Select Committee on Environment, Food and Rural Affairs Written Evidence


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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