Select Committee on Agriculture Minutes of Evidence

Examination of witness (Questions 1 - 19)




  1. Mr Curry, I welcome you to the Committee. You have appeared before us from time to time wearing another hat. Today we invite you to wear a different hat as Chairman of the IACS and Inspections working Group which reported to MAFF just over a year ago. Recently, you provided an upbeat progress report on implementation, except for the failure to remove the concept of producer groups in relation to the sheep annual premium scheme. That is rather like the "Schleswig Holstein" question: I used to know what it meant but have forgotten. However, for this purpose I do not believe that I need to know. Given that MAFF does not seem to have found it too difficult to follow your recommendations, do you think that you were sufficiently radical?
  (Mr Curry) We certainly set out to be radical. When we met for the first time I made it clear that we would leave no stone unturned and take a serious look at the issue of burdensome regulations. Therefore, we certainly wished to be radical. I believe that we went as far as we could in our radical approach. However, one is constrained by many of the EU support systems in terms of just how radical one can be. However, we set out to achieve as much as possible.

  2. What do you mean by "radical" in this context?
  (Mr Curry) Bearing in mind the remit, which was to look at IACS and farm inspections, we interpreted it as including all support systems for main enterprises on farms; that is, livestock and the systems included within IACS. We set out to find out whether there could be a better way to apply those schemes and monitor their enforcement. Therefore, we were content to look at all aspects and, if necessary, turn them over. We did not challenge the schemes themselves because clearly they were not within the remit.

  3. Had you been trying to design the system from scratch, were there areas in which you felt that you might well have made recommendations which would have led to quite a fundamentally different system from that which exists? To illustrate what I mean, might you have recommended that, say, in relation to inspections in the meat processing sector we should move to the HACCP (hazard analysis at critical control points) system, as opposed to the physical presence of a veterinarian on the line?
  (Mr Curry) Wearing my other hat, I worked very closely with the Pooley Group and its report which looked specifically at abattoirs, meat processing plants and the controls and enforcement in place there. I advised Pooley from the outset that there was a serious opportunity to introduce a hazard-based system in those plants; indeed, the group came to that conclusion. One was quite prepared to take that approach. However, one found that the systems of support in place in the livestock sector, particularly beef, had evolved over a long period of time. One support system was introduced and a few years later another one was introduced. One has suckler cow premium schemes, beef special premium schemes and ultimately an extensification scheme. These were introduced over a period of time. Each individual scheme had its own rules, enforcement of those rules and method of application, and one would not have started from that point if one had begun with a clean sheet of paper. We tried to go back as far as we could to find common ground between the schemes and opportunities to rationalise the way in which they were being enforced.

  4. Basically, did you seek to make the present structure work better rather than devise an alternative strategy?
  (Mr Curry) Yes. We did not believe that it was within our remit to devise an alternative support structure. That would have meant a complete renegotiation of the beef support systems in Brussels which we did not believe fell within the group's remit.

  5. When do you plan to make another review of progress of implementation?
  (Mr Curry) At the end of the current year.

  6. Have you chosen that date unilaterally?
  (Mr Curry) We held a review meeting in December, one year after submission of the report, to monitor progress against the recommendations. I plan to do the same thing in December 2001. I have indicated to the Permanent Secretary that, assuming progress is well advanced at the end of 2001, it may not be necessary to have another meeting. The Committee will have read that we set certain timescales against some of the recommendations. Two years was as far as we went, and hopefully two years after submission of the report those timescales will have been met.

Mr Todd

  7. If one reflects on the work of the Better Regulation Task Force on environmental regulation, its conclusion on the comparison with European regulation of a similar kind is rather less favourable than yours. The main criticisms were: first, a less proactive approach by British regulators in attempting to define the appropriate level of regulation in the first place; secondly, the inclusion of additional features and the implementation of regulation much earlier than other Member States. Have you reflected on that document and compared it with yours?
  (Mr Curry) Yes, I have. A number of the recommendations which come from the group chaired by Lord Haskins confirm our own and are similar to ours. We did not consider environmental schemes and controls. At our first meeting we debated the extent of our remit and decided that the environmental area - there are various environmental schemes, and it is a fairly complex area - ought to be subject to a separate study and we did not have time to delve deeply into it. Had we done so we might well have arrived at the same conclusion as Lord Haskins. However, that is an area that we have not studied.

  8. Your answer appears to be that there may be a cultural difference between the way in which we deal with the environmental regulation of farming and the way in which we choose to regulate other aspects?
  (Mr Curry) There may well be. I am not qualified to express a view on the environmental schemes and whether we are over-zealous in our interpretation of European environmental regulations or go ahead of other Member States in enforcing them. From our limited study of the implementation of IACS and other farm support systems in other Member States, we found that all were driven by the need to comply with and meet European auditor requirements. We also found that enforcement and the fear of disallowance led every Member State to apply the regulations as rigorously as possible. All farmers in every Member State believe that their government are over-zealous in implementing European rules.

  9. Does that imply that your group might have focused more time on whether preparatory work should have been done on the regulatory environment itself by the British Government to ensure that it was appropriate? As I believe you said in response to the Chairman, you accepted the basic regulatory framework as it was and asked how it was being applied. One argument would be that that was an opportunity to ask whether the regulatory framework was appropriate to the task and whether the group could have an influence in improving quality while being consistent with the overall objective.
  (Mr Curry) I do not want you to misinterpret what I said in answer to the Chairman. We did not accept that the regulatory framework built around every support system was not up for review. What we did not challenge was the support system itself. We accepted that the beef special premium, the suckler cow premium and various support systems would continue. We reviewed and challenged the way that those systems were put in place, how they were implemented and the regulatory framework which was built around them.

  10. Do you accept that your study on the international comparisons was fairly limited?
  (Mr Curry) Yes, it was very limited.

  11. You visited the Netherlands and popped over the border into the Republic of Ireland. Therefore, the physical scrutiny was limited?
  (Mr Curry) Yes.

  12. You looked at the forms that other Member States produced?
  (Mr Curry) Yes.

  13. That would have produced a fairly incomplete perspective?
  (Mr Curry) It was not a comprehensive review of how Member States implemented regulations; it was a quick look-see.

  14. Do you believe that such a study should be commissioned?
  (Mr Curry) I think that it would be helpful for a better understanding.

  15. Yet that was not one of your recommendations?
  (Mr Curry) We felt that we had sufficient anecdotal evidence, together with the forms that we surveyed from admittedly limited knowledge, to arrive at the conclusions that we did. I do not believe that a more detailed study would have led to substantially different conclusions in the group. It quickly became apparent that there were three key issues: first, a reduction in the number of forms; secondly, a reduction in the number of farm inspections; and, thirdly, the establishment of some appeal mechanism. If one strips away everything else one nails it down to those three issues. I do not believe that a trip round Europe would have resulted in any different conclusion.

  16. Is that not the typically UK-centric view that we have some issues to resolve which we shall do in our own way but have little to learn from the application of similar constraints by our European colleagues, because almost certainly they do it in a more sloppy, inefficient way?
  (Mr Curry) Had we followed what I believe to be the prevailing UK view we would have come to the conclusion that the British Government was more rigorous than any other in their implementation of EU regulations. That is certainly the prevailing view in the agricultural industry. From our admittedly limited interrogation of other Member States and information available to us, we did not confirm that view.

  17. I recognise the view that you express, but the alternative interpretation is that other EU states have a more intuitive and lighter touch in implementing the basic framework that is given to them by the European Union. We are not more rigorous but more heavy-handed. That is an alternative perspective where perhaps we have something to learn from how others choose to implement what is to be done, rather than take the rather patronising view that we are rigorous about it and others are sloppy?
  (Mr Curry) Certainly, we found that the approach in Ireland to IACS was simpler. The form-filling was much simpler than ours. We found that the Netherlands had already embarked on a computerised national cattle register in the early 1990s and were much further advanced in the data they held and their ability to help their industry through form-filling. There are individual examples where Member States have made greater progress in reducing the regulatory burden.

  18. Those were the only two countries you visited and you found two examples?
  (Mr Curry) Yes, but we had forms and other information provided by other Member States. The recommendations reflect the fact that we want to see a reduction in form-filling. We do not deny that there are examples of where that can be improved.

  19. You highlighted the Irish example. It has also been drawn to our attention that the sheer scale of form-filling in Ireland appears to be dramatically less than ours. Did you not feel that that implied the need for further study of how they arrived at that process, or did you accept the view, which was no doubt given to you by MAFF officials, that the Irish are pretty sloppy about the whole process and risk being disallowed on some of these claims?
  (Mr Curry) If one looks at the disallowance record of each Member State—

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