequent inaction.
Instead of fixing their mistakes DEFRA have been fixated on preventing themselves from being held to account, they tinker around the edges grudgingly forced to fix one line at a time - and nothing changes because all of the licensing officers are too busy avoiding responsibility for misinterpreting the last lot and the decimation of our industry continues.
While everyone pretends that nothing they did was their fault, in the real world our customers do not care if our sector is inspected or rated. No one has ever asked if we were licensed. No one cares about government ratings and no one can make any sense of the regulations or how the ratings were determined.
The good or bad reputation of any kennels and catteries is decided by our customers - They don't neeed or want advice from any remote and bureaucratic source on where to place their favourite family member - we hold at least 50 public viewings a year and all our customers care about is will their cat be happy here while they're away.
Fixing their mess:
01 We need a distinct classification separate from Tourism and Charities and we need to release DEFRA from the responsibility of being involved in writing regulations or retaining any damaging influence over this sector.
02 We need our regulations to be restricted to a three page document of single achievable, policable and universal regulations with an educational advisory on health and hygiene for new businesses.
03 The CFSG must be reformed or abandoned because the current make-up of the CFSG has proved itself to be uninformed, unbalanced and unfit to advise on animal welfare to any governement department.
04 Inspections must benefit the industry - We need to dispense with all adversarial, aggressive and threatening inspections with non-confrontational and educational help.
05 Inspections should only be carried out by specialists in the field of animal welfare and only by people who have years of realvent experience in this industry.
06 A rating system that isn’t transparent, self-explanatory and doesn’t consider experience is not fit for purpose and must be scrapped.
07 The involvement of local authorities must be restricted to listing whether a boarding establishment is licensed.
What concerns me is that while it would be a perfectly legitimate response to name and shame all those involved, our industry representatives are already forced to pussy-foot around these clowns to get them to do anything.
Not because they don't have sufficient data to identify their mistakes but because the only thing these bureaucrats care about is not facing the consequences of the chaos they've caused by their ruinous adventures into business and other people's lives.
08 It's too late to reverse the damage done to our industry by this beauracratic incompetence.
09 The impact of losing so many dedicated and professional people over such a short space of time can't be reversed.
10 The closure of a third of the UK's boarding capacity hasn't even filtered through to the general public currently planning their holidays.
11 DEFRA has no incentive to accept responsibility and have offered no moritorium on licensing or a retraction of the regulations.
12 DEFRA have created financially disadvantagous rules for licensed establishments to raise animal welfare but in doing so caused a catastrophic rise in unlicensed alternatives who are less reliable, less safe and beyond all government control.
13 The lack of any reasonable or speedy action by anyone has increased the opportunity for thousands of untrained, unlicensed and uninsured people to operate unhindered by exhorbitant overheads, training or rules.
14 Without any of the responsibilities or costs the competition can put out unchallenged negative advertising demonising kennels and catteries as prisons accross all social media, and all we hear from those responsible for overseeing these illegal operations is crickets.-- Cat Whisperer
How DEFRA and local authorities failed our industry
Reflecting on what has occurred over the last few years - what was imposed, what was demanded and what was ignored should deter anyone from thinking that owning your own business means that you make your own decisions, or that being your own boss is going to protect you from being unemployed. At its most reductive, very quickly, you're going to discover that while you paid for the business, pay taxes and think you're the owner, as far as the bureaucrats are concerned you're only the licensee. DEFRA decided to govern your personal life, your access to downtime and every aspect of your business and yet no one in this industry had a say in any of the new regulations - Everything from the size of a pen to the position of a scratching post to cataloguing the colour and consistency of every turd or hairball produced by every cat must be recorded and stored to be checked and enforced by a local authority licensing officer.
It's 2022 and for the past three years people working in our industry:
- 01 have been fighting to be recognised as an essential and distinct industry requiring full representation on the Canine & Feline Sector Group's (CFSG) advisory board to reverse the damage done by the CFSG to our industry.
- 02 have been trying to survive during the pandemic after a clerical error caused many local authorities to bankrupt local businesses by denying eligibility for travel restriction Covid payments during the UK's lockdown.
- 03 have been subjected to abuses of power perpetrated by local authority licensing officers using DEFRA's legislation to justify their mistakes and the widespread incidents of bullying and thuggery.
It's difficult to generalise when there are actually some half-decent well-meaning licensing officers who understand that their only role should be to provide a license - and the purpose of an inspection should be to identify areas than could improve animal welfare - but it's an unavoidable fact that DEFRA wrote regulations has allowed all council employees to act as adversarial power-crazed thugs despite having no practical skills or relevant experience of running a business or our industry - and this is particularly problematic because the only qualification they need to wield unfettered power is a generic and entirely inadequate course that wouldn't qualify them to clean a litter tray without supervision.
In an ideal world all political entities would be aware that their purpose is to identify and fix failing systems and improve the function of beneficial systems - But here we are in an anarchic and dystopian world where the least amongst us have thrown out collectivism and enshrined inequality by assuming to rule us - The people who are already a wasteful and unjustifiable drain on a country's finances and the most unproductive members of society - who get to choose their own working conditions and their own rates of pay and then deny everyone else the same equality of life.
The fact is that while many bigoted politicians have made a career out of miligning sectors of society for their cost to the state, bureaucrats and politicians are the real parasites and as individuals are the highest paid recipients of welfare - All of them who should be answerable to everyone, are constantly in everyone's way when all we need from them is to stay hidden, do their jobs well and improve the lives of the people they serve - and in exchange our taxes will keep them from having to work or get their hands dirty.
It's as important to establish that our industry wasn't consulted on their own regulations as it is to establish that individual licensing officers were willing to impose DEFRA's uncosted, damaging and inefficient regulations without question.
Both groups threaten the survival of an entire sector of private businesses without taking any responsibility for their actions and have yet to make any admission of failure or offer any contrition.
There's no other job in the world where someone is given free reign to do whatever they like and not be responsible for anything they do. But licensing officers have been allowed to run roughshod over this industry, interpreting the regulations without guidance or consequences for themselves and there are no sanctions in place or a right of appeal to stop them.
At the receiving end of this ridiculous chain of demand are businesses forced to pay taxes and VAT and then pay on top for their own inspections while the additional costs of implementing the regulations means that the public end up paying more for a worse service - Licensing officers have been abusing a sector of demonstrably responsible hard-working, useful and productive members of society who give no consent but are given no choice but to comply.
Over the past three years there have been numerous examples of licensing officers using our annual inspections as an excuse to bully, make suggestive or sexual advances, close down catteries, reduce star ratings, demand remodelling - in short, threatening industry members with financial ruin in exchange for a star-rating that is not supported by this industry and is not able to inform anyone's decision to use a cattery.
As a result of this perfect storm of intransigence, ignorance and bureaucratic misfeasance:
"In the last three years the UK has lost around a third of it's boarding capacity - our plight was discussed in parliament and as more people are driven out of this industry - the majority cite DEFRA's regulations and council inspections as the last straw and the refusal of many local authorities to properly support animal boarding establishments during Covid comes in a close second"
--Cat Whisperer 2022
For the first time in decades DEFRA updated our regulations and they produced a useless document because they failed to consult anyone representing the industry.
DEFRA's expertise is in land management, with a mandate to improve the environment and strengthen food supply chains. When they write farming regulations they take advice from the Trade & Agriculture board who at least theoretically represent farmers' interests.
No one on the steering committee and no one on the CFSG were qualified to give advice about writing laws for an industry that they had no knowledge of. The regulations were never checked for feasibility, reviewed or examined before being imposed - But it's precisely because DEFRA received the wrong advice, had the wrong mindset and having developed their own absurd objectives ended up with legislation that is unfit for purpose - it was never even proof-read to remove references to keeping fish in a cattery.
But on the ludicrous “advice” of the CFSG, DEFRA wrote regulations governing our personal lives requiring us to agree to prisoner style home detention sentencing in exchange for two extra stars - not for the maximum of six months as outlined by human rights sentencing, but for your entire lifespan in this industry. DEFRA and the CFSG wrote legislation for us that doesn't apply to anyone else in this sector - including more draconian personal restrictions than those pertaining to any of the UK's animal charities, and enforces tighter restrictions on our industry than were written by the Royal College of Veterinary Surgeons for thier own members.
Neither the CFSG or DEFRA had any appropriate knowledge of the tourism industry or boarding establishments and yet wrote legislation to govern us - Not a single regulation recognises the differences between a commercial enterprise with permanent staff and a single person running a small community based service facility on their own.
DEFRA introduced pointless paperwork and financially damaging changes that reduced the welfare of the animals - and then unlike the aerospce industry or construction introduced new building regulations that were applied retrospectively without any costings, financial help, adequate time-frames or caveats.
Every licensed cattery is subject to DEFRA's licensing rules - but as a collective experience, every impractical unjustifiable non-universal dysfunctional regulation can be identified - but of course we can't even start the ball rolling if the people we have to deal with only want to avoid having to take responsiblity for their own decisions.
Our alliance fought to gain a direct communication with DEFRA which we now have - But prior to this DEFRA's spokeswoman agreed to face to face meetings in Parliament and then refused to meet the industry's representatives when the cameras were turned off. We even have instances of local councils requesting clarification on specific regulations that DEFRA refused to respond to - And the CEO of the CFSG tried to avoid being held to account by refusing to acknowledge any of the emails and voicemails of the most representative group of cattery & kennel owners in the industry for the best part of a year.
It's not surprising that DEFRA and the CFSG didn't want a dialogue or a partnership because the regulations already evidence that no one involved in writing any of the laws at any point had the slightest understanding of the commercial animal boarding sector.
Nine people influenced the contents of our industry's rules. Yet no one sitting on the CFSG represents or understands the purpose of our industry. A vet and a pet food manufacturer and six representing charities who have never run a hotel and barely have any contact with animals is not representative of our sector.
Not a single person on the CSFG board represents a sector that puts animal welfare before profits or self-interest.
When was the last time the PDSA saved a kitten from a tree?
When was the last time the RSPCA picked up and rehomed an abandoned litter?
When did a vet perform life-changing surgery because the owner couldn't afford the fees?
Charity organisations aren't businesses and they aren't providing a service. They can't even support the causes they were set up to help, because if the probem is ever solved, the free ride is over - and it's this reality that illustrates that there's no legitimate reason for any charity to be on an advisory board that isn't concerened with charity work - Because whether it's animals, cancer research or mencap, that's where their expertise is.
It's an abuse of public trust to masquerade as advisors when they are only lobbyists for their own sectors - The only purpose of having any influence over policy is to protect their brands, raise their profile, extend their authority and protect their tax-exempt status.
And without being cynical, the entire purpose of a charity is to avoid paying any tax while skimming off as much as possible from donations for themselves - and they aren't providing a public service because the main work of every charity is raising more money through envelope stuffing, emotional blackmail and staging high profile raids for the media to keep the money rolling in.
But the core of the problem is that the staff working for DEFRA didn't understand their own objectives and failed to improve animal welfare because the entire document is a transparently flawed attempt to justify a five star system that is so complex that it conveys nothing to our customers. The five star rating system doesn't even exist. DEFRA and the CFSG's designed a document to differentiate between two artificial standards that in many cases has no scientific basis or are entirely arbitrary and others that are absolute and supercede every other regulation or standard. But it's not just the lack of critical analysis, inadequate knowledge or the beauracratic incompetence that has lead to local authorities being given the power to drive people out of our industry. It's that no one is responsible for their own decisions because everyone involved will claim that they were "just following orders". When in fact everyone involved embraced their inexperience and mental vacuity and failed to understand the practicalities or consequences of anything that they were doing.
DEFRA have made an indisputible pigs ear out of the entire legislation, not out of malice, but because because they chose to base their regulations on the advice of an advisory board who had no pertinent knowledge or practical experience of the industry.
No one involved had any idea how catteries function or who works in them.
Everyone appears to have assumed that catteries have unlimited piles of cash to reinvest or that cattery owners are only motivated by profit or have shareholders to serve - when in reality many catteries don't reach the annual income threshold to pay taxes - And while the abysmal disregard for practicality and consequences appears in every syllable, the regulations are the undeniable evidence that DEFRA is probably the least qualified government department to write any regulations for any commercial boarding operation.
And by arming local authorities with pointless regulations, the fate and future of individual catteries were being decided by local authority employees who proved themselves to be the least qualified people to comprehend or apply any regulation with any accuracy or consistency.
Having to read, comprehend and interpret 26 pages of ill-conceived drivel would confuse most council employees, but beyond that, we have instances of council Licencing Officers just making up regulations as they went along.
But the reason they have been allowed to continue to abuse business owners is because absolute authority corrupts absolutely and they did whatever they wanted because DEFRA has failed to act to prevent it.
DEFRA put all their mistakes in writing - but they are still refusing to take responsibility for writing personally intrusive and nonsensical regulations that increased operating costs and decreased animal welfare!
DEFRA put all their mistakes in writing because there was no industry representation - so they had had no knowledge of who runs catteries or how the industry operates.
In specific terms, the majority of catteries work more hours than a junior doctor for half the current minimum wage and most are run and owned by single people and couples.
Within the context of knowing nothing about our industry, DEFRA's team of incompetents wrote regulations:
- that reduced the time we spend with the animals in our care.
- that introduced an unworkable rating system that only misinforms the public.
- that increased the stress of annual inspections because licensing officers could not apply the new rules consistently or accurately.
- that increased operating costs and workload to provide inconsequential paperwork for licensing officers.
- that caused many irreplacable people to leave the industry taking decades of hard earned knowledge and experience with them.
The Department for Environment, Food & Rural Affairs is supposed to be a professional department with serious responsibilities. But while the cabinet Minister can't take responsibility for or oversee such a wide-ranging brief - In real terms these regulations were written by a team of low-level functionaries with the skills to throw excrement at a fan and the criminal culpability of a gang of teenagers approaching a blank wall with a box of spray paints.
--Cat Whisperer
DEFRA's 26 page regulatory document for catteries is at every level an ill-conceived collection of misinformed and unworkable nonsense:
No competent department would introduce a five star system and then concoct two separate standards for every regulation to differentiate between a five star standard and a three star standard without recognising this as complete nonsense.
No competent department would create a star system to rate businesses that is so complex and arbitrary that no member of the public would ever be able to make sense of how the rating was reached or derive any meaning from it._
No competent department would try to impose a 20th century rating scheme on the public or try to replace social media or google reviews with something worse - the only relevant considerations for the public are staff competence, quality of care and personal experience - All the information that people can find on social media and DEFRA's inspections and regulations can't provide.
--Cat Whisperer
The majority of DEFRA regulations were written by people who didn't have the skills, knowledge or ability to identify their own ignorance. They failed to gather any pertinent information from our sector and failed to challenge the fanciful beliefs of an unrepresentative and ignorant advisory board.
Ultimately, faced with hundreds of complaints and closures, DEFRA still failed to see any of the obvious problems caused by applying or policing nonsensical regulations - And even after DEFRA received industry wide condemnation and reams of evidence exposing their regulations as unfit for purpose, they still refused to recognise that a full retraction of the the entire legislation was the only way to halt the damage they were causing to this industry.
And to make this clear, DEFRA put themselves in charge of regulating every aspect of this sector's private businesses on the erroneous belief that animal welfare and wanton neglect was so widespread thoughout the UK that anything and everything needed to be regulated - and the only thing DEFRA has managed to communicate in the past two years is that they represent a group of useless bureaucrats who are entirely out of touch with reality, unaccountable to the public, and they operate without any consequences for doing a shit job, no incentives for doing a good job and no one takes any responsibility for their own decisions.
It's absolutely incredible that the Minister wasn't held to account - and even more incredible that this entire department wasn't fired and a moritorium halting all inspections and granting 5-stars to every establishment until all of the problems were resolved.
The same poor judgement that engineered the closure of boarding establishments and left communities with no safe or licensed alternatives has continued to screw up despite knowing that they caused the rise in unlicensed alternatives which was in itself lowering the standards of animal welfare - and the only action we've seen is pointless tinkering and minor addendums and changes that licensing officers are still ignoring.
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DEFRA needs to accept that they decided to introduce a 'rating system' that conveys nothing of worth, was not costed or funded and is too complicated for council workers to read or understand.
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DEFRA needs to understand that they tried to regulate an entire industry that is so varied that the opportunity to impose universal 'standards' is almost nil.
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But DEFRA have effectively turned all boarding establishments into prisons for animals and permanent lockdown for owners while reducing the time required to ensure the welfare of the animals - All of which manifested as 26 pages of incompetent drivel that has created more problems than were solved.