Select Committee on Environment, Food and Rural Affairs Minutes of Evidence

Examination of Witness (Questions 119 - 139)




  119. Mr Stevenson, you are the policy and legal director of Compassion in World Farming?

  (Mr Stevenson) Political and legal director.

  120. That is what I have down here, as a matter of fact. And your concerns are animal welfare?
  (Mr Stevenson) That is correct.

  121. And you state that "the decoupled farm income payment will be conditional on the respect of statutory animal health and welfare standards", and the Commission welcomes that. You then go on to say that you would like to see cross-compliance at a higher level than current welfare legislation. Would you like to explain what you mean by that and how you would justify it in the light of the constant argument about the international competitive position of British farmers?
  (Mr Stevenson) Can I start by saying that I welcome really all the various proposals that the Commission have made in their paper about animal welfare, both the general statement that farm animal welfare should be fully integrated into the CAP—to me that is a huge step forward—but also the three specific areas where they are suggesting it should be taken into account, of which as you rightly say the first one is that anyone receiving direct payments, coupled or uncoupled, there should be a cross-compliance requirement for. Chairman, I am a bit torn on this myself. If all that were achieved is that there would be a cross-compliance requirement as regards animal welfare in terms of what is statutory and what is legislation, of course that would be a big step forward; it would help enforcement and monitoring considerably. The reason I would like to explore the possibility of going further is twofold: firstly, there are certain areas where there is very little legislation—indeed, no species specific legislation. That is if one takes cattle, both beef and dairy, and sheep, neither at UK nor at EU level, either as detailed requirements in the way that we have for pigs, laying hens and calves. There are, of course, the broad provisions of the 1968 Agricultural (Miscellaneous Provisions) Act and certain broad provisions of the 2000 Regulations which would apply to any animal, but since one would have to ask what one is cross-complying with, one might have to for cattle and sheep create something that is at the moment not there. Now, we may decide that should be Council of Europe recommendations or DEFRA codes. So firstly, in some places, there just is not any detailed law. Secondly, and I will try to indicate one example, I would be unhappy, I think many people would, to see CAP payments, not necessarily animal welfare ones but agri-environment ones, which very probably inadvertently are leading to a deterioration in animal welfare standards. I gave one example in my submission which I noticed in the farming press at the beginning of the year, and I cannot give exact details but it seemed that a particular farmer, in order to benefit perfectly properly from agri-environment payments possibly to make more land available for an agri environment scheme, had brought his sheep, previously reared in the normal way outdoors, indoors and was rearing them throughout their lives indoors on concentrates, and I think most people would accept that is not a good way of rearing sheep. Inadvertently the CAP had encouraged that, it would appear, and therefore, again, I would like to see some standards for cross-compliance which avoided that danger of animal welfare standards being damaged by a particular scheme.

  122. The instrument of cross-compliance in the Commission's proposal is the farm audit.
  (Mr Stevenson) Yes.

  123. What needs to be done to the farm audit to make it into an efficient instrument of compliance, and how would you respond to that old British complaint that we do more of it than anybody else and that, in practice, there will be differential compliance and, however much the Commission throws the book at people who do not comply, it takes an awful long time for the book to land?
  (Mr Stevenson) Firstly I think the farm audit scheme, at least as envisaged in the Commission paper, is meant to in some ways simplify the monitoring and controls over a whole range of areas, not just animal welfare but environment, food safety and occupational health and safety, and if done well could bring under one auditing scheme a range of monitoring and controls which are burdensome to farmers. It could, and I would welcome this, simplify things. Going on to your other point that British farmers may find themselves more rigorously audited and monitored than others, clearly this is a problem. We do a lot of work; we put a lot of pressure on the Commission and the Member States to try and get better enforcement of welfare standards in all fifteen countries, not just on farm but transport and slaughter. It is a very slow and at times depressing process but I do think slowly things are happening in other countries. I do not think we should despair long term. I think there is a significant shift including in southern Europe into taking these issues more seriously, but there is a long way still to go.

  124. Do you regard membership of an assurance scheme as evidence of adequate compliance with animal welfare conditions? There is a big drive to get people to sign up to an assurance scheme. Do you believe that constitutes sufficient evidence?
  (Mr Stevenson) The short answer is no and I will try to elaborate on this. I am aware that one of the Commission's proposals is that there should be in Pillar II a new food quality chapter which I welcome where one of the ways in which farmers could be helped is when they are adhering to a quality assurance scheme they would receive some sort of payment; also there would be financial assistance for the promotion of such schemes. In that wider context, if we just step back for a moment, I think I would feel and I think many people would agree that over the last twelve years, both in this country and in the EU as a whole, significant strides to better animal welfare have been made. I think we also might agree, although probably disagreeing about the details, that there is a fair way still to go—perhaps we are halfway there. Therefore, if we are looking at that overall strategy about how one drives welfare standards upwards, I think quality assurance schemes have got a vital role to play—really vital. At the moment, though, if you actually analyse the terms of most of the schemes operating in this country, they really are not good on welfare. I am disappointed that there is a significant gap between the welfare rhetoric often in the introduction in which they are saying—sometimes directly sometimes implying—"Look, public, you can trust us; we are assuring good welfare", and yet when one analyses those schemes often they are doing little more, no more, than saying to the members, "You must obey the law and you must observe DEFRA codes". Well, yes, of course they must—all farmers even outside the assurance scheme must do that. If the assurance schemes are playing a role, just as cross-compliance under the CAP might, in really making sure the law is complied with, that is of value, but I am very disappointed with the standards because they imply they are ensuring good welfare but if you look at the schemes, just to give some examples of the kind of things that are allowed, pigs—and I am talking now about pigs bred for their meat or other breeding sows—can be kept indoors throughout their lives without any straw; they can be tail docked; teeth clipped; the farrowing crate can be used for sows. If you look at laying hens the battery cage can be used under the assurance scheme. If you look at the meat chicken, the broiler scheme, they permit a stocking density way above what science says you should not go beyond. The schemes allow the use of the very fast growing broilers where one gets such a high incidence of leg disorders and heart failure; they allow the use of high yielding dairy cows where again, just a few days ago, it was revealed that every year about 70 per cent of dairy cows are possibly going lame; 45-50 per cent get mastitis, yet those high yielding breeds are used. There are restrictive feeding regimes for breeding sows and broiler breeders which lead, according to science, to chronic long-term hunger, so there is a range which I think do not from my point of view constitute good welfare and which are permitted by the schemes, and I believe I am accurate. Indeed, we published a report earlier this year, Compassion in World Farming Trust, analysing these schemes and summarising this by saying that quality assurance schemes could play a very important role in driving welfare standards forward and upward, but at present they are failing to do so because of low standards.

Mr Lepper

  125. You have already mentioned some of the thirteen key animal welfare determinants that you say a farmer should satisfy or adhere to in order to receive payments. From your point of view, is that a definitive list? Is it susceptible to change over the years? How did you arrive at those thirteen? You have given us some examples.
  (Mr Stevenson) Of course I would imagine this is a list one can keep thinking about. The reason I produced it was—and can I just clarify, we have moved through your question from that first area the Commission looked at which is saying, "Look, if you are receiving direct payments there is going to be a cross-compliance" to looking at the two other areas which I am very interested in, one of which is the new "meeting standards" chapter where farmers would get some payment if they met certain standards—and, again, Chairman, I am aware there is a big question about what those standards are. Is it just the law or something higher than the law, and I know you may challenge me again as to why I would want it to go beyond the statutory requirement, and indeed those thirteen determinants that you refer to I set out when looking at the third of the Commission's proposals, which is that animal welfare should be brought into the agri environment chapter. This was yet another tier of possible payments which I think is very much in the Commission's mind, and certainly in my mind, and designed for farmers who have gone way beyond the statutory minimum really to the very best kind of schemes. No, of course, this is not meant to be a set-in-stone list. I was trying to say that I applaud what the Commission has suggested but we all need to begin to think what standards are we talking about. I could have taken the approach of saying well, for pigs I believe these are the standards; for laying hens these are the standards and so on, and I felt this would be far too detailed at this point in the debate and that one ought to look at the determinants, the principles, and if one agreed those principles one said, "Right, bearing those in mind, what are the kind of standards one would set?", but if I can give some examples, looking at specific species for this third tier of payments, the very best—which go, you could say, very considerably beyond the statutory minimum. Imagine, for example, if you look at pigs, one would be looking at a system where the animals were free range—not just the breeding sows which is becoming increasingly commonplace but the pigs which are reared for their meat, because remember in many free range systems the sows are outdoors but as soon as they are weaned the piglets are brought indoors. I would be looking at a system where they are kept free range, or if they were indoors one would be looking to see that there is really no tooth clipping, no tail docking, no form of mutilation, a good fairly deep bed of straw, generous space allowances, fresh air, daylight—the very best of indoor systems. If one was looking at broiler chickens I would only be looking for that highest tier of payments for really good free range systems. Interestingly, Chairman, you asked me earlier about the discrepancy between UK and continental standards. We have recently been to about six Member States in addition to the UK looking at free range broilers, at examples of things that are actually on the ground, working and are commercially successful. I have to say the best we found were in Portugal and France. So sometimes other Member States, even the ones we do not associate with good welfare, can do really good systems. Those are the kind of systems that would fall within those welfare determinants. They were not just outdoors but they had a lot of tree cover which is what chickens really like; they were in very small groups—about 300; the indoor accommodation was good—they were only being stocked at about 8 or 9 birds per square metre. This was the very highest of standards for that tier.

  126. From what you have said, you feel that those standards are standards that would be acceptable as the highest level of standards throughout the European Union, not just throughout the European Commission zone?
  (Mr Stevenson) Yes. Clearly there would have to be the same standards in all Member States.

  127. And you envisage, do you, farmers who meet those standards being compensated, as it were, through the rural development regulation?
  (Mr Stevenson) Yes. I believe that when farmers are achieving those highest of standards, the addition of animal welfare to the agri environment chapter, they should be receiving some real reward that helps with the capital costs of change and possibly at least for a limited period with some of the extra running costs.

  128. And the meat, let's say, from the pigs would still be on sale in the market place at a similar price to other pig meat which did not meet the same standards?
  (Mr Stevenson) Well, in some but not all cases those higher standards would lead to higher production costs and therefore the retail price would have to be higher, and therefore it may never reach a mass market, but I think it is important to encourage. I am always torn between what I ideally would like and what I believe is realistic, and I recognise that for the foreseeable future there will continue to be some fairly intensive livestock rearing but I would like to see schemes like this encourage a greater take-up of the best of standards, and it can be done. Just to give one example where there are discrepancies—and, again, interestingly we do not come out the better in this one—I suspect probably no more than 1 per cent of British broilers are kept free range whereas in the French broiler industry, which is a similar size, 15-20 per cent are free range, and often very good free range. A scheme like this could help us and other countries to create a larger proportion of our broiler or pig industry in really the best of standards.

  129. Generally, people when they are buying their chicken or their eggs or pork who are concerned about these issues of animal welfare and high standards are willing to pay a bit more. Why should we, the taxpayers, be compensating farmers for producing meat of that high standard when people are quite prepared to pay for it in the market place?
  (Mr Stevenson) I suspect neither here or in other Member States are enough people willing. If by giving some financial help under the CAP to the farmer one can bring the retail price down because some of the extra costs will be met through the CAP then a larger proportion of the public may be drawn to buying meat reaching these high standards. I accept that your question still remains, "Why should we pay for it?", and I think in a sense there are two answers to that. I think the timing may be difficult to see but I think, however slowly and unsteadily, the CAP is going to shift from Pillar 1 type subsidies to Pillar 2 if only because it is being pushed in that direction by the WTO, and therefore if the EU, including ourselves, wants to continue helping farmers and they have to do it under more Pillar 2 type schemes, then animal welfare seems a very legitimate thing to do. But responding to the Chairman, I think Chairman you rightly said that farmers are under enormous pressure at this point. I think the pressure is partly coming internally from supermarkets who ever more want to drive down the farm gate price and I totally sympathise with farmers' predicament there, and the pressures are coming more globally from the WTO which is in effect saying, "Fine if you want to have higher animal welfare standards but you cannot in any way restrict the import of cheaper welfare products which could undermine our farmers". So if as a society we are saying we want better farm animal welfare, we have to devise a strategy which makes that better welfare economically viable. I have no desire to see farmers, British or European, go out of business. I think that strategy has a number of limbs, but I think one important limb is support from the CAP. I do not think support from the CAP can solve all the problems. It is one of half a dozen strategies which can help our society create decent animal welfare standards in an economically viable manner.

Mr Jack

  130. One of the things I am struggling with is that, with your emphasis on bringing all species within the proposals to take animal welfare into further thinking about the development of the CAP, currently hens and pigs and calves do not get any money and one of the theses which the mid-term reform is supposed to be addressing is the decoupling of payments associated with production. Now, some outside the EU might look at payments for higher welfare standards as a production aid because effectively what you are saying is to achieve the standards that you have delineated requires expenditure or less income than a more intensive system. How would we cope with that if we were to come under attack from outside for bringing into the CAP payment structure species which currently do not receive any money?
  (Mr Stevenson) I first ought to clarify that the first of these three ways in which the Commission is trying to bring animal welfare in cross-compliance is only for people receiving direct payments, coupled or uncoupled, and therefore in practice one is not looking at pigs and poultry there but more beef, dairy and sheep. But with the other two ways, the meeting standards and these very highest of standards that I have just been talking about, you are quite right. I think what the Commission has in mind and certainly what I would want to see is pigs and poultry, which is after all where many of the intensive problems come, being brought in and then it would be very much pig and poultry farmers who would benefit from that. To try and answer your point, yes, we could clearly come under attack from our WTO partners that we are giving production-related aid. All I can say to that is that in the EU's formal negotiating brief for the current on-going WTO round, they have proposed three ways of trying to address the damage being done by WTO to animal welfare in EU farms, one of which is a recognition that animal welfare payments be brought in the green box—ie, that they are WTO acceptable. So I think the EU is trying to address this.

  131. One of the things in your evidence that you say you fully support is the Commission's statement, "Animal welfare concerns must be fully integrated within the CAP". I am still struggling, following the line of questioning of colleagues, to understand—notwithstanding your own I think quite optimistic hope that there could be some (a) growing appreciation within the EU of animal welfare standards as an issue but also (b) still a very different appreciation of what this concept of animal welfare means—how we are going to get some kind of uniform standard or, if you like, baseline from which you could then build the hierarchy of conditions, because you have described your thirteen, if you like, Stevenson ideal circumstances, but this term "animal welfare concerns must be fully integrated" is not exactly a precision definition of saying, "We will attempt to define species by species some minimum standards, notwithstanding what we already have in terms of our rules, which will be recognised as an improvement on what we already have in welfare of the way that animals are reared for human consumption or their products for human use", and then on top of that we might have a hierarchy of things we would like to see happen. I struggle to understand how this is going to be defined and negotiated. Have you had some comfort from somebody in the Commission that this situation which has so far eluded us can be achieved?
  (Mr Stevenson) Certainly when I have talked to the principal official in the Commission dealing with this the Commission is clearly very positive about this, and that comes through from their paper. Animal welfare is referred to on many occasions, not just a couple of times. Again, can I just reiterate that these thirteen what I call animal welfare determinants were suggestions for that very highest tier, where it is absolutely clear that what the Commission has in mind is that these are payments for people going significantly beyond legislative standards.

  132. How do we define the baseline, because from that everything else would follow? How can you get some kind of universal appreciation of what is a good standard for animal welfare which, by definition, must be an improvement on what we have at the moment?
  (Mr Stevenson) I think clearly, like any of the animal welfare directives, they would have to be negotiated. I am just trying to set the ball rolling with some preliminary thinking. These determinants would have to be negotiated and I recognise those negotiations will be difficult because there are different cultural values on animal welfare between the Member States, but hopefully out of that negotiation would come some agreement on what sort of standards we are talking about. Again, things have moved on in Europe. If I can give two examples, last year a pigs directive was agreed when, in fact, the southern countries had quite enough votes to block it if they had wanted to, and that directive does not just ban sow stalls but requires all pigs to have a certain amount of straw or similar manipulable material; it brings in a much tighter ban on routine tail docking than before—this was agreed probably with no great joy but nonetheless by countries like France. I think Spain did vote against it but on their own they did not have enough votes to do anything about it. Just moving off on-farm issues for a moment, at the Agricultural Council meeting in September nine of the fifteen Member States—and we were just one out of nine—voted to say there should be a maximum limit on animal transport for slaughter or fattening of eight hours or 500 kms. Things are moving, and I am not saying that the fifteen Member States would somehow simply just rubber-stamp my thirteen determinants, but I am sure eventually something could be negotiated. Going back to the Chairman's very first question, of course I try to say what I would at the best and ideally like but let me be clear, in terms of political reality, going to the first of the things the Commission proposes, the cross-compliance, it will end up as you suggested—that the cross-compliance will simply be with the law—whatever the law might be at a particular point. If I am being honest, I wish it would go beyond that. If you look at the middle of the things they talked about, this meeting standards chapter where you would specifically get a payment to help you meet new statutory requirements, again it may well be that the political reality is that you will not have to go beyond the legal requirement. Now, I have indicated in the paper they are nothing like as demanding as the thirteen determinants and I feel you should go a bit beyond it, and I elaborate on that. I think it is only with the last of them, this bringing animal welfare into the agri environment chapter where I brought in these thirteen very high standard determinants, where clearly a farmer to get that payment would have to go way beyond the legislative requirement because that is the whole point of this extra payment—it is for people going significantly beyond the law. I recognise, however, that with the first two I might struggle in terms of political reality to see it going beyond the requirement to adhere to the law.

Mr Borrow

  133. I want to come back to this idea of payments for improved animal welfare standards. I can understand the theory of it and I understand there is a demand out there, because it is quite clearly there now, where people are prepared to pay a premium for agricultural animal products if they can be assured that those animals have been brought up to certain standards. If we have an EU scheme using the reformed CAP to give extra payments to farmers to enhance the animal welfare conditions, that will have the effect maybe of reducing the price that these premium products will come to the market at, and therefore expand the number of people who could afford to pay the premium. Am I right in thinking that that is the assumption, rather than bringing animal welfare products to the market at the same price as those products where animal welfare has not been a big issue?
  (Mr Stevenson) Sorry—I do not know if I followed you correctly. Yes, these support payments would, in effect, mean that the retail price could be lower than otherwise because the extra production cost would be in part met by the consumer but in part by these payments. I am hoping because the price can come down that these will move away from being just niche products for a few people who choose to pay that extra and cover wider availability. They may still not be for the mass market: they still may be at a higher price than the factory farmer.

  134. Because there is an issue in addition to the issue around the WTO and whether this is supporting production which I think is an issue for politicians, and that is the majority of poor people in Europe will not pay the extra for a premium product. Whatever their concerns about animal welfare, if the poor people are seeking to feed a family, they will go for the cheapest product.
  (Mr Stevenson) Yes.

  135. All the statistics and information show that to be the case and therefore this is an issue around the CAP reform for politicians. So is it right that taxpayers' money, including taxpayers' money from poor families, should be used to subsidise food that is brought principally by better off or more affluent people who have the financial resources to care about animal welfare and, in doing that, pay the extra? I think that is the real dilemma that politicians face, because unless we can bring the price of meat that is produced by good animal welfare to a price that everybody can afford, we end up subsidising that product for the better off at the price of the poor?
  (Mr Stevenson) I would hope that in a variety of ways, including very specifically through the CAP support, the meat and eggs coming from higher welfare animals could be brought within the reach of everybody so that, as I said earlier, these would no longer be just for a niche market but would have a wider availability. I have to say, if I look at our own supporters, the people who care about having decent farm animal welfare standards are not only the people who can afford it. They are not just the wealthier consumers but also very much the poorer people who would probably very much welcome it if the price of high welfare meat and eggs could be brought down within their reach. So this should not become just subsidising the tastes of the better-off consumer, but I recognise there is a important question for politicians. As a society, both British and European, if we want decent standards of animal welfare, then given the pressures from supermarkets and given these huge pressures from WTO, we have to devise a strategy about how we can make that happen of which I think these payments are one—but only one—part.

  136. Moving on, one of the things the Commission is looking at is to reinforce the conditions and controls into which export subsidies for live animals can be granted, and obviously that is something that is of great importance. How do you think these conditions can be improved?
  (Mr Stevenson) Firstly, can I make clear in terms of live animals the export refunds are available only on the export of live cattle, and only when they go to third countries. The UK itself is not involved in that trade; these animals are mainly coming from Germany, the Republic of Ireland, and France. The figures exported each year vary but they are in the range of 250,000 live cattle a year. The amount of subsidies given vary year by year; they have swung in the last few years from between 90 million and 290 million euro but maybe averaging out round about 100 million euro a year, so it is a huge subsidy. The fact that this is immensely cruel live trade has been documented time and again. The suffering happens both during the long journeys, then at unloading at journey's end, then at the onward transportation from unloading to the slaughterhouse, and then at the slaughterhouse, and I could go into more detail on the cruelty if you wanted me to do so. Having praised the Commission, one area we are very disappointed is that they have not come out and said, "Look, export refunds on live cattle exports should just be abolished". This is not a particularly outrageous position. In October just a few weeks ago the European Parliament for the second year running when considering next year's budget said that export refunds on live cattle exports should be abolished. A number of Member States want to see them go but there is not yet a sufficient majority. If they are not to be abolished, of course I want improved controls. The Commission have had in force since 1998 a regulation trying to in theory say that you do not get your export refund if you do not maintain high welfare standards, not just during the bit of the journey within the EU but for the whole of the journey. It is in practice almost unenforceable. Commission's own figures show that in one 21-month period towards the end of the 1990s they withdrew the export refunds in respect of just over 3,000 cattle, and during this period over 500,000 were exported. I do not believe for one minute that only 3,000 of them were transported in very poor conditions so that scheme is not working at the moment to raise standards. If standards are to be raised then some of the things we have suggested are that it should be made clear, because at the moment what the regulation says is that the welfare during transport directive applies all the way through to arrival in the third country. The first point we believe is that it should be made clear that that includes not just the journey but the unloading; some of the worst problems happen during unloading. For example, one EU vet—and I do not mean an official vet but from an animal welfare organisation—saw the unloading of EU cattle in Egypt about eighteen months ago, and apart from sheer brutal beating some of the animals were falling off the gangway into the sea and drowning, so bringing unloading into it is still a very grey area but I think it would help. Secondly there needs to be a more significant proportion of the consignments arriving in third countries which must be inspected. At the moment under the Commission regulation which tries to control it, it is actually very few, and I think that should be significantly increased—indeed, I would like them all to be inspected. Thirdly, these inspections in third countries are done usually not by EU officials but by a local approved supervisory agency. Quite frankly, my impression is they are not doing their job thoroughly and they should be regularly inspected by the Commission just as the Member States are to see if they are doing the job properly. Fourthly, I believe that the export refunds should only be available if the animal is going to be slaughtered in a slaughterhouse which adheres to the standards of EU welfare at slaughter legislation, because what goes on in these slaughterhouse is terrible. I am not referring to the religious slaughter—I do not like religious slaughter but I recognise it is permitted by EU law so I am not entitled to complain about it in third countries—but the pre slaughter handling is appalling. For example, in one case we saw EU cattle in a Lebanese abattoir and the way of bringing the animal to the ground preparing it for throat cutting was for two men to lie across the animal's back and bounce on it till it fell to the ground. Recently we saw cattle being, while still fully conscious, hung upside down from a rail by one leg and then having their throat cut. Now, for such a heavy animal to be hung upside down by one leg is painful and frightening, so I would like to see a requirement that the slaughterhouses used adhere to EU standards. But above all I would like to see export refunds abolished. I think that is unacceptable. Going back to the point about the decisions of how public money is being used, I do not think public money should be used to foster and encourage a trade which regularly is inflicting great suffering on animals.

  137. So, if I read your views correctly, you would prefer it to be stopped altogether?
  (Mr Stevenson) Yes.

  138. And if it is not stopped you have very little faith that there is any real way in which new regulations can be brought in by the EU that would be effective because of the difficulties of enforcement?
  (Mr Stevenson) Yes. Though I have suggested four ways in which they could be strengthened, I do not have a lot of faith it is going to make all that much difference.

  139. Finally, the European Commission have come up with four possible reforms for the dairy sector. I wonder if you had any views on the four reforms?
  (Mr Stevenson) I am sorry, I have to confess not to feeling expert on that particular point and I do not want to mislead the Committee, but I would like to make a broad statement as regards the dairy sector. I think it has been generally agreed by many over the years that the quota system has encouraged intensification. It has made it attractive for farmers to try and maximise yields per cow leading to high levels of lameness, mastitis and other problems, and I think, therefore, however the dairy sector goes forward, again on this principle that animal welfare should be integrated into the CAP, I would like the animal welfare side to be looked at in the way payments are made. Again, I would like some cross-compliance and I would like it to be a requirement, whatever shape or form this takes, that payments are dependent on the fact that you implement a veterinary health plan, that you have agreed as a farmer with your veterinary surgeon to reduce the incidence of lameness and mastitis and to achieve a high health and welfare status in the herd. If I could pick up on a point you raised earlier about my pleasure concerning this principle that animal welfare should be fully integrated into the CAP, apart from the three specifics we have discussed, one of the problems over many years is that when new CAP policies or subsidies are formulated I do not think anybody has until very recently turned their minds to what would be the impact on animal welfare, and will there be, very possibly, inadvertently an animal welfare downside, and I would like to see a requirement that, before a new policy or subsidy is introduced, there is an animal welfare impact assessment: that we do not suddenly find we have a problem that we do not really want but that we have encouraged through a particular subsidy.

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