APPENDIX 5
Memorandum submitted by the RSPCA (H5)
EXECUTIVE SUMMARY
The CAP has to date not encouraged the promotion
of good animal welfare farming practices under its incentive programmes.
Some of the payments under Pillar I linked to production could
conversely encourage a shift towards more intensive farming methods.
The Commission proposals in the MTR are a radical and brave step
to address this problem and place animal welfare firmly at the
centre of European farming. The RSPCA welcome the proposal to
delink subsidies from production and the coupling of all payments
to baseline legislative standards. The RSPCA also believe that
the addition of four new areas into the RDR to promote better
animal welfare will set up new incentive schemes for producers
to meet higher standards than the baseline ones. Finally it sees
the proposal to compensate producers to meet animal welfare standards
that are higher than in third countries as being consistent with
its WTO AoA strategy and ensure that European farmers can continue
to meet consumer demands for improvements in the ways that animals
are reared and farmed.
1. The RSPCA welcomes the opportunity to
give evidence to the Environment, Food and Rural Affairs Committee
on the mid-term review of the CAP. The Society feels that the
mid-term review comes at a critical time for animal welfare. Animal
welfare was not widely discussed in the 1999 Agenda 2000 reform.
However consideration of animal welfare has changed in two important
ways since Agenda 2000: the legal position under the Treaty of
Rome changed in 1999 when the EU adopted a Protocol on animal
welfare under the Treaty of Amsterdam, which has strengthened
the case for improving animal welfare measures under the CAP.
Secondly, in November 2001 the Doha Round was launched under the
World Trade Organisation, which has a direct link into CAP reform.
The Round has pledged to phase out export subsidies, improve market
access and take account of non-trade concerns such as animal welfare.
The EU has proposed various measures at the WTO agriculture negotiations
to ensure that measures to support and encourage animal welfare
can be taken within existing trade rules.
These include the proposal to give payments
to producers to compensate them for higher costs involved in producing
products to welfare standards higher than in third countries.
2. The MTR also comes at a critical time
for British agriculture, with the expected publication of DEFRA's
strategy on the future for British farming following the Curry,
Anderson and Royal Society reports. The Society has drawn up its
own position paper Into the fold: bringing animal welfare into
the CAP, which details how it sees animal welfare being developed
and encouraged under the CAP payment scheme. Under Pillar I payments,
the RSPCA believes that the system of giving direct headage payments
or market support payments could encourage animal welfare problems.
For instance in the dairy sector, linking the payment of subsidies
to the amount of milk produced under the regime has encouraged
increasing productivity from individual cows, despite a reduction
in stocking rates in the 1980s. The system offers few inducements
to reverse this process, which may lead to welfare issues such
as increased incidence of mastitis, lameness infertility or premature
culling. At the same time there were no direct links between Pillar
I payments and welfare standards. This connection should be made.
Under Pillar II payments, animal welfare was only mentioned briefly
as an objective under the Rural Development Regulation and there
were no incentives under the RDR to promote higher levels of animal
welfare.
3. The RSPCA welcomes most of the recommendations
on animal welfare in the Commission proposal. The Society believes
that these recommendations, if agreed, rigorously defined and
properly enforced, will go a long way to ensuring that animal
welfare is centrally positioned within European farming and different
levels of animal standards developed. The Society believes that
the proposal to decouple payments from production levels would
turn the CAP regime away from encouraging intensification. The
proposal to include four new areas on animal welfare to the Pillar
II payments would finally place incentives to encourage producers
to farm on a more sustainable and welfare friendly level.
4. The proposal to decouple payments from
production is supported. Decoupling would also be put the EU into
a strong position at the AoA negotiations, as all existing payments
could theoretically be moved from the Blue to the Green box. This
would put the EU in to a stronger negotiating position for supporting
its position on non-trade concerns, such as animal welfare. However,
there are concerns on the implementation of the payment and how
it would be calculated. For instance, farmers could stock to high
levels of animals in the year that has been chosen as the benchmark
year for this payment, and measures would have to be taken to
ensure that this does not occur. It is also a concern that the
dairy payments would not be included until the Agenda 2000 reforms
have been implemented, as this would see reform of the dairy regime
postponed until 2005.
5. A wider cross compliance mechanism is
supported by the RSPCA as this would, for the first time, ensure
that all CAP payments are conditional on meeting baseline welfare
requirements. The RSPCA has proposed a three tier pyramid system
of incorporating animal welfare into the CAP. The basic standard
would be the minimum legislative standards as recognised in this
cross compliance mechanism. Baseline legislation is in force for
veal calves, laying hens, pigs and transportation of live animals,
and there are laws regulating antibiotics and use of hormones
such as BST[9].
New laws in other farming sectors, such as dairy cattle, beef
cattle, ducks and geese could be agreed in the next decade. Until
this occurs, it is recommended that the Council of Europe Recommendations
on these species are followed. All member states are members of
the Council of Europe and have agreed to these Recommendations.
These would form the base of the pyramid and would under cross-compliance
payments be made mandatory for all CAP payments under Pillar I.
These requirements would solve the anomaly of a farmer receiving
CAP support payments even if he was being prosecuted for non-compliance
with welfare standards. The aim of the higher levels would be
the promotion of positive action to create a more sustainable
farming process. Incentives to meet these levels are discussed
below under the RDR scheme.
6. As the voluntary cross compliance mechanisms
have not been extensively taken up after the Agenda 2000 reforms,
the RSPCA agrees that mandatory cross compliance should be enforced.
The introduction of mandatory cross compliance would be consistent
with the recommendations of the Curry report that stated that
the small minority of "rogue" producers who operate
below the welfare codes should be pushed out of the market (p
100 Farming and Food: a sustainable future). The RSPCA
believes that these cross compliance conditions would meet the
test of balancing commercial considerations with animal welfare
ones, as they are merely implementing baseline legislation. This
would also nullify the issues of competitiveness with other EU
member states.
7. The RSPCA welcome the Commission proposals
to widen the remit of the conditions and incentives under Pillar
II. Creating the RDR under Regulation 1257/1999 in an attempt
to re-position the CAP from delivering production targets to enhancing
rural environments was one of the main achievements of Agenda
2000. However, although the present RDR does include animal welfare
as an objective in five of its chapters, RSPCA research shows
that the animal welfare issues have failed to be adequately promoted
or funded. In the UK the Rural Development Plans (RDPs) in the
four devolved administrations shows animal welfare has been highlighted
as a priority in two of the four areas. Only in Wales have specific
measures encouraged provisions to improve animal welfare in all
four of the areas where subsidies could be given (support for
farm holdings, training, marketing and rural area promotion).
8. Under-funding is also a problem, both
of animal welfare objectives under the RDR and of the RDR itself.
The budget for the RDPs for the four areas of the UK up to 2006
show that only 16 per cent of the total English budget and 2.55
per cent of the Welsh will be used for the issues outlined above
that could benefit animal welfare. For instance, in the year 2001-02,
£2 million has been set aside for training in England under
the RDR[10].
The majority of the budget is used in agri-environment schemes
and Less Favoured Areas neither of which mention animal welfare
as an objective at present though the Commission has proposed
that animal welfare be integrated into the agri-environment scheme
under its MTR proposals.
9. The RSPCA welcomes the proposal to encourage
take up of assurance schemes under the RDR. This proposal is also
consistent with the recommendations from the Curry Commission
(p 41 Farming and Food: a sustainable future) but there
are a number of unanswered questions. In particular, the scope
of payment: is the scheme for existing assurance members or only
new ones, in which case the existing one would be penalised even
though they had operated the higher standards for longer. The
RSPCA recognises that the welfare outcome of an assurance scheme
is dependent on the level and specificity of standards and the
rigour and consistency of enforcement. RSPCA defines assurance
schemes as those promoting higher standards of welfare rather
than those that have criteria low enough to allow all producers
to participate. The incentives for assurance schemes would, under
this parameter, provide the higher level of animal welfare standards
in European farming. A framework to ensure that such payments
would only go to encouraging these higher standards has been drafted
by the RSPCA and includes ensuring that the scheme is transparent,
has standards that cover all stages of the animals' lives and
is independently audited. The RSPCA's Freedom Food scheme is seen
as an assurance scheme that fits this definition and now has standards
operating in eight sectors, including beef and dairy cattle and
sheep.
10. The RSPCA welcomes the new method of
allowing compensation payments to higher-welfare producers to
counteract the higher costs from such systems and ensure a level
playing field against imports from third-country producers still
using intensive systems. It is recognised that higher welfare
standards can lead to higher production costs—particularly
in labour, additional land required and feed. In one sector—the
egg industry—research conducted by the RSPCA in 2001 underlined
the disadvantages faced by European egg producers once the battery
cage is phased out under new European laws unless a system of
compensation payments are agreed. If welfare standards are to
be maintained and farming not undercut by imports produced to
lower standards, farmers that produce to higher standards need
to be compensated.
11. The RSPCA believe that such a payment
would create the incentives to help farmers change over from intensive
systems. It would also be consistent with the approach adopted
by the EU in the AoA negotiations where the EU has proposed three
methods to maintain higher welfare standards in the face of incoming
exports of products produced under lower welfare standards, one
of which is allowing compensation payments for producers attaining
higher standards[11].
Prior to producing these proposals the Commission ran the risk
of proposing one method in the AoA negotiations, which could not
be delivered through its own agricultural subsidy schemes. This
proposal closes that loophole and also provides a methodology
to ensure that agreed legislation to improve animal welfare can
be implemented and further proposals to raise standards to improve
animal welfare will not be restricted in the future.
12. The Society supports the proposed assistance
for farm audits under the RDR. This would be consistent with the
approach for whole farm audits, as proposed by the Curry Commission
and the RSPCA demand for farm licensing to ensure compliance with
certain standards. It would also provide an additional safety
net to cross compliance to ensure that the baseline standards
are being followed. Proposals to give payments to such audits
under the RDR are consistent with this approach.
10 September 2002
9 In addition Directive 98/58/EC gives baselines standards
for all farming, based on the Council of Europe Convention for
the protection of animals kept for farming purposes. Back
10
Farming and Food. Report of the Policy Commission on the future
of farming and Food. UK 2002. Back
11
EC proposal on animal welfare and trade in agriculture. G/AG/NG/W/19
June 2000. Back
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