Joint submission in response to the consultation on plans to develop a new zoo at the Cuningar Loop, Glasgow On behalf of the undersigned charities and our tens of thousands of supporters, we would like to formally register our opposition to the proposals to establish a new zoo complex in South Lanarkshire. Grounds of opposition Our fundamental opposition to the proposals lies in concern for animal welfare, negligible conservation impact of zoos, poor legal compliance with standards and the wider ethical concerns regarding holding animals captive in tourist attractions. Our shared stance on this matter is based upon decades of research, investigation and expertise and can be summarised as follows: Animal welfare We maintain that zoos cannot meet animals’ natural physical, social, behavioural and emotional needs and thus the welfare of zoo animals is severely compromised. Peer- reviewed research published in the last year has shown that less than one quarter of British zoos were assessed by Government-appointed zoo inspectors as meeting all the required standards for animal welfare 1. On a very basic level, zoos cannot provide the amount of space animals have in the wild. This is particularly the case for those species who roam larger distances in their natural habitat. We understand from your consultation event that, among other species, it is proposed to keep lions, gorillas, Nile crocodiles, hyenas, penguins and seals at the Glasgow zoo. We need hardly state that in an urban zoo it is impossible to provide the complex terrestrial or marine environments and the amount of territory necessary to individuals in these species if they are to enjoy a reasonable standard of psychological welfare. Lions, for example, are known to face problems of obesity and inactivity in zoos, and have been recorded as spending 48% of their time pacing – a recognised sign of behavioural problems. Hyenas are largely nocturnal and therefore unlikely to benefit from being kept in a busy daytime attraction. Seals are also known to suffer boredom in captivity, being deprived of the external stimuli of the haul-out site, the requirement to find prey, varied social companions, and weather and sea conditions. We therefore suggest that the proposed species are particularly unsuitable for life in captivity and that it would be misguided to consider keeping them at the attraction. Education and Conservation We maintain that zoos deliver a misleading and potentially damaging message by implying (both implicitly and explicitly) that captivity is beneficial to the cause of species conservation and that visitors are able to witness “wildlife” first-hand in the zoo environment. This message directly contradicts that of many leading experts in 1 Draper, C.; Harris, S. The Assessment of Animal Welfare in British Zoos by Government-Appointed Inspectors. Animals 2012 , 2, 507-528. the field of conservation and the overwhelming body of evidence that demonstrates that species can be conserved only as part of their entire ecosystem; that is, habitat conservation is the only way in which effective conservation can be realised. In addition, by virtue of their captive state, zoo animals do not behave as their wild counterparts thus seeing an animal in a zoo does not educate as to that species’ life in the wild. As a result, the zoo animal represents a distorted view of its own species. Poor legal compliance with standards A 2011 study 2, whose findings were formally welcomed by Government in 2012, found that there were widespread concerns surrounding compliance with the provisions of zoo legislation within the UK. Problems included missed inspections and 75% of inspection reports used in the study identifying recurring unsatisfactory issues. Furthermore, it was found that 95% of zoos should have had legal enforcement action taken against them at some time between 2005 and 2011 as a result of their failure to meet basic legal standards. Animal/human contact We note that animal handling and performance sessions may take place. This is inadvisable as touching, stroking, holding, riding on or swimming with even a captive- bred wild animal is unnatural and can cause distress, and can place both the animal and the human at risk of injury and disease. Ethics We maintain that holding any animal captive for commercial purposes is unethical and cannot be justified. Furthermore, we believe that the keeping of animals in zoos sends a damaging message to the general public, and particularly children and young people, by the implication that animals can be maintained in captivity to satisfy our own curiosity, despite the animal gaining no benefit from the practice. The practice implies that the animals’ own lives hold no inherent value in their own right; the keeping of animals in zoos therefore has negligible or even negative educational impact. Despite our fundamental opposition to the proposals on the grounds stated above, we are aware that consideration of animal welfare or ethics fall outside of the jurisdiction of local authority planning committees and so may not be deemed to be directly relevant when the time comes to consider a formal application. Furthermore, the artist’s interpretation featured on the Wildside website is the only plan of the zoo that has been made available in the public domain and, as such, it is impossible to make any assessment of potential animal welfare provision in anything other than very generalised terms at this stage. We assume also that it is not intended to replicate this artist’s impression exactly, as this would be extremely difficult in real life. 2 CAPS. A Licence to Suffer: A critical analysis of regulatory protection of animals in zoos in England, 2011 Economic viability Notwithstanding the above, we understand that a major focus of any planning process is to approve measures which support the principle of sustainable economic development. South Lanarkshire Council recognises that: “At the national level the Scottish Government has identified the need to make Scotland a more successful country by pursuing sustainable economic growth 3”. The stated vision for South Lanarkshire Council’s Local Development Plan is: “To promote the continued growth and regeneration of South Lanarkshire by seeking sustainable economic and social development within a low carbon economy and an improved urban and rural environment"4. It is argued in the case of the proposal in question is that plans for a new zoo are not economically viable in the long-term. This is of concern to us on the basis that there is likely to be a direct link between the financial viability of a zoo business and the ability for that zoo to provide for the welfare of the animals held by it. Many zoos rely on visitor income in order to care for the animals and thus if the business fails, the welfare of the animals is put in jeopardy. Our position on this matter is outlined below. The location chosen for a new zoo at the Cuningar Loop places the proposed development just 7 miles from the site where Glasgow Zoo operated until 2003. It seems reasonable, therefore, that Glasgow Zoo and its operation be used as a valid comparison against which the potential success of the new plans can be gauged. Glasgow Zoo closed after running up reported debts of around £3.5 million which, in turn, resulted in the zoo failing to meet the standards required under zoo licensing regulations; impacting upon animal welfare and ultimately resulting in the zoo’s closure. The financial problems came as a result of a year-on-year decrease in visitor numbers and the associated decrease in income. Competition with Edinburgh Zoo was deemed to be one of the factors affecting Glasgow Zoo’s visitor numbers. Given that, in 2003, Edinburgh Zoo had not introduced its high profile panda exhibit, which has seen its visitor footfall increase by around 50% to 810,937 visitors in the last twelve months, then it stands to reason that the Cuningar Loop project will be under much more pressure than its predecessor in terms of competition with its Edinburgh- based rival. Prior to the arrival of the pandas, the finances of Edinburgh zoo had also been in decline for a number of years; leading to concerns being raised over the zoo’s ability to meet the needs of the animals and thus avoid the same fate suffered by Glasgow Zoo previously. We firmly believe that this decline is indicative of the lack of demand for a zoo attraction in the local area. 3 South Lanarkshire Main Issues Report, May 2012, p. 9 4 South Lanarkshire Main Issues Report, May 2012, p. 14 It is clear that the pandas have bought Edinburgh Zoo some respite but evidence has shown that other zoos which have been involved in panda loans have seen an initial spike in visitor numbers which is, ultimately, unsustainable. We believe that the special circumstances which currently apply to Edinburgh Zoo should not be taken as an indication of an increased interest in zoo attractions more generally. All evidence suggests that in the short term, as visitors continue to flock to Edinburgh Zoo to see the pandas, the zoo at Cuningar Loop will be overlooked. In subsequent years, as the draw of the pandas wears off, it is reasonable to assume that visitor numbers will drop back to the “pre-panda” levels. That is, levels which could barely sustain one zoo in the area and had, for over ten years, been too low to support two. As the economic viability of proposals falls clearly within the decision-making remit of the planning authority, we encourage the company to reconsider the zoo proposals at this point, prior to submitting any formal application for permission. If the application is submitted, it will be formally opposed and the request made in the strongest possible terms that the application be denied.