Memorandum submitted by Compassion in
World Farming
IMPLEMENTATION OF CAP REFORM IN THE UK
EXECUTIVE SUMMARY
1. Compassion in World Farming (CIWF) welcomes
the fact that the CAP reforms agreed in 2003 have made farm animal
welfare an important component of the CAP for the first time.
2. We welcome the new "meeting standards"
provision which allows financial support to be given to farmers
to help them adapt to the introduction of demanding standards
based on EU legislation in the field of, among other things, animal
health and welfare. CIWF believes that the Department for Environment,
Food and Rural Affairs (DEFRA) should use its option under this
new provision to make money available to farmers to help them
meet higher, legally binding, welfare standards.
3. Especially welcome is the new provision
which allows payments to be made to farmers who wish to introduce
particularly high welfare standards which go beyond usual good
animal husbandry practice. This is extremely important as it will
encourage farmers to go further than required by the law (which
often still permits very intensive, low-welfare farming) and to
introduce really good welfare practices. CIWF believes DEFRA must
use its power under this provision to provide CAP money to help
farmers who want to introduce the best of animal welfare standards.
Political and Legal Director
Compassion in World Farming
COMMENTS BY COMPASSION IN WORLD FARMING
1. Compassion in World Farming (CIWF) welcomes
the fact that the CAP reforms agreed in 2003 have made farm animal
welfare an important component of the CAP for the first time.
Financial support for farmers who adopt good animal
welfare standards
Support to help farmers meet standards
2. We welcome the new "meeting standards"
provision which allows financial support to be given to farmers
to help them adapt to the introduction of demanding standards
based on EU legislation in the fields of environment, public health
and animal health and welfare.
3. The importance of the above provision
arises in the context of the World Trade Organisation (WTO) rules.
It is generally assumed that when the EU bans a cruel farming
system, it cannot ban the import of meat or eggs coming from animals
reared in that system. This leaves EU farmers vulnerable to cheap,
low welfare imports; one way in which EU farmers can be helped
to reach higher welfare standards while not being undermined by
such imports, is to receive financial support with the costs involved
in introducing higher standards.
4. CIWF believes the Department for Environment,
Food and Rural Affairs (DEFRA) should use its option under the
new "meeting standards" provision to make money available
to farmers to help them meet higher, legally binding, welfare
standards. DEFRA should make money available under this provision
as it is essential that we as a society take all possible steps
to move away from industrial livestock production to more humane
and sustainable animal farming methods.
Support for farmers who go beyond legally required
standards
5. Particularly welcome is the fact that,
under the CAP reforms, payments can be made to farmers who enter
into commitments for at least five years to introduce improved
welfare standards which go beyond usual good animal husbandry
practice. This is extremely important as it will encourage farmers
to go further than required by the law (which often still permits
very intensive, low-welfare farming) and to introduce really good
welfare practices.
6. To CIWF's dismay, DEFRA has already made
it clear in a consultation letter earlier this year that it is
unlikely to provide CAP money to help farmers who want to introduce
the best of animal welfare standards. CIWF believes DEFRA should
reconsider its position as the above provision is one of the most
welcome reforms introduced in the CAP and it is a matter of great
regret that Britain, which claims to lead the way on animal welfare
in Europe, seems unlikely to use its new powers to help farmers
who want to move to the best of animal husbandry systems.
7. Clearly, if payments are to be made,
thought will have to be given as to which practices/systems qualify
for the new welfare payments. CIWF would welcome the opportunity
of contributing to the debate as to what standards should qualify
for the new payments.
Cross-compliance with animal welfare standards
8. We welcome the fact that payment of the
new single farm payment and other direct payments will be conditional
on the respect of certain statutory animal health and welfare
standards. This will support the enforcement of animal welfare
legislation.
Farm advisory system
9. CIWF welcomes the new Farm Advisory System
and urges that animal welfare be given a high priority in this
system.
Decoupling of subsidies from production
10. CIWF welcomes the fact that many subsidies
which are currently linked to the volume of production will be
replaced by a decoupled single farm payment. The decoupling of
subsidies from production will remove the incentive to produce
too many animals in order to attract high subsidies.
11. We are, however, extremely disappointed
that Member States have the option of keeping some of the beef
and sheep subsidies as coupled payments, ie coupled to the number
of animals held as this will give a continuing incentive to the
production of too many animals and to the use of stocking densities
which are too high for good welfare. We hope Member States will
not take up the option of keeping some of the payments as coupled
payments. We are pleased that DEFRA has said that the options
for reducing the extent of decoupling in England in the livestock
sector will not be taken up.
Dairy regime
12. CIWF is disappointed that the CAP dairy
regime has not been thoroughly reformed. It is widely acknowledged
that the quota system has promoted the use of high-yielding cows
which suffer a range of serious health and welfare problems including
metabolic hunger, digestive disorders, high levels of painful
lameness and mastitis, sometimes fatal production diseases and
premature culling due to severe loss of body condition and chronic
exhaustion.
13. CIWF believes that the CAP dairy regime
must promote a move away from the use of high-yielding cows. In
particular, subsidies should be decoupled from production as soon
as possible, with subsidy payments being made to farmers, not
processors. These payments should be conditional on meeting welfare
conditions such as having in place a herd health scheme which
includes regular veterinary visits and a lameness and mastitis
prevention service provided by a veterinary surgeon.
14. In particular, subsidy payments should
be conditional on the adoption of a low-yield strategy or the
ability to demonstrate that the herd has good health and welfare
standards even with high yields. Higher direct payments should
be available for farmers whose milk yield per cow is below a specified
level.
Compassion in World Farming
December 2003
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