PART III: A New Body to Govern, Finance and Regulate Greyhound Racing
A NEW BODY TO ADMINISTER AND REGULATE GREYHOUND RACING
- The Need For Change
- NGRC - The Regulator
- BGRB - The Industry Body
- The Greyhound Board of Great Britain - An Alternative Structure
- The Outline Structure
- The Main Board & The Regulatory Board
- The Legal Position
- The Role of the GBGB and Relationships Within the Organisation
- Supporting Committee Structure
- Supporting Staff Structure
- Tenure of Directors
Although our Terms of Reference place emphasis on the need to review the current and future regulation of greyhound racing and the issues relevant to the principles of modern regulation, it became clear to us early in the review process that it would not be possible to address these matters in isolation. Indeed, any sporting regulatory regime is only as effective as the governance and financial structures which support it and the first part of our Report has illustrated in some detail why the current complex and sometimes illogical system of governing and financing greyhound racing is less than fully effective.
As has already been discussed, greyhound racing in Ireland is a thriving sport and, as with horseracing in Ireland, it is evident that one of the two main reasons for its undoubted success is that the sport has a strong, Government-backed central body - Bord na gCon - which governs all administrative and regulatory aspects of greyhound racing; the second reason is the relatively generous and secure funding regime enjoyed by Bord na gCon but, given that a significant proportion of it derives from the public purse, that is not an advantage we can seek to replicate here in Great Britain  for reasons which have already been given.
The Need For Change
However, the need for a single, clearly identifiable governing body in relation to greyhound racing in Great Britain was also identified by many of those who presented evidence to us, although not, as we have seen, by the NGRC itself. There were a number of reasons for this which have already been exhaustively catalogued, but, in essence, they reflected the overall view that the current administrative and regulatory structure is too complex. This has led to inefficiency, duplication, slow decision making sometimes without adequate consultation and frequent tensions and disputes between the bodies involved. This situation means that the industry finds it hard to speak with one voice on those occasions when it matters.
There is also the perception that the NGRC has pursued and defended its independence to the point where it has distanced itself from the sport to such an extent that it has lost the confidence of those it regulates. As in any situation where a sport, or indeed any body of people, submits itself to a non-statutory regulatory regime, that position is untenable. Add to this the remit placed on the NGRC by the Minister of State at Defra in December 2006 that it must "make root and branch changes" if it is to be endorsed as the sport's regulator by central Government and it becomes clear that a radical approach to the regulation of the whole industry is indicated.
That is not to say, however, that the NGRC has not made the strenuous and indeed successful efforts to which we have already referred to modernise its approach and to address the criticisms which have been directed towards it. In particular, the award of UKAS accreditation is a major step forward and one which any new structure must retain. It is particularly significant that great strides have been made in the computerisation of records and the tracking of retired greyhounds; there is more to be done and an evident enthusiasm to do it, so it is important that any new structure takes this crucial aspect fully on board.
We are also aware that the BGRB itself has not been without its shortcomings. The apparent dominance of particular stakeholder groups on the Board created an unbalanced situation in which the regulatory budget was vulnerable to manipulation, thus rendering genuine independence at least partly illusory, and where the vested interests of the few could be pursued without significant hindrance.
However, we have already described the substantial change which has occurred since January 2004 and would reiterate that the introduction of two non-executive directors and the consequent absence of any single stakeholder majority has been a key development, leading as it has to the streamlining of the committee structure and to the lead role in the budgetary process now being played by the independent directors. This is a strength on which we shall seek to build.
Nevertheless, as discussed earlier in this report, it remains the case that neither the NGRC nor the BGRB necessarily operate in pursuit of the same objectives and, in fields such as welfare, where they should be doing so, the tactical approach may be different.
In view of this and the evidence presented to us we, as signalled throughout this Review so far, concluded that we must look at the central administration and regulatory mechanism as a whole. It seems clear that if a way of identifying the necessary central functions and a better way of arranging them can be found, then the sport would benefit from improved efficiency and less internecine competition. If, in the process, there is scope for cost savings, much needed additional funds would be released.
On the issue of costs, it has been said that the problems faced by greyhound racing could be resolved were the betting industry to make a greater financial contribution. To make such an assertion, it is first necessary to establish that the overall level of funding which is available is being used to best effect and that expenditure of such funds is appropriately prioritised. We shall return to this issue in more detail but it remains the case that, if organisational savings can be identified, then these could be applied to other more pressing heads of expenditure, thus alleviating some of the pressure in cash hungry areas such as welfare, integrity and prize money.
In our review of the administrative and regulatory mechanisms, we looked first at the main functions of the two bodies.
NGRC - The Regulator
Part 2 of this Review has discussed in greater detail the role and functions of the NGRC and, for convenience, these are summarised again below, albeit in no particular order:
- The implementation and management of the Rules of Racing.
- To evolve, amend and provide advice on the Rules of Racing as is necessary in conjunction with the rest of the sport.
- The identification and registration of greyhounds for NGRC licensed racing.
- The licensing of greyhound racecourses, trainers, owners, kennel staff and track officials.
- To set licence fees in consultation with stakeholders to run the administration of the sport.
- To inspect and maintain the standards required of all licensed parties.
- To manage and maintain a database of all NGRC registered greyhounds, owners, trainers and other license holders.
- Management of the drug sampling programme.
- Setting standards for racing integrity including race form and greyhound performance.
- Investigation of complaints, alleged breaches of the Rules of Racing and, where necessary, the implementation of the disciplinary process.
- The publication of all formal notices and information through the NGRC Calendar  and web site.
- Setting standards for greyhound welfare and retirement.
BGRB - The Industry Body
There is, at present, no universally recognised body which governs the sport of greyhound racing in Great Britain. The BGRB is as close as it currently gets but its roles and functions are largely promotional (in the commercial sense) and representational. They may be summarised as follows:
- Strategic planning.
- Formation of industry policy on welfare and other common-interest issues.
- Preparation and presentation of the annual budget.
- Provision of public relations and media services, including Government liaison.
- Representing the sport where a single point of contact is required, such as with the public or press, or other related industries such as bookmakers or picture/rights distributors.
The BGRB discharges these functions with a small core staff and a network of committees, each of which addresses specific areas of activity and which report, through an Executive Committee led by the BGRB Chairman, to the main Board.
The Greyhound Board of Great Britain - An Alternative Structure
It is clear from that which has gone before, all of it evidence-based, that however well the NGRC and the BGRB work in isolation, they have found it extremely difficult to work together. Indeed, it is hard to avoid the conclusion that the power struggle which has characterised their relationship for so long has actually worked against progress.
There is also the continuing danger to the sport and its reputation that the perception held by those concerned with greyhound racing, from the Government downwards and in particular by the welfare groups, is one of a private club regulating a major British sport. This can only be harmful to those commercial opportunities which must be exploited if greyhound racing is to prosper.
It is against this background, therefore, that our recommended solution to the shortcomings of greyhound racing's current central structure is the creation of a single entity which combines the strengths of both the NGRC and the BGRB. This new body should take over from the existing bodies and perform cost-effectively the administrative and regulatory tasks required by greyhound racing. We propose it should be called the Greyhound Board of Great Britain (GBGB) and that it should be the sole governing body of greyhound racing in Great Britain.
We have already highlighted the fact that one of the main bones of contention between the NGRC and the rest of the industry has been the former's insistence on maintaining its absolute independence, possibly to the exclusion of other priorities. Whilst we accept the need for an independent regulatory structure, we do not accept that independence and integration within a governing body are mutually exclusive. We will therefore recommend a structure which maintains the maximum degree of independence for the regulator consistent with the need for transparency and accountability to the sport as a whole. At its most fundamental this means that the GBGB, as the new governing body, would operate from a single headquarters unit.
We recommend that the GBGB should be established as a company limited by guarantee. Appropriate memorandum and articles of association should be drafted to provide that the company should be a 'not for profit' organisation. We suggest that the guarantees in the company should be held equally between the Racecourse Promoters Association, the Federation of British Greyhound Owners Associations and the Greyhound Trainers Association.
The Outline Structure
In considering a Potential Model for Future Regulation, the APGAW Inquiry  recommended that "a significant number of representatives from animal welfare organisations…" should be included on a broadened independent body to regulate greyhound racing. After having reflected at length on this proposal, we cannot support it. Greyhound racing is a commercial undertaking; it is part of the leisure industry and a prime betting medium. In common with any other commercial undertaking, it has to be financially viable to survive. It is also a sport, like horse racing, which involves large numbers of animals. This combination of sport, betting and animals demands rigorous, effective and, as far as possible, independent regulation.
Whilst animal welfare charities have an important role to play in ensuring the care and welfare of greyhounds, we are not convinced by the argument that they should have a seat on the main board. They are not, in our view, in place to operate or regulate a commercial leisure activity but to bring influence to bear which helps to ensure that such activities are run humanely by those whose responsibility it is.
A regulatory body, constituted as suggested by the APGAW Report, would also include track vets, representatives from the independent operators as well as the current NGRC. To include in addition a "significant number" of welfare representatives, who would quite possibly be difficult to select, would result in a Board which would be unwieldy in the extreme, riven by conflicting interests, and most unlikely to be an effective regulator in practice.
This is not to say, of course, that the position of the Welfare Groups should not be appropriately promoted and our proposals below explain how we would envisage their interests being properly reflected and incorporated into the new structure.
The Main Board & The Regulatory Board
We envisage that the GBGB should have a single main Board which would be the highest level of authority in the sport. It should, ideally, be smaller than the existing BGRB Board and contain an increased proportion of independent  members. Incorporated within the GBGB, but with independent status, would be the Greyhound Regulatory Board (GRB). It is a fundamental feature of this Regulatory Board that it is a body integrated into the overall GBGB structure and not a subordinate element of it. For this reason, it is recommended that there would be strong common representation on both Boards to maintain the necessary high level of regulatory influence consistent with accountability. It is suggested that the composition of the two Boards should be as follows:
GBGB Board (10 Members):
One independent chairman - to hold a casting vote
The independent chairman of the Regulatory Board
Three independent directors - (to include the Veterinary Director from the GRB - see below - but not necessarily limited to one vet.)
Three racecourse promoters nominated by the RCPA.
One greyhound racing practitioner nominated jointly by the FBGOA and GTA
The GBGB Chief Executive
Although we do not support the direct involvement of any of the welfare organisations at board level in the governance or regulation of greyhound racing, we believe it would be appropriate to appoint independent directors either with direct veterinary experience of greyhounds or with an interest in and understanding of welfare issues falling short of direct involvement - or both.
The recommended structure would, we believe, give a combination of stability and expertise to the Board with the chairman only having to use his casting vote in the unlikely event of an even split amongst Board members (as is the case at the Horserace Betting Levy Board). In essence, any proposition before the Board would have to attract a measure of independent support to succeed.
Regulatory Board (5 Members):
One independent chairman with a background in regulation.
One independent member qualified as a veterinarian.
One independent member with a background in the regulation of greyhound racing
GBGB Chief Executive
Senior Stipendiary Steward
With this structure and composition, three members of the Regulatory Board, including the Chairman, would also sit on the main Board, thus maintaining a strong element of regulatory influence at the highest level.
Stewards Disciplinary Committee
We have also heard much criticism that the existing regulator is rule maker, prosecutor, judge and jury in its own court. There is some justification in that assertion and we would address that by creating a separate body, the sole function of which would be to hear disciplinary proceedings. We suggest that this body be called the Stewards Disciplinary Committee and that those stewards serving on that Committee should be precluded from serving either on the GBGB Board or the GRB at the same time. The Committee would be serviced by a full or part time Clerk to the Stewards Committee. We see no reason to seek change to the Appeals Procedure which has already been put in place.
The Legal Position
The NGRC has provided us with a substantial weight of evidence which seeks to demonstrate why the BGRB and the NGRC must remain forever separate in order to preserve the integrity of the NGRC as an independent regulator. Since this is contrary to the structure of the unified body we have proposed above, the issue is addressed at this point before we go on to describe the different roles and relationships which we envisage.
It was our view when considering these issues that the legal backdrop has changed in recent years with the introduction of the Competition Act 1998 and also that many of the objections to combining the two bodies which have hitherto been upheld by the Court would be overcome by the substantial independent element which we are now recommending at the decision and policy making levels. Indeed we have received substantive legal advice of our own which indicates as much at the same time as giving guidance on other potential areas of difficulty.
The advice itself is detailed and constructive but concludes that the amalgamation of the NGRC and the BGRB is no more likely to give rise to any greater exposure to successful challenge than exists already. The advice goes on to stress the need for practical separation of regulatory activities and competition compliance measures. We have taken this into account when formulating our proposals; for example, the omission of stakeholder involvement in the composition of the Regulatory Board described above derives from this source. A copy of the advice will be made available to the Transition Committee (see Chapter 16). We have also had sight of legal advice on the same subject commissioned by the BGRB from a different source. It also comes to the same conclusion that there are no sustainable objections in law to an amalgamation of the two bodies such as we have described.
The Role of the GBGB and Relationships Within the Organisation
The GBGB Board
The GBGB Board is the highest level of management in greyhound racing. It is ultimately responsible for all aspects of governance and regulation and must therefore be in a position to approve the proposals of the Regulatory Board. It has no links with, nor authority over, the Stewards Disciplinary Committee or the Appeals Procedure.
We envisage that the supporting structure for the GBGB Board should continue to function broadly around the Committee system currently in place with permanent staff resources allocated to particular areas of activity, including the management and implementation of welfare policy which we consider is a governance as well as a regulatory issue. We consider that the Committee level is the correct point at which the Welfare groups should have direct representation and suggest that the Welfare Committee should include among its membership a person nominated by the Greyhound Forum. It is for the Forum itself to decide who that should be.
We consider that a financial services office and a centralised IT and database management team should be specifically established. We examine staffing implications in more detail later in the paper but strongly believe that those who are currently involved in these areas of activity should be encouraged to continue, within the new framework, the excellent work which they have started .
The responsibilities of the GBGB Board and its supporting structures would therefore be as follows:
- To develop a commercial strategy for the greyhound racing industry.
- To promote the interests of greyhound racing.
- To approve proposals for additions or amendments to the Rules of Racing as submitted by the Greyhound Regulatory Board. 
- To formulate industry policy on welfare and other common-interest issues.
- To manage Government and inter-industry relations including public relations and media liaison.
- To approve the annual budget.
- To establish and maintain a common database covering all licensed greyhounds (active and, in due course, recently retired), personnel and premises.
- To develop and implement industry training policy.
Greyhound Regulatory Board
It is essential that the Greyhound Regulatory Board and its supporting staff have the independence necessary to police the sport of greyhound racing by enforcing Rules of Racing which have been approved by the GBGB Board and taking action against those alleged to have breached those Rules in accordance with procedures which have also been approved by the GBGB Board. The regulatory element should continue to administer the licensing system but we do not consider that the setting of licence fees per se is a regulatory issue, although regulatory costs will of course still have to be met from this source. Rather we see this being done by a separate finance office which would manage all non-levy (BGRF) income to the GBGB and which we discuss in greater detail later.
In summary, therefore, the responsibilities of the Regulatory Board would be as follows:
- To implement and manage the Rules of Racing.
- To propose, amend and provide advice on the Rules of Racing and to gain formal approval for such changes as are necessary from the GBGB Board.
- To provide the identification and registration of greyhounds for licensed racing.
- To license greyhound racecourses, trainers, owners, kennel staff and track officials.
- To inspect and maintain the standards required of all licensed parties.
- To manage the drug sampling programme.
- To set standards for racing integrity including race form and greyhound performance.
- To investigate complaints, alleged breaches of the Rules of Racing and, where necessary, to implement the disciplinary process.
- To publish all formal notices and information through the Calendar and web site.
Supporting Committee Structure
It is quite clear to us that both the BGRB and the NGRC are currently run by dedicated and well motivated teams of people. We firmly believe that if their efforts can be co-ordinated and directed under a single main board structure, such as has been described, and led by a single chief executive, that their combined output would be greater and better focused than the sum of the two parts. That will mean some structural reorganisation and certainly co-location.
As a basis upon which to build, we believe that a streamlined version of the Committee structure which underpins both the BGRB and the NGRC should, in essence, remain, with each Committee chaired by a main or, where appropriate, regulatory board member and supported by one or more of the sections/teams within the permanent staff structure. This latter point is important because focussed executive support can lighten the load on the respective Committee chairmen and assist the Committees themselves in identifying the decisions they must take by developing proper executive analysis and recommendations in advance of meetings; and subsequently progressing and implementing such decisions.
It would, of course, be necessary to add a standing Regulatory Committee to support the Greyhound Regulatory Board in the first instance and to form a team or teams to support that Committee. Membership of the Regulatory Committee might include the Head of Regulation and representatives from the practitioner and welfare fields. In this context, the continuing need for the current related NGRC Expert Committees (Integrity Joint Committee, Rules Review Committee and Sales Trial Sampling Committee) would be for consideration by the Regulatory Committee itself but there is no reason why they should not be retained as specialist sub-committees of the Regulatory Committee if deemed necessary.
The BGRB set up its present structure of policy committees matters nearly four years ago, following a design by one of its directors. This represented a major step forward in resolving detailed matters without debate at full board; in involving a wider range of greyhound practitioners in the work of the Board; and in empowering the committee chairmen in progressing policy initiatives. The Committees also form an essential part of the budget-setting process, which will be described in more detail in Chapter 10.
The standing committees of the BGRB include the Commercial Committee, the Racing Committee and the Welfare Committee. There is also the Chairman's Executive Committee comprising the chairman himself, one independent BGRB director and the three standing committee chairmen. It is in the nature of the current organisation that a number of the same people sit on different Committees.
Although the structure has worked well, the creation of the GBGB will provide a timely opportunity to review certain elements of its operations. We are told, for instance, that some of the Committees have become too large for effective despatch of business; also, and perhaps as a consequence, there is a tendency for attendances to be unstable, resulting in the substitution of members which can prejudice continuity and consistency in decision-making. This may also provide an opportunity to review the terms of reference of the Committees to ensure that their functions remain relevant and focussed and would not be better carried out elsewhere.
It seems likely that the work of the NGRC's Veterinary, Welfare and Scientific Committee could be combined with the BGRB's Welfare Committee to good effect, ideally under the chairmanship of the independent veterinary director of the Regulatory Board.
The current membership of these two existing committees would require review to ensure that the new committee (perhaps called the Greyhound Welfare Committee) was of a manageable size and included expert representation from the operational areas of the sport as well as from the veterinary and welfare fields. We recommend that the Chairman of the Retired Greyhound Trust should be retained as an ex-officio member and, as indicated above, that one member of the Greyhound Welfare Committee should be nominated by the Greyhound Forum.
We further recommend that the existing Joint Finance Committee and the BGRB Budget Committee should combine to become a Finance sub-committee of the Executive Committee. It is ultimately for those involved to decide but we would suggest that the Finance sub-committee should comprise the GBGB board chairman, the Regulatory Board chairman and one other independent main board director. The Executive Committee itself would of course need to expand to accommodate the chairman of the Regulatory Committee. We envisage that the financial services office and the IT and database management team, both mentioned above, should be responsible, through the Chief Executive, to the Executive Committee.
An organisation chart showing the proposed Board/Committee structure is appended to this chapter.
Supporting Staff Structure
The NGRC headquarters currently has a staff of 12 persons and the BGRB currently has a full-time complement of 4 persons, supported where necessary by consultants in the fields of welfare, industry training and public relations/public affairs. We believe that all 16 of those currently employed by the NGRC and the BGRB could be integrated into a joint headquarters structure to provide comprehensive staff support for the standing committees and both the GBGB and the GRB. A proposed staff organisation chart is appended to this chapter as a suggested starting point for the new organisation.
We of course accept entirely that, in managing the transition which must occur, those with responsibility for that process may take a different view on the way forward. However, we have taken this approach because we are conscious that structural change on this scale has the potential to be highly disruptive and one reason behind our approach is to minimise the day-to-day impact on the staff involved, particularly in the early stages. We have no doubt that the management team will, in due course, identify synergies and working patterns which we have not recognised and adapt the organisation accordingly.
Distribution of Staff
It has been represented to us that the various functions currently carried out by the NGRC and the BGRB can be listed and categorised as either "Regulation" or "Administration" and divided accordingly. Whilst superficially attractive, there is, or should be, in practice a good deal of interface between the two. In the key area of welfare, for example, it is evident that the Rules of Racing play a major part in ensuring the welfare of greyhounds but it is not part of the welfare task per se to develop and maintain the Rules of Racing. Rather that is a matter for the regulator, in consultation with others, including the welfare interests, to carry out this task. Similarly, a crucial function of welfare is the registration, licensing and tracking of greyhounds but, again, the execution of these tasks is not a welfare responsibility.
The headquarters structure which we are suggesting, therefore, envisages an interactive relationship between the various teams, in response to management direction, to secure whatever objectives the organisation as a whole needs to achieve. To deliver this result, we are proposing a structure headed by a Chief Executive Officer with two main divisional branches covering Policy & Industry Affairs and Regulation reporting into that office.
Policy & Industry Affairs
The Head of Policy & Industry Affairs would act as Company Secretary and should, we believe, be responsible for all activities which do not lie within the specific field of regulation outlined below. These would include direct responsibility for developing commercial strategy, marketing, public relations and industry training and the supervision of the welfare, finance and administrative support functions within the headquarters. Essentially this role reflects much of the work currently undertaken by the BGRB's General Secretary and Policy Officer, adapted to meet the needs of a unified headquarters.
Similarly, as the chart shows, there are certain regulatory functions currently carried out by the NGRC which, under the Head of Regulation, could translate directly across into the new structure and in which change will be minimal, at least in the first instance - perhaps the current NGRC General Manager might be an appropriate appointee to this role. The NGRC Security Office functions would, we believe, continue as they are, as would such functions as registration and licensing. The Head of Regulation, in close co-operation with the Head of Policy & Industry Affairs, would also be responsible for the definition and co-ordination of the developments needed in the field of IT (see paragraph below).
The BGRB have recently recruited a Finance Manager and there is also a Financial Secretary at the NGRC. We have argued elsewhere for a simpler financial management structure than that which currently exists, which should flow naturally from the reorganisation anyway. If this can be achieved and the relative roles of the two persons concerned can be matched, we see potential advantage in a strong finance office employing two people handling all aspects of financial management for the organisation. This would, as suggested above, include everything from recommending appropriate fee levels to management of the payroll.
Turning to IT, it would appear, prima facie at least, that the resource for the timely development of IT systems between the two organisations is inadequate. The NGRC IT manager has made great strides in implementing a system for the tracking of retired greyhounds but systems are needed to ensure that accurate and accessible records of all licensed greyhounds and personnel are available to management, not only in the interests of effective regulation but also to enable the industry to counter some of the claims of those opposed to greyhound racing. We describe what we see as the priority goals for IT development to be addressed by the new organisation in Chapter 14 below but consider that an IT support and development team of 2 would be the minimum required to deliver what is needed in a reasonable timescale. Indeed, it seems likely that consultant support in this area may also be needed in the first instance.
We note that, under current arrangements, the BGRB employs a full-time Welfare Officer and also a Welfare Consultant. We have proposed a new Welfare Office consisting of two people, recognising that they will have an involvement with managing the impact on the industry of the Animal Welfare Act and the secondary legislation which flows from it as well as working closely with all other elements of the headquarters in the development of policy and regulatory recommendations on welfare-related issues affecting the industry. We would also envisage this office perhaps supporting the CEO where events or circumstances demand press and/or public relations responses from the industry. Taking into account the job descriptions for the existing incumbents which have been provided to us, it is for consideration that both members of staff should be employees of the new organisation.
The NGRC currently employs seven Stipendiary Stewards; it has told us in evidence that the figure required is 12 and, indeed, that it was a requirement of the Minister of State at Defra that such a number should be available. We are unqualified to give a view on whether this number is correct or not but it is evident that resources are currently spread thin on the ground and that an increase is clearly necessary. It is not immediately obvious where the additional funding needed to fulfill this aspiration can be found but it must, in our view, be an early objective for the Regulatory Board to carry out a review of its Field Force requirements and to accord an appropriate budgetary priority to meeting them. We have therefore, and for the purposes of this Review only, illustrated a Field Force of 22, of which 11 are Earmarking Stewards, with the remaining 11 comprising the seven current Stipendiaries, the three Security Officers (Sampling) and the Investigating Officer. However, we must be clear in stating that, if the case for 12 Stipendiary Stewards is correctly made, the recruitment of the extra five should be seen as a high priority for the new Board.
It will be noted that our recommended membership of the Greyhound Regulatory Board included the "Senior Stipendiary Steward". Currently, none of the Stipendiary Stewards carries this title. We therefore recommend that either one of the current incumbents should be identified and appointed as such; or that a person should be recruited specifically to the post as part of the overall increase in Stipendiary Stewards discussed above.
Tenure of Directors
We note that different arrangements are in place concerning the length of time for which directors/stewards may serve on their respective boards and even between the time that non-executive and industry directors may serve on the same board. We are also aware that there are some directors who have served for many years. In general terms, we are not convinced that such longevity, in this or any other field, necessarily contributes positively to innovative thinking or a readiness to adapt to or even recognise changing circumstances and priorities.
We recognise, of course, that tenure must ultimately be a matter for the industry and for the boards themselves but the issue will nevertheless need to be addressed and agreed before any new Articles of Association are finalised.
It is our strong recommendation, in the interests of good governance, that directors, including chairmen, should serve for no more than four years at a time and that they should be eligible for re-election only once, thus capping their service at eight years. We are also aware that the BGRB has a maximum age limit beyond which directors may not serve. The new body will wish to take advice as to whether, following recent age discrimination legislation, such a provision remains legally enforceable if it wishes to retain the restriction.
We have in this Section set out our reasons for recommending a single body to govern and regulate greyhound racing in Great Britain. The suggested structure is designed with interdependent and cross-reliant staff functions within a clearly defined management framework.
Although deliberately not far reaching in personnel terms, we have also made proposals as to how, certainly initially, such an organisation might be structured, recognising that it will, indeed must, evolve as it gains momentum and operational experience. This has not so much been a case of reallocating particular tasks from one body to another as seeking to create one integrated organisation carrying out the entire function of both existing bodies. At the same time, we have sought to preserve the degree of independence needed by the regulatory element to carry out its role unimpeded by factional interest or the threat of cash starvation, whilst remaining accountable at the highest level to the industry and the wider public it serves.
 Greyhound Racing in Northern Ireland, such as it is, is regulated by the Irish Coursing Club
 The NGRC Calendar is a fortnightly, subscription publication containing information, advice and guidance for licensed persons, up-to-date licensing or rule change information and lists of upcoming Open Race events as well as the results of Open Races staged over the previous two weeks.
 Associate Parliamentary Group for Animal Welfare Report - 19 May 2007 - Para 4.4
 We recommend that the term "independent" shall mean any person not beneficially interested in the ownership, control or operation of greyhound race tracks, the holding or conduct of public sales of greyhounds or the training of greyhounds for reward, or in bookmaking.
 We expect that such approval would not be unreasonably withheld, although recognising that excessive cost, inadequate notice and/or impracticality of implementation could be examples of occasions on which Rule proposals or amendments might need to be reconsidered.