APPENDIX 12
Memorandum submitted by the National Farmers'
Union of England and Wales (G15)
INTRODUCTION
1. The NFU welcomes the opportunity to submit
evidence to the Committee in connection with its inquiry into
the role of DEFRA, one year after the new Department was established.
We have used the Committee's terms of reference as the structure
for our comments. We have sought to adhere to the Committee's
request for an overview on the direction the Department is taking,
and to keep our evidence as brief as possible. The Department's
responsibilities cover such a broad field, and it has been such
an eventful year on a number of policy fronts, that it is not
possible to attempt a comprehensive assessment of the Department's
performance across the board: we have naturally concentrated on
the Department's interface with the agriculture industry and the
farming community who we represent.
GENERAL BACKGROUND
2. Debate about the appropriate structure
of Government machine for agriculture, the environment and rural
issues has been ongoing over many years. Indeed as recently as
March 2000 when the Prime Minister launched an Action Plan for
Farming it was stated that he wanted to bring speculation about
the future of the Ministry of Agriculture to an end and emphasised
that MAFF would fulfil the task of implementing the strategy for
farming and food. By the time of the publication of the Labour
Party manifesto before the 2001 General Election there was a commitment
to create a "Department for Rural Affairs" to lead renewal
in rural areas. As DEFRA's Departmental Report 2002 rather coyly
remarks "the creation of DEFRA allowed for little formal
planning of the complex logistics of the merger" of former
MAFF with parts of former DETR, and some Home Office staff. In
short it is clear that there was little in the way of a detailed
blueprint for the design and functions of the new Department before
the election, and accordingly its construction and development
has created an impression of some haste and improvisation.
APPROPRIATENESS OF
DEFRA'S VISION
AND PROGRESS
TOWARDS IT
3. The new Department could hardly be said
to have had a flying start in life. Indeed it has had to face
serious internal problems for example relating to different structures
of staffing and pay amongst its civil servants, incompatible IT
systems etc. From the agricultural point of view the new Department
inherited a major crisis in the form of the worst outbreak of
foot and mouth disease (FMD) recorded anywhere in the world. Although
this disaster for farming had peaked in terms of daily cases before
the new Department came into being, nonetheless the sheer scale
of the outbreak, and the severe consequences for farming and for
the wider rural economy are still very real issues some seven
months after the last reported case. In these circumstances it
is not perhaps surprising that the diversion of the new Department's
attention and resources to tackling FMD has delayed some of the
development of the new Department. The establishment of aims and
objectives for the new Department has taken many months, commencing
with the first thoughts of the Secretary of State in June last
year, and followed by a consultation exercise in the autumn.
4. We support the Government's policy of
opening up Whitehall to the commercial realities of the world
which it oversees and regulates. We have therefore been disappointed
that more use has not been made of the opportunity of DEFRA's
creation to import into the new Department senior persons from
the commercial world with expertise relevant to the Department's
responsibilities. We note that this has been done to some extent,
for example senior IT posts, but believe there is scope for more.
5. The Secretary of State's vision for the
Department which appeared towards the end of 2001 is couched in
somewhat Arcadian prose. It is worth noting the original vision
statement which still appears on DEFRA's website states that "the
pursuit of sustainable development . . . is vital to achieving
this vision", whereas the prospectus document published by
the Department in March of this year Working for the Essentials
of Life adjusts this statement to the more ambitious line that
"Through the practices of sustainable development . . . we
will achieve our vision". This is perhaps symptomatic of
the Department's decision to place all its eggs in a basket of
"sustainable development" without apparently recognising
the potential conflict or inconsistency of its stated commitments.
For example, the Department rightly perceives the importance of
global and international objectives in relation to the environment
and climate change. Yet the delivery of the Department's objective
of promoting a "sustainable, competitive and safe food supply
chain which meets consumers' requirements" will require a
much more robust sponsorship and promotion of the economic sustainability
of British agriculture by DEFRA than has been apparent to date
in the light of the support given to their agricultural industries
by other countries amongst our competitors in Europe and the wider
world. This must be accompanied by the application of significantly
more resource to fund the achievement of the objective.
6. In assessing what would be required to
achieve its vision through the practice of sustainable development,
we question whether the Department has taken sufficient account
of the fact that many of the key resources such as land are largely
privately owned, and that there are existing and long-standing
rights in respect of other resources such as water. These considerations
should be more demonstrably integrated into the Department's approach.
7. The NFU welcomes the Department's commitment
to raise the status and profile of science within DEFRA to deal
with the Department's challenges. It is therefore right that the
Department has set in hand a fundamental review of the organisation
of science in DEFRA and has appointed a new Chief Scientific Adviser
to lead this process. We welcome the important statements made
by the Prime Minister in his speech to the Royal Society on May
23 2002 about the importance of making judgements on the basis
of scientifically evaluated facts, and that "environmentalism
is strongest when allied to hard science and empirical testing".
However to turn the Prime Minister's statement into reality will
require strong emphasis amongst DEFRA's science department and
the Chief Scientist on proper development of both European and
international policies. Already DEFRA's inability to secure review
and revision of the discredited science which underlies the application
of the EC Nitrate Directive to England shows that farmers face
unnecessary regulatory costs as DEFRA implements existing EU legislation.
8. Given the difficulties it faced from
the standing start, it is no surprise that the Department has
struggled to determine its aims and objectives in life and to
put the necessary structures in place to achieve them. Although
it must be right to have conducted this exercise in a transparent
and consultative manner, many of DEFRA's stakeholders have become
increasingly impatient for the Department to get on with the job
of tackling some extremely pressing difficulties within the Department's
remit, most notably in the agricultural sector. The Department
must now move on from infancy to a mature application of practical
management of its responsibilities. This will inevitably require
the provision of sufficient resource by DEFRA and equally the
provision of necessary financial resources by Treasury to enable
DEFRA and its related Executive Agencies and other associated
bodies to better meet their responsibilities.
DOES THE
DEPARTMENT GIVE
"PROPER WEIGHT"
TO EACH
OF FARMING,
FOOD, ENVIRONMENTAL
AND CONSERVATION
CONCERNS ?
9. We remain deeply concerned that DEFRA
is failing to give proper weight to the future of farming. DEFRA
is the sponsoring Government department for farming at a time
when farmers are in a long established financial depression. Moreover
DEFRA took over from MAFF the role as the primary Government department
for the management of the FMD outbreak. DEFRA naturally, and properly,
devoted substantial financial and staff resources to controlling
and eliminating the FMD outbreak. We welcome DEFRA's close contact
with the NFU at both national and local levels and the strenuous
efforts to secure a united approach to bringing the end of the
FMD outbreak. However, we remain deeply concerned that other farming
priorities which require Government action have not received the
attention they deserve.
10. The NFU is particularly concern over
the slow response from DEFRA, and Government as a whole, to the
recommendations of the Policy Commission on the Future of Farming
and Food. Some of the recommendations from the Commission's report
have made significant progress but too many of the more major
policy issues referred to in DEFRA consultation on "Sustainable
Food and Farming, Working Together" remain the subject of
slow moving consultation and decision-taking. No one can judge
the value of the strategy for sustainable farming to which the
Government has committed itself until these on-going processes,
and crucially the question of adequate funding for them, have
advanced much further.
11. We would argue that DEFRA's failure
to take steps to help farmers across its wide agenda leads to
it also running the danger of failing to deliver its food, environmental,
conservation and rural affairs concerns. Farming remains the core
of our food industry, our environment and our rural economy. We
find it ironic that policy tensions on agricultural issues between
former MAFF and former DETR often produced pressure within the
system for solutions which more effectively balanced the needs
of a competitive agriculture on the one hand with environmental
and other public policy objectives on the other than we perceive
happens now that the policy-making is housed under one roof.
12. The NFU continues to be very concerned
over DEFRA's implementation of its regulation of farming. DEFRA
quite rightly in Working for the Essential of Life undertakes
not to impose unnecessary regulations and to ensure that care
is taken on the economic consequences of regulation. The NFU and
farming community do not see that this has yet been turned fully
into operation. We remain concerned over "gold-plating",
characterised by a tendency to err excessively on the side of
caution apparently to be sure to escape infraction proceedings;
and over DEFRA's failure to review regulation, whether existing
or newly proposed, with stakeholders including the NFU. DEFRA
should place even greater emphasis in ensuring that its negotiators,
whether in world or EU discussions, fully understand the implications
of policy development on farmers and the importance of pressing
for new regulations to have the least adverse impact on farming.
13. Notwithstanding the huge pressures placed
on Ministers and officials in the Department by the FMD crisis,
in our view the Department continues to be under-resourced in
terms of its ministerial complement. In our view DTLR received
a more favourable complement of seven ministers from its creation
after the election last year than did DEFRA which received an
allocation of only five ministers to take on the responsibilities
inherited from MAFF, DETR, and the Home Office. This more generous
complement has been continued in the restructured arrangements
for transport, and for local government and the regions, announced
on May 29. We believe that there is a strong case for DEFRA to
be strengthened by the appointment of a food chain minister at
Minister of State level in the Commons, and that this would be
of material assistance in progressing towards the Department's
objectives for a sustainable farming industry.
14. The NFU has welcomed the establishment
of the Rural Payments Agency, and the opportunity that has been
taken to have a single cohesive unit for payments under the EU
CAP and other schemes. However it is a matter of regret that morale
in the RPA appears to be very low. For most farmers their only
direct interface with DEFRA is through the RPA, and the difficulties
and prolonged delays experienced in payments by the Agency have
inevitably tarnished the new Department's image with many of these
customers. Delays in payments under ERDP schemes are well-documented.
It is most important that the RPA swiftly overcomes IT problems,
clears backlogs in payments, and establishes a more positive relationship
with customers. We appreciate that management of the RPA is aware
of the need for this, but the sooner they can achieve it the better.
15. The NFU has examined the performance
of DEFRA at the regional level. We detect a number of problems
here. In general the Department's policy strategists are perceived
to have worked hard to establish the new Department at regional
level, in relation to the Government Offices of the various regions.
It has however been pointed out that in some cases senior regional
officials of DEFRA appear to spend a fair proportion of their
time on matters which are not directly related to DEFRA. Whilst
we see the importance of good working relations and other Government
Departments at regional level, the very broad remit of DEFRA's
responsibilities means that regional officials are hard put to
do justice in any depth to the Department's remit, let alone that
covered by other Departments.
16. It is perceived that there is some notable
confusion in the minds of officials themselves about their exact
role and how their responsibilities within DEFRA relate to the
rest of the Department and to other departments in the Government
Offices of the regions. It is has also been noted that in some
cases there appears to have been some tension between regional
DEFRA and regional Government Offices regarding lines of responsibility
and functions. These conditions have inevitably led to a somewhat
cautious attitude by officials who can appear very conscious of
demarcation lines, and frustration for customers arises when a
'pass the parcel' attitude is encountered. Stakeholders and customers
who had been promised that the new arrangements would provide
a more integrated, joined up approach, have too often had to share
officials' confusion, and there is a danger of disillusionment
with the young Department setting in.
17. In summary we believe that DEFRA has
made a well-intentioned but often under-resourced start to many
of its responsibilities, and that much work must be done to convince
stakeholders and customers of the Department's understanding of
their problems and of its commitment and ability to provide a
service at a level which will see them efficiently and effectively
addressed.
IMPACT OF
THE ROLE
AND INFLUENCE
OF THE
ENVIRONMENT PROTECTION
GROUP AND
THE WILDLIFE
AND COUNTRYSIDE
DIRECTORATE OF
THEIR TRANSFER
FROM FORMER
DETR
18. These groups brought with them to DEFRA
some issues which have a high profile, for example the implementation
of the new right of access to open country under the CRoW Act
2000, the introduction of Environmental Impact Analysis regulations,
and the Water Framework Directive. We perceive that in addition
ministers have tended to put most emphasis on the environmental
aspects of agriculture, perhaps to indicate a desire for an integrated
approach to the new Department's responsibility in the name of
sustainable development. The real test of a balanced approach
within the Department will come on such issues as cross-compliance
of environmental payments to farmers, and the extent to which
the needs of agriculture as a primary user industry will be recognised
in the bringing forward of the Water Bill.
THE DEPARTMENT'S
OBJECTIVES IN
PURSUING THE
"RURAL AFFAIRS
AGENDA"
19. DEFRA's Objective no 2 is "To enhance
opportunity and tackle social exclusion through promoting sustainable
rural areas with a dynamic and inclusive economy, strong rural
communities and fair access to services". Although some of
the powers and mechanisms for achieving that objective fall within
the DEFRA remit, the fact remains that much of it is delivered
through the policies and programmes of other departments of state—for
example DTI, and what was DTLR but now further separated (from
the original DETR empire) into the Department of Transport, and
the Office of the Deputy Prime Minister covering such matters
as local government, housing and planning. We are not convinced
that DEFRA has been able to establish the "clout" for
rural issues that we believe a Department with formal responsibility
for Rural Affairs should have. What influence, for example, has
DEFRA had over policy for the future of rural post offices?
20. The Countryside Agency's recent report
on progress with "rural proofing" did not give DEFRA
a good assessment on embedding rural proofing in policy making
procedures, or on promoting proofing checklists, or on setting
and monitoring rural targets or on enhancing rural awareness through
staff training. DEFRA should be leading the way—not falling
behind other departments which are notorious for their insensitivity
to the rural dimension. We welcome the expression of ministerial
regret for this position in the Lords debate on rural policy on
April 30, and in principle we welcome the development of a new
classification of "urban" and "rural" based
more on land use, settlement patterns and economic activity. However
do not find the minister's statement in the debate very reassuring
that "we shall then have a suite of definitions on which
we can draw as appropriate but as understood for various different
purposes". It is of concern that the new classification is
apparently at least 18 months away, and even then it may not be
so helpful in more clearly defining "rural" for policy
purposes given that this is a long-standing and already well-researched
issue.
21. DEFRA has the potential to take a positive
lead on rural affairs. For a variety of historic, cultural, resource,
managerial and not least political reasons it runs the risk of
failing and becoming inward-looking. For the sake of farming and
our unique countryside this must not be allowed to happen.
May 2002
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