Submission - Draft Dogs Law - States Veterinary Officer - 17 November 2025

Infrastructure and Environment

Natural Environment  

Howard Davis Farm, La Route de la Trinité   Trinity , Jersey, JE3 5JP  

Tel: +44 (0)1534 441600  

Email [email protected]

Deputy Hilary Jeune  17 November 2025 Chair, Environment, Housing and

Infrastructure Panel

(By email)

Dear Deputy Jeune

Draft Dogs Law (Jersey) Amendment Regulations 202- (P.63/2025)

I am writing with regards to correspondence received on the 12th of November 2025.

The XL Bully isn't a recognised breed by the Kennel Club (or by most kennel clubs in Europe including FCI - Fédération Cynologique Internationale) it's a "type" derived from mixing American Bully lines with other large dogs (Pit Bull–type, Mastiff, amongst others). There are no breed standards, there is no regulated temperament testing, and there is huge variation between dogs within the same type. Some breeders deliberately select for size and intimidation, not temperament. Poor or unethical breeding increases the risk of unstable temperaments, fear reactivity, and unpredictability. It is suggested that a combination of breed traits, size, and owner profile has produced more high-risk outcomes compared to other types of dogs.

The XL Bully type is extremely strong, muscular, and heavy often 40–60 kg (90–130 lb). When such a large dog becomes aggressive (for any reason fear, pain, excitement), the damage potential is huge. While a Chihuahua or Cocker Spaniel might also bite, the impact of an XL Bully attack is vastly greater.

The proposed legislation changes take into consideration a conformation standard which includes the measurement of certain characteristics such as size, width, shape of head, body shape amongst others. The option suggested on the draft law is a pragmatic and effective short-term response to a growing issue in Jersey which impacts public safety. The concerning increase in fatal and serious dog attacks involving dogs of the XL Bully type (mainly in the UK) alongside the realisation that a number of such dogs are already living in Jersey and continuing to breed was presented to the Committee des Connectables who agreed that swift targeted action was required to limit the number of XL bully type dogs in Jersey, trying to avoid further breeding which would result in a continuous growing issue.

The idea behind the proposal is to reduce the number of dogs exhibiting physical characteristics which are deemed to make them inherently more dangerous should they become aggressive for whatever reason and implement safeguard measures to minimise the risk to the public. This is not a ban but an implementation of safeguard measures on dogs exhibiting certain characteristics.

Other options such as behaviour assessments were considered, however, it was concluded that such approach faced significant obstacles in implementation, would absorb significant amounts of time and resources, had no guarantees of success on its own and any benefits would take longer to materialize.

Dog behaviour is fundamentally different from physical traits because it is a result of a complex mix of genetics, environment, learning, and even moment-to-moment emotions/reactions. Unlike physical characteristics, behaviour is not fixedit changes as animals learn and adapt. This means behaviour is never certain; it is influenced by circumstances and not always definite.

An approach that does not focus on specific dog characteristics but instead applies to all dogs emphasising owner responsibility and mandatory trainingcould, in theory, tackle the root causes of dangerous behaviour. However, such a system would require significant resources, time, and regulatory changes to be implemented effectively.

In addition, there are further consideration of legal nature, which we did not analyse as it is not our area of expertise, for example, how to reconcile such an approach with Human Rights Legislation.

Whilst none of the obstacles identified are unsurmountable, they require a radically different approach in terms of time and resources. We must remember Jersey has more than 10220 dogs registered, and any behaviour assessment would have to be done to every single dog in the Island, most likely at a pre- determined frequency, and behaviour is complex to assess.

In summary, the subjectivity and complexity of implementing a broad "non-bread specific" reform on dangerous dogs regulation would be extremely slow to achieve with significant ask of resources and finances and there is no certainty that it would minimise the risk without further additional measures.

The current proposal strikes a pragmatic balance between an efficient allocation of existing resources and realization of benefits to public safety whilst addressing the urgency of the issue in a timely manner.

Yours sincerely,

Susana Ramos, DVM, MVPH, MRCVS

Chief Veterinary Officer and States Veterinary Officer