Memorandum submitted by the RSPCA
IMPLEMENTATION OF CAP REFORM IN THE UK
EXECUTIVE SUMMARY
The RSPCA welcomes the agreement on the CAP
and believes that it places animal welfare for the first time
into the CAP. It is disappointing that many of the issues agreed
under the CAP reform will not produce benefits until 2007, which
is when cross compliance for the three animal welfare Directives
comes into effect and provides the first opportunity to ensure
farmers are adhering to baseline standards. The RSPCA believes
that the proposals in the Rural Development Regulation could make
a substantial difference to raising animal welfare standards but
there are two concerns. An insufficient budget for rural development
plans in the UK may not see new ideas for funding coming on stream
for a number of years and this may cause an imbalance in approach
if other Member States implement funding mechanisms for animal
welfare. Secondly many of the definitions for animal welfare schemes
have to be agreed at a Member State level and the RSPCA wishes
to see definitions agreed in the UK such that new funding is channelled
for schemes that implement and ensure higher welfare standards.
The CAP reform gives a real opportunity to ensure that enforcement
and development of animal welfare standards are carried out at
each level (baseline medium and higher standards) but the actual
implementation of the options in the reform by the UK will determine
how effective this will be.
INTRODUCTION
1. The RSPCA welcomes the opportunity to
give evidence to the Environment, Food and Rural Affairs Committee
on the implementation of the CAP reform in the UK. The RSCPA welcomes
the final agreement on the Common Agricultural Policy that was
achieved on 26 June. This agreement was the first time that proposals
to achieve animal welfare benefits were agreed under the CAP,
and in particular that the Rural Development Regulation (Pillar
2) has agreed budget line proposed for delivering higher animal
welfare standards.
2. It is therefore consistent for the UK,
which has traditionally positioned itself as a champion of animal
welfare, to utilise these opportunities. The RSPCA believes that
there are three main opportunities from the reform: to deliver
enforceable baseline standards through the cross compliance scheme,
to promote mid range welfare schemes by the national envelope
and to promote higher welfare standards through the rural development
programme. There are also opportunities to ensure that the higher
standards currently practised in the UK are not undermined by
cheaper imports from more intensive systems in third countries.
3. The Society also believes that the agreement
on including and increasing the importance of animal welfare within
the CAP is consistent with the principles behind the report on
the Policy Commission on the Future of Farming and Food. Although
the Commission did not review animal welfare as its main aims,
it did focus on a number of issues which are directly applicable
to the CAP reform. These include developing assurance schemes
to improve animal welfare, and developing budget lines to ensure
that high standards of animal welfare do not drive domestic producers
out of the market.
4. The issues that have been agreed under
the CAP reform fall into two main areas: those that are compulsory
for Member States to implement and those that are voluntary. This
has implications for differences between Member States in achieving
improved animal welfare standards and also in the extent to which
the UK will promote achieving improved welfare standards as part
of its strategy in progressing farming.
COMPULSORY MEASURES
5. On compulsory measures the RSPCA agree
that decoupling should be introduced for the livestock and dairy
sectors from 2005. We strongly support the cross compliance mechanism
as it would, for the first time, ensure that all CAP payments
are conditional on meeting baseline welfare requirements. 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. This would also ensure that animal welfare
standards could be built into the CAP; the basic standard would
be the minimum legislative standards as recognised in this cross
compliance mechanism.
6. The introduction of mandatory cross compliance
is consistent with the recommendations of the Curry Commission
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)
7. The RSPCA is disappointed that cross
compliance for the three pieces of animal welfare legislation
is due to be delivered in 2007, the last of the three phases of
introduction. It feels that, as the cross compliance system is
only delivering already existing legislative standards, compliance
should be easier to initiate than other measures. It believes
that measuring compliance should not be onerous if the animal
welfare measures are added to existing forms in a tick box format.
The impact of cross compliance of animal welfare measures on the
agricultural sector should be positive, as there will be minimal
financial burden, but the benefits of ensuring that farms are
adhering to baseline legislative standards.
8. The national envelope provides an opportunity
to encourage the production and marketing of higher welfare quality
products and should be used for the livestock and dairy sector.
Given the problems with funding that the additional areas to the
RDR could face to come under the English RDP, the allocation of
funds under the national envelope could realise immediate specific
gains for animal welfare rather than waiting until 2007. The same
issues as outlined for the assurance scheme still apply, namely
that there should be clear standards of animal welfare that are
above the national legislative baseline and the quality product
should follow the same process as the assurance schemes as laid
out under the RDR. The RSPCA sees that funding from the national
envelope could deliver standards that are above the baseline but
not as high as the farm assurance schemes (see paragraph 16).
The RSPCA is developing a range of indices that could be used
for this funding.
VOLUNTARY MEASURES
9. On the voluntary areas, there is considerable
scope for the UK which the RSPCA hopes the UK will utilise. There
are two principal concerns. At present there is enough financial
basis for the implementation of "the broad and shallow scheme",
agreed to be implemented under the agri-environment scheme from
2004. The benefits for this will be almost exclusively to deliver
environmental goods. The RSPCA believes that it is important a
budget line is allocated to incentives to deliver animal welfare
benefits. The present budget for the RDPs for the four areas of
the UK up to 2006 show that only up to 13% of the total English
budget and 2.55% of the Welsh will be used for the issues that
could benefit animal welfare. The majority of the budget is used
in agri-environment schemes and Less Favoured Areas neither of
which have included animal welfare as an objective to date. This
appears to be in conflict with public opinion on the relative
importance of animal welfare and environmental issues. A survey
by Charity Awareness Monitor in June 2001 found that almost twice
the percentage of respondents cited animal welfare as a concern
compared with environmental issues.
10. The RSPCA recognises that DEFRA are
not inclined to consider new budget lines for animal welfare until
2007, but underlines the importance of agreeing a proactive strategy
for the next funding period so that further animal welfare benefits
can be delivered. The RSPCA believes that this is consistent with
the Curry Commission report that stated on animal welfare that
"most people, including farmers, would like to ensure that
farm animals are looked after to the highest standard possible"
(p 99).
11. The second concern lies on defining
further some of the areas under the Regulation 1783/2003 on support
for rural development. The Commission has stated that it will
be up to the discretion of Member States to agree definitions
for these areas so it is crucial that the UK, once it implements
new areas for animal welfare, agrees definitions that are meaningful
so that they provide a level of animal welfare above the baseline
standards and also provide an incentive for farmers to take up
these schemes.
12. The RSPCA consider that there are four
issues that the UK should utilise in Regulation 1783/2003 to provide
a range of options in ensuring animal welfare benefits are delivered
under the Pillar 2 payments:
Article 21. Provide time limited aid to farmers
facing new legislative requirements and allow farmers to claim
for a significant impact on a significant number of farmers. Support
is modulated, is degressive over five years and is to a maximum
of
10,000 per farm pa.
This measure complements the EU's approach at
the WTO, whereby such subsidies would be classified under the
Green box. It is uncertain how significant will be defined, but
there are a number of changes to EU legislative animal welfare
standards that are in the process of coming on stream, where this
budget line could prove to be useful, for example,
Pigs: new space allowances for sows and gilts
under Directive 2001/93 for new buildings came in to place from
January 2003 and are due to be implemented for all buildings from
2013, although changes in the UK may be minimal as UK legislation
imposed changes from 1999.
Laying hens: under Directive 1999/74, all new
buildings for alternative systems have had to comply with the
new conditions on cage size from 2002 and will have to apply to
all buildings from 2007. All unenriched cage systems are due to
be phased out by 2012.
13. The RSPCA believe that DEFRA should
be allocating a budget to this situation. It will ease any financial
implications that might in some cases result from the change in
welfare standards and ensure that the UK farm industries can remain
competitive against other EU member states, who may also be allocating
financial assistance in this area.
14. Under Article 21d support is available
for farmers using farm advisory services. 80% of the cost is possible
up to
1,500 per holding. It is still unclear what role
the farm advisory service will play in implementing the new cross
compliance provisions of the CAP. At present the advisory service
will be voluntary until 2006 and then be voluntary in the country
for any farmers so its impact could be limited. The RSPCA believe
that the UK should implement such a scheme from 2005 and encourage
the uptake of the scheme by bringing in funding for the service
and making efforts to inform producers of the benefits to their
business. The RSPCA hopes that the service will play an important
role in establishing which farms are not implementing cross compliance
provisions, particularly on the relevant Articles in the three
animal welfare laws (Directive 98/58/EC, Directive 91/629/EC and
Directive 91/630/EC), and assist them in meeting such standards.
There should be a process set out that establishes a direct link
between the cross compliance mechanisms and allocation of subsidies
under the CAP.
15. Article 22 sets out the new animal welfare
benefits under the Agri-environment payments: farmers may be paid
if they give a commitment for at least five years to apply more
than the usual good farming practice including good animal husbandry
practice. Support shall be granted on income foregone, additional
costs resulting from the commitment given and the need to provide
an incentive. Annual payments could be given up to
500/LU. The RSPCA believes that such a payment would
create the incentives to help farmers change over from poorer
welfare systems and would be complimentary to the assurance schemes
and scheme to reward changeovers to higher systems. It is an approach
recommended by the Curry Commission (p 48 and p 72 Farming and
Food: a sustainable future). As with the assurance scheme it is
important that the standards for such an initiative be properly
defined and represent a higher level than the baseline legislative
standards. It is uncertain what is defined as more than the usual
good farming practice and good animal husbandry. The RSPCA would
favour a broad and shallow approach to this payment, so as to
maximise the extent of the scheme and to fit in with the existing
broad and shallow scheme giving environmental and archaeological
incentives. The RSPCA is in the process of developing standards
that could provide a template for this scheme and these could
include issues such as, at a generic level, ensuring that the
farm has a written Animal Health Plan that is implemented and
regularly reviewed, and at a species specific level, implementing
standards that are beyond minimum legislative standards.
16. The RSPCA feels that this scheme, if
applied at a broad and shallow level, would fit in with payments
for the highest tier of assurance schemes. The baseline standards
would be the minimum legislative standards and be monitored via
the cross compliance mechanism. Such standards would not be eligible
for payments under the RDP unless it was under Article 21 (meeting
standards) and Article 21d (funding the farm advisory scheme).
The aim of the higher levels would be the promotion of positive
action to create a more sustainable farming process. The proposals
for the broad and shallow scheme under the agri-environment measures
would fit in at the intermediate level. The highest level would
be linked to marketing initiatives that have already developed
high standards and would qualify under Article 24 on food quality
and assurance schemes.
17. Under Article 24 a budget line for food
quality schemes is established whereby support is given for measures
to improve the quality of products and to provide assurances to
consumers on the added value of such products. There are useful
parameters given so that the scheme must be transparent and complete
traceability is assured; it must be open to all producers and
there must be an independent inspection body verifying compliance
and traceability.
18. The RSPCA welcomes this initiative.
This proposal is also consistent with the recommendations from
the Curry Commission (p 41 Farming and Food: a sustainable future).
Curry concluded that all food produced in the UK should carry
an assurance mark to confirm the product has been produced to
DEFRA codes of practice and minimum standards. The Food Standards
Agency, in its report in 2002 on reviewing food assurance schemes,
made clear that they did not want a proliferation of alternative
schemes and logos and endorsed the RSPCA assurance scheme, Freedom
Food, and LEAF as higher level schemes.
19. The definitions on an assurance scheme
in the final agreement have become clearer since the original
proposal; there is now language on traceability and independent
inspection. The processes which an assurance scheme has to fulfil
to qualify for this budget is more defined but it is still unclear
how the standards for such an assurance scheme will be defined.
However the definition that standards in such a scheme should
be significantly beyond animal welfare commodity standards is
non specific and so unclear. The RSPCA believe that only schemes
such as Freedom Food which have been acknowledged by the Food
Standards Authority as higher level schemes (and indeed were mentioned
in the Curry Commission report as examples of higher welfare schemes)
should qualify under this definition. The RSPCA has also drawn
up standards for a number of sectors that could also be used as
a basis for such a definition but there is a need to ensure that
the phrase significantly beyond is applied consistently and that
payments under this scheme do represent the highest tier of payments
under the RDP.
20. Finally it is important to acknowledge
that other member states have already given budgets for some of
these areas under their rural development programmes. France,
for instance, has provided support for food quality schemes and
pollution reduction schemes which have included had the effect
of paying farmers for higher welfare standards. In one example
an intensive pig farmer in Brittany gets Pillar 2 aid in return
for ensuring that pig slaughter takes place later in the animal's
life and that the animals have to be housed on straw bedding rather
than concrete or slatted floors. It is important for the competitiveness
of British farming in areas such as pigs or laying hens, that
the UK RDPs do not fall behind other Member States in the amount
of financial benefits or the types of schemes delivering improvements
to animal welfare. In this respect it may be useful if the four
UK regions set a funding target for animal welfare under the RDPs
(for instance as a percentage of total RDP funding) to ensure
that measures to improve animal welfare are taken up.
RSPCA
December 2003
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