. • The consultation states that the Scottish Government proposes to introduce new licensing requirements for animal boarding “that will be delivered through the same framework as used in the Animal Welfare (Licensing of Activities Involving Animals) (Scotland) Regulations 2021”. • The Animal Welfare (Licensing of Activities Involving Animals) (Scotland) Regulations 2021 replaced previous legislation covering pet sales and dog breeding, and introduced new licensing requirements for cat and rabbit breeders, animal welfare establishments (such as animal sanctuaries and rehoming centres) and other pet rehoming activities. • Schedule 2 of the Regulations set out general licence conditions that apply to all licensable activities, and includes the following conditions on ‘emergencies’ with specific reference to fire risk: “10.—(1) If animals are kept in premises, other than domestic premises, from which the licensable activity is carried on— (a)a written emergency plan, acceptable to the licensing authority, must be in place, known and available to all the staff on the premises, and (b)such a plan must be followed where necessary to ensure appropriate steps are taken to protect all animals on the premises (without risking human life) in case of fire, breakdowns of essential heating, ventilation and aeration or filtration systems or other emergencies. (2) Any such emergency plan must include details of the emergency measures to be taken for the extrication of the animals should the premises become uninhabitable and an emergency telephone list that includes the fire service and police. 2 (3) External doors and gates must be lockable. (4) If animals are kept in premises from which the licensable activity is carried on, a designated key holder with access to all animal areas must at all times be within reasonable travel distance of those premises and available to attend in an emergency.” • Whilst the licensing conditions in the Regulations themselves do not explicitly include a requirement for fire alarms or smoke detectors in licensed premises, in December 2021 the Scottish Government issued guidance against these conditions stating: “Any buildings must have at least one working smoke detector (or other suitable fire detection system) installed in a suitable location on each separate level / floor of the property and there must be at least one carbon monoxide detector.”