PART I: The Greyhound Industry and Issues Affecting its Regulation

Chapter 1

Background Profile of Greyhound Racing in Britain

Introduction

Greyhound racing was launched on a commercial basis in the UK by the Greyhound Racing Association on 24th July 1926 at Belle Vue, Manchester. The sport enjoyed immediate popularity and grew rapidly, to the extent that, in December 1927, some 28 racecourse promoters met (at Wembley Stadium) to consider the establishment of a national control organisation. It was agreed to establish a Greyhound Club "somewhat along the lines of the Jockey Club" and National Greyhound Racing Club was thus formed in January 1928 with the first set of Rules of Racing published in April of the same year.

Greyhound racing went on to enjoy its heyday in the immediate pre and post Second World War years. It has suffered steady decline in recent decades and is now, perhaps unfairly, not always seen as a major national sport. Outside of the specialist and trade channels, the media coverage of greyhound racing is surprisingly limited. In some ways it exhibits the engaging features of a cottage industry, conducted by and for enthusiasts and bookmakers - though the pleasures it can give deserve to go much wider than that. Historically, it has enjoyed a 'colourful' image, with rumours of 'dodgy' practices, which is part of its attraction to many of us.

The statistics of the sport's decline are not always easy to obtain and verify (ours were provided by track Promoters, the British Greyhound Racing Board and the National Greyhound Racing Club). The number of licensed greyhound racecourses has fallen significantly, more than halving from 64 in 1960, though recently steadying to the present 30, with the recent reopening of Hull. The number of independent tracks has slumped even more sharply, down from 87 in 1960 to some 14 now - and more than halving in the past 10 years. Those figures may soon be affected still further by current welfare legislation, with its imposition of the costs of rising welfare standards. Some independent tracks may be forced out of business; other independents may upgrade and cross the line to join the licensed ranks.

Licensed meetings have not declined so radically, down from 6,787 in 1960 to 5,999 in 2006, the expansion in BAGS racing to some 21,000 fixtures in 2007, rising to over 26,000 in 2008, or nearly one third of all racing, explains this resilience. Some tracks race up to half a dozen times a week throughout the year and greyhound racing is on offer somewhere in the UK from morn till night. This proliferation of racing taxes the resources of nearly 500 full-time professional trainers (there are twice as many more registered who are not full-time) for whom the formal financial rewards are not impressive and allegedly declining in real terms.

Attendances

NGRC course attendances have thinned relentlessly for decades and presently average only about 600 spectators per licensed fixture (compared to over 2000 in 1960), with often barely a hundred people watching daytime meetings organised under BAGS, and the independent tracks average below 200 per meeting. Top attendance in 2007 so far has been 5000 at the Wimbledon Derby. In the post-war glory days crowds of 20,000 were common. Total attendances in 2006 were 3.2 million, down from 3.9 million in 2001 and from over 15 million in 1960. But 3 million is not an insignificant attendance figure. Greyhound racing still can claim to be one of the larger spectator sports in the UK. (League Football is a clear number one with over 13 million attending Premier League matches alone in 2006/07 and horse racing is second with 5.86 million in 2006, while greyhound racing is third). This 2007 season hopes to show the first attendance increase this decade (suggested by the Board as rising to 3.4 million).

We have received evidence which suggests a link between attendance and the quality of facilities. Some British greyhound stadia are disappointingly shabby - especially in comparison to the best in Ireland. But those tracks such as Yarmouth and Peterborough, which have recently invested in new grandstand and restaurant facilities are showing positive returns. Yarmouth enjoyed a 52% increase in attendances over the first few months of this year. The sport's decline might surely be halted and even reversed by modern management, increased investment and marketing skills.

The Betting Industry

Television coverage, both on domestic TV and especially to bookmakers' shops, has developed and has increased further since the advent of evening opening for bookmakers in September 2007. Therefore the public following of greyhound racing, while showing greatly reduced physical presence of spectators at tracks, has moved and widened from the stadia to the screens. In many ways greyhound racing has become more of an off-course betting medium and less of a spectator sport.

Bookmakers are major players in the British greyhound industry, both as owners of 6 tracks and as customers for the race betting product. The revenue of on-course and primarily off-course bookmakers is difficult to calculate because the reporting of specific product-related off-course betting figures is not required either by statute or other commercial arrangement. This difficulty of measurement has been accentuated by the 2001 switch from basing general betting duty on turnover to a gross profits mechanism. However, the best figures available suggest that off-course betting turnover has risen strongly, from some £1.3 billion in 2000 to an estimated £2.5 billion in this year 2007. Half of the tracks generate over 90% of the betting turnover, while 13 smaller tracks provide only 3%.

Bookmakers make a significant financial contribution to the sport. Some, including the major ones, make a voluntary contribution of 0.6% of their relevant turnover to the industry's British Greyhound Racing Fund (BGRF). This contribution rose dramatically from £3.8 million in 2000 to around £11.5 million in 2006. It provides the funds for the annual BGRF budget and has primarily financed the greatly increased central expenditure on greyhound welfare in recent years, led since 2004 by the British Greyhound Racing Board chairman Lord Lipsey. In addition, the bookmakers now pay £18 million directly to 18 racecourses for the television transmission of BAGS races to their shops [1]. Without their contributions, British greyhound racing would be in a dire financial plight.

It should also be noted that the bookmakers have a strong commercial interest in ensuring that greyhound racing must, for betting reasons, maintain good standards of racing integrity and, for their own image reasons, should have high welfare standards. They can exercise a positive influence in both respects at the 6 tracks which they own and through the valuable BAGS contracts which they offer to other private promoters. The bookmakers contribute the largest sums directed to welfare and they stated to this Review their willingness to support greater expenditure on welfare providing the financial channels handling the money are transparent and accountable.

Registrations

One striking industry statistic is the number of greyhounds registered for racing. Over 10,000 new greyhounds were registered to race at licensed British tracks in 2006, having been up to nearly 12,000 in 2004. Up to 4000 dogs race at independent tracks, according to the recent report of the Associate Parliamentary Group on Animal Welfare (APGAW). During one week in August 2006 there were 8,664 greyhounds running in 1,444 races (one third of them under BAGS). To some extent this large number may reflect an enthusiastic interest in owning and training greyhounds - which would be quite remarkable to anyone from horse racing when seeing the low level of British greyhound racing prize money. Total prize money has actually risen by over 60% this decade. But it is spread over many more races and the average prize money per race is still only £220, with the top prize at an average track around £100, which does not give owners and trainers much return. For many, their satisfaction is derived from the sport. The pleasure exhibited by participating dogs, owners and trainers in the racing is one of the many delights derived from attending greyhound racing.

However, the main reason for the high numbers of dogs participating in greyhound racing is more likely to be the high bookmaker demand for betting product. This is coupled with the over-supply of young dogs, especially from Ireland, the source of some three quarters of all hounds racing in Britain, with some 8000 dogs imported annually during recent years. Ireland breeds over 20,000 greyhounds per year, as many as are bred in the whole of the United States.

Actually, the statistics suggest that personal ownership of racing greyhounds in Britain is becoming less attractive, especially for routine BAGS racing. With BAGS, the track trainers increasingly take on ownership themselves in order to maintain their necessary number of greyhounds available for racing at their contracted tracks. It was stated to us by the Federation of British Greyhound Owners that as many as 70% of racing dogs are now trainer-owned, compared to only 20% a decade ago. Even at more popular evening meetings the figure of those greyhounds which are trainer-owned has apparently risen to a third. There are currently around 12,000 registered owners, but the number of 'hobby' owners is in decline, allegedly influenced by the trend for costs - such as vets fees inflating 12% per annum - to rise more rapidly than prize money.

The high number of greyhounds being bred and raced to meet bookmakers' demands for betting product can create worrying welfare problems. The high volume of racing may mean that there is insufficient time between meetings and races to prepare and repair track surfaces or to diagnose injuries to hounds. Above all it has raised questions about how the dogs are treated or disposed once their racing careers end (often when as young as 3 or 4 and including those retired because of track injury). The 'wastage' rate is high. It is estimated that over 10,000 greyhounds leave British licensed racing each year, together with others from independent tracks. In addition are the dogs which from the beginning prove unsuited to racing. Together this constitutes a massive exodus of greyhounds, often with up to 10 years of their prospective lives remaining. Not all can be tended by their racing owners, trainer-owners or can currently be re-homed. It has been suggested to us (though numerical proof is lacking) that the trainer-owned dogs form a disproportionate part of those needing but often lacking re-homing. A significant number - so far not reliably quantified - are put down, not always humanely. Given the numbers of greyhounds retiring from racing each year, it seems unlikely that all can be re-homed and therefore some euthanasia may be inevitable, as is accepted in the NGRC Rule 18 as a last resort. But it is important that this be done professionally and humanely.

Very recently there seems to have been some decline in greyhound registrations. Imports from Ireland have fallen this past year as British prize money proves a diminishing relative attraction. This is encouraging from the welfare aspect. Certainly, greyhound racing has to come fully to grips with the welfare issues relating to the high numbers of dogs being bred and disposed. Basically the industry must examine further how to provide lifetime care for more of the thousands of dogs which retire from racing each year and should seek to reduce the total numbers coming into the sport, possibly by regulating breeding and by prolonging the careers of the current racing population. This issue is further discussed in Chapter 13 below.

Greyhound Welfare

Although the welfare dimension relating to the use and disposal of thousands of greyhounds each year has been an issue for some time, it has recently attracted significant negative publicity and is therefore of great concern to whoever governs and regulates the sport in future. The standards whereby dogs are used and disposed are the focus of increasing public, political, professional, media and charity scrutiny, as illustrated by the recent APGAW report.

At root in the growing welfare debate is a fundamental difference of approach to animals in our society. On one side are those, such as the welfare lobby, but going far beyond them among the wider public, who view the greyhounds and many other animals as sentient beings (like humans but clearly nicer) to be treated humanely and where possible sustained throughout happy and healthy lives. On another side (though there is much grey area in between), are those, often earlier related to rural life and agriculture, who will treat their animals well but view them primarily as commodities for commercial exploitation and to be disposed of economically and humanely once their commercial use is over. (Greyhounds, unlike many farm cattle, have little post-disposal food or product value). The former welfare group view racing greyhounds basically as pets who run for a short period of their lives and who should be cared for properly afterwards. The latter group sees the dogs as a sporting commodity whose commercial use is concluded once their racing days are over - although this does not mean that many will not keep and treat their dogs with good care afterwards. These two views are sometimes hard to reconcile in the industry. But the welfare view is increasingly influential in Britain, with the public, the media, Parliament and the government. In fact, to this Review many of the sport's commercial stakeholders expressed sympathy to the welfare view and a willingness to spend more money on welfare. In Ireland, traditionally a more rural society, the welfare lobby is less vociferous and less influential, but there is evidence that welfare concerns are increasing as Ireland grows more prosperous and more urban middle class.

The scandals recently exposed at Seaham and Hinckley - and allegations of mass killings in Wales - revealed ethically unacceptable (though not always illegal) methods of greyhound disposal (though the Greyhound Trainers Association claimed to us that this reflects past history and not present experience). Recent Animal Welfare legislation touches centrally upon such welfare standards and practices, with its crucial 'duty of care' obligations. This enabling Act and the secondary legislation which will follow in 2009 means that regulation of greyhound welfare will tighten anyway, regardless of the actions of the industry. Even should the sport remain self-regulated, as is discussed below (see Chapter 8), it will be so within an enhanced regulatory framework.

From greyhound racing's point of view, the main thrust of the 2006 Animal Welfare Act, to be implemented by 2009, is the 'duty of care' which makes the person in charge of an animal (eg a greyhound) responsible for it in relation to the specified 'needs': suitable environment, diet and housing; ability to express normal behaviour; and protection from pain, suffering, injury or disease. With greyhounds, the breeder, owner, trainer, track or veterinarian who is in charge of the dog at a particular relevant time would be the person deemed responsible for its care in the statutory respects. Supporting the Act will be secondary legislation which in turn will be supported by welfare Codes of Practice derived from the Greyhound Charter. The Codes themselves will probably not be made legally compulsory but any contravention may be taken as evidence in a court of law. The legislation is a radical move in the direction of welfare regulation which will provide a statutory framework within which the sport and its regulator will have to operate.

Many in greyhound racing, including the NGRC, the Board, some promoters and bookmakers, and especially the vets and the welfare lobby, have in their evidence to us shown that they share these welfare concerns and are anxious to respond to them. Others in the industry may not be fully aware of and sensitive to the strength of the welfare momentum. Some may perhaps be aware but are troubled by meeting the costs of rising welfare regulation. In our view the sport has no alternative other than to raise those standards and regulate accordingly. It must pay the costs of welfare regulation or suffer increasing criticism. The industry might then be initially a little smaller, at least temporarily, with fewer marginal tracks. But it would surely be healthier, economically and morally, in the longer term.

Greyhound welfare has not always in the past been handled satisfactorily by the industry and its ruling bodies. But the recent new regimes at the BGRB and the NGRC have lately made commendable progress - which is not always acknowledged by some critics in the welfare lobby. How welfare is handled in the future will be a major challenge to whoever is conducting the regulation and governance of the sport. Clearly veterinary surgeons should play a greater role in achieving enhanced welfare standards (proposals for that are discussed later in this Report (see Chapter 15). This welfare dimension is so closely related to our regulation remit that below some space is devoted to suggestions for the urgent future agenda of greyhound racing's future regulatory arm (see Chapter 9).

An Overview

Overall, the profile of the British greyhound industry which presents itself to our Review is a mixed one. Welfare concerns represent a potential commercial threat unless properly addressed. There has also been long term commercial decline, though with some recent financial stabilisation based mainly on the betting input. There would be some grounds for commercial optimism if the industry felt able to invest more in becoming a modern leisure industry. An evening meeting at a modern stadium with good competitive racing and excellent dining facilities can provide fine family entertainment and great satisfaction for spectators, owners and trainers. But part of the focus of the sport has switched from providing spectator enjoyment to providing product for punters elsewhere. A wet Monday afternoon BAGS meeting with few spectators or bookmakers is not always an exciting experience.

Those familiar with the recent modernisation of the rest of the British sporting and leisure industry are struck by how, in comparison, greyhound racing appears at times to be stuck in a different time warp. It can offer a touching reminder of earlier - and especially working class - sports from the post war decades before most of our leisure industry (now belatedly including even conservative horse racing) decided to modernise. As one of our expert assessors commented, 'our pubs do not now look, smell and feel like they did 30 years ago - yet many of our greyhound tracks depressingly do feel just like that'. That feeling may be nicely nostalgic as well as depressing, but it is not necessarily a formula for future commercial success.

Whether the sport can revive and progress as a major spectator sport is, given current social and economic trends, unclear to an outside observer and reviewer. To make such progress it must adjust to accommodate those trends. But the pleasure of participants and spectators which we have witnessed suggests that there is hope. More investment in changing the sport into a modern well-regulated leisure industry might achieve a great deal, as has been demonstrated at those few tracks which have invested in modern facilities. Increased attendances would not only improve the track atmosphere but would also result in increased Tote turnover with benefits to the owning stadia. Tote turnover slipped from £91.9 million in 2001 to £82.5 million in 2005, at least partially attributable to a fall of 5 in the number of tracks. However, since evening opening of betting shops became legal on 1st September 2007, there is exciting potential for increasing income as the word spreads and the new betting opportunities attract more off-track customers. Whether the present industry entrepreneurs feel that major investment is worthwhile, or if they prefer to wait for planning permission to sell out to a supermarket developer as the more profitable short term outcome, is hard to gauge. (Six leading tracks were recently put up for sale). But the better run stadia - such as Yarmouth and Peterborough among the smaller tracks - offer a promising model and Wimbledon on Derby night is impressive.

Ireland

These commendable British examples (and many Irish tracks) demonstrate that the modern public, including its affluent young men and women, will attend and enjoy greyhound racing if it is promoted in an attractive and welfare-friendly environment. Our brief and highly pleasurable sightings of Irish greyhound racing showed their industry flourishing more prosperously than its British equivalent. Shelbourne Park and Cork are far more impressive than any track in Britain and it is claimed that they are not alone and that the average Irish racecourse is better in terms of facilities for spectators, trainers, vets and dogs. Attendance levels, the quality of racing and especially the levels of prize money are strikingly higher - as are the proportion of young women present and, predictably, the degree and volume of enjoyment exhibited by the crowds. In the past decade, attendances at Irish tracks rose 94% to 1.33 million, prize money rose 400% to 12 million, Tote turnover jumped 65% to 50.5 million and on-course bookmaking turnover rose 320% to 93.2 million. These dramatic improvements undoubtedly reflect the fact that in those 10 years over 90 million were invested in the sport's facilities by the Irish Greyhound Board (Bord na gCon). There are no unlicensed tracks in Ireland and no tracks served only by contracted trainers. Personal ownership of dogs is more extensive. It is claimed that one in six Irish adults attends a greyhound meeting at least once a year. That would be a marvellous, if currently remote, ambition for the British industry. The Irish Board's current forward business plan makes its British equivalent seem unambitious and financially deprived by comparison. Some might note the benefits of selective state intervention and fear the impact on British horse-racing were the statutory levy to be withdrawn.

However the successful Irish model is not one which our British industry could easily follow - other than in its broad aspiration to give the public a good evening out. Irish greyhound racing is based on strong state involvement and generous state funding. The governing Irish Greyhound Board is a semi-state commercial body. It was established by government in 1958 under The Greyhound Racing Act which gives the Board powers to regulate all aspects of Irish greyhound racing, including licensing, permits and monitoring their Rules of Racing. The Board itself owns 9 of the 17 licensed tracks, which offers it great leverage over the standards operated by its own management and to set an example to the private operators. The Board also operates Tote facilities at all tracks and applies an on-course levy on all bookmakers' betting. This enables the Board to supplement prize money to generous levels beyond those in Britain and also to provide grants and loans for improving stadia and track facilities and to market the sport effectively. Underpinning this is the Horse and Greyhound Act (2000), through which it was established that 20% of all racing subsidy would be made available to the greyhound industry, thus providing substantial finance for the industry, allowing it to invest with long term confidence. (Act to be reviewed by the Irish government during 2008). Of course not every aspect of Irish greyhound racing is golden. Its racing integrity is viewed with a degree of suspicion by its bookmakers (who prefer to take televised racing from British BAGS meetings where the integrity is reasonably assured) and its application of welfare standards is often behind those in Britain - the wealthy Irish Board spends far less on welfare than does the British Board, though it has plans for increases. Some of these differences relating to integrity and welfare perhaps reflect differences in approach between the two national industries. Irish greyhound racing conveys the impression that its broad approach is based on consistently trying to protect and encourage owners and trainers (who may welcome a light touch in welfare and integrity regulation). The approach of the British industry is probably shaped more by a desire to encourage betting punters and to hold the welfare lobby at bay.

Irish greyhound racing is strongly inter-related to that in Britain, which is why we have touched upon it here. It supplies three quarters of our racing greyhounds and the welfare issues of over-breeding, tracing and re-homing greyhounds common to the two countries will require close cooperation between the British and Irish greyhound authorities. The flourishing Irish model might create envy in Britain. But there is little prospect of its style of statutory regulation and finance being copied here in the near future, given the climate of hostility within the British government to having more state intervention in our sport. The Irish experience is valuable to observe because it demonstrates that well managed greyhound racing offering excellent facilities can attract a large modern audience and enjoy prosperity. However, British greyhound racing will have to develop its own wholly commercial model to try to produce a similarly successful leisure industry. One consequence of having a more modern, successful and profitable British greyhound industry would be that there should be more funds available to pay for the better regulation which this Review seeks.

Conclusion

Most of the broad aspects of modern British greyhound racing mentioned in the above brief general profile, and in the specific analysis and recommendations below, relate directly or indirectly to the regulation of the sport. Confidence in the integrity of the actual racing, and therefore in the huge betting on that racing, depends on the sporting integrity which good regulation secures. Equally, the high welfare standards which today's society demands can only be ensured by strict regulatory procedures - by the rules, licensing, inspection, enquiry and enforcement which an efficient and well resourced modern regulator implements. Without good regulation the sport cannot remain healthy and would suffer ever greater criticism. Good regulation must be at the heart of a successful British greyhound racing industry.

Our main remit in this Review is to consider the present regulation of greyhound racing and to make recommendations for improvement. Our Terms of Reference are at Appendix 1 but in principle were:

"To review the current and future regulation of greyhound racing and to make recommendations as to what changes are needed in respect of regulation at the NGRC and elsewhere."

That remit is not as limited as it may at first sound. Because regulation inter-relates with so many other key aspects of the sport, it does not exist in a separate ring-fenced state which can be examined briefly within strictly limited boundaries. Hence our terms of reference conclude with a helpful sentence:

"There shall be no impediment to the Chairman commenting on other matters relevant to regulation issues."

Our Review therefore necessarily extends, as has the above introductory profile, into other related aspects of this sport. Based on the substantial evidence presented to it by a comprehensive range of witnesses from throughout the industry, it will look below at the British Greyhound Racing Board and at the British Greyhound Racing Fund as well as primarily at the National Greyhound Racing Club because each, to differing degrees, has an influence on how greyhound regulation is resourced and conducted in this country. Appropriate regulation is at greyhound racing's core. This Review attempts to assist greyhound regulation to progress towards a position where it can most actively further the health of this sport as a major British leisure industry.

[1] The apparent synergy between the payment and the number of tracks is coincidental; payments are based on fixtures.