Stan Roberts•1 week ago Dear Sir/Madam,I wish to submit my comments and objections regarding certain provisions of the proposed City of Cape Town Animal Keeping By-law 2026.I am a responsible bird keeper/breeder and support appropriate animal-welfare standards, responsible animal ownership, biosecurity and reasonable measures to prevent genuine public nuisance.My concern is that several provisions of the proposed By-law appear unnecessarily broad and may have serious unintended consequences for responsible bird keepers and breeders.1. I object to the proposed threshold requiring a permit for keeping more than five captive birds on residential premises. This threshold does not take into consideration small to large holding residential properties, where the number of birds could be proportionate to the size of the property. I request that this provision be reconsidered and replaced with a more proportionate, risk- and nuisance-based approach. Animal-Keeping-By-Law-2.pdf2. We are concerned about the proposed aviary standards. Animal-Keeping-By-Law-2.pdfBird species have vastly different requirements. We keep small finches and pheasants. These two species require vastly different natural substrates and vegetations that are essential to healthy living and breeding, which are not been catered to in the proposed aviary standards.It is our suggestion that aviary requirements be outcome-based and species-appropriate, developed with input from experienced aviculturists, avian veterinarians and recognised bird-keeping organisations.3. There seems to be a duplication of regulatory controls between Helderberg nature, City of Cape Town and local Municipal laws. The standardisation of this bill is not clear on who is going to control these regulations. As this bill overlaps with already existing controls.4. In the matter of the regulation of breeding and sales, there needs to be more clarity. In current practice, responsible hobby and conservation breeders occasionally sell or exchange surplus offspring as a normal part of maintaining viable breeding collections. It is critical that there be no limitation to this practice as the strength of the gene pools is already weakened and many breeds are in danger of total infertility. Animal-Keeping-By-Law-2.pdfClear distinctions should therefore be created between hobby breeders, conservation breeders, specialist aviculturists and commercial animal traders.There is also a concern about existing aviaries and established collections. Many responsible breeders have maintained facilities for years or decades. New setback, building-plan or construction requirements could make perfectly functional existing aviaries technically non-compliant despite there being no animal-welfare or nuisance problem.We request protecting existing lawful facilities, except where an actual welfare, health or nuisance problem can be demonstrated.Finally, we ask the City to ensure that enforcement is proportionate. There must be a clear distinction between animal cruelty or serious welfare violations and ordinary technical or administrative non-compliance. Responsible owners should ordinarily be given a reasonable opportunity to correct technical non-compliance before more serious enforcement measures are considered.We respectfully request that the City reconsider these provisions in consultation with recognised avicultural organisations, experienced breeders, specialist veterinarians and other affected stakeholders.We support responsible animal keeping and effective animal-welfare legislation. Our objection is not to regulation itself, but to regulation that may be disproportionate, scientifically inappropriate, duplicative or unnecessarily restrictive of responsible aviculture.We request that this submission be formally recorded as part of the public participation process concerning the Draft Animal Keeping By-law 2026.Kind regards,Stan RobertsSomerset West[Bird keeper / breeder / aviculturist]info@ropro.africa0824440525
