Select Committee on Environment, Food and Rural Affairs Minutes of Evidence


Memorandum submitted by National Farmers' Union

EXECUTIVE SUMMARY

  The following should be read in conjunction with the NFU's full submission.

Price cuts

  The NFU regards the proposed price reduction of 42.6% as unnecessarily severe. Price cuts should be limited to what is necessary to drive the Restructuring Scheme and achieve the required reduction in European production.

Additional price cuts

  A combination of additional price cuts and factors not taken into consideration by Commission calculations will effectively mean that UK growers could face a price cut of approximately 54%.

Quota

  The NFU is opposed to compulsory quota cuts and welcomes the Commission's intention to use a combination of price cuts and a voluntary restructuring scheme to achieve market equilibrium instead.

Quota ownership

  The NFU is disappointed that in both of its proposals for the Restructuring Scheme and quota buy-back, the Commission has neglected the legitimate rights and interests of growers by failing to provide an adequate role for growers in the decision making process.

Implications for UK agriculture

  The effects of the proposed reform would include a material reduction in the area of beet grown in the UK, a reduction in the number of holdings on which sugar beet is grown and increased risk of factory closure. The loss of the crop on holdings will have a direct impact on the level of labour that the farm is able to support, and so lead to further job losses.

Decoupling

  Compensation should be decoupled from production. Any scope for Member States to allow partial coupling would encourage less efficient producers to remain in beet production, thereby hindering the objective of achieving an efficient and viable EU industry in the longer term and disadvantaging UK growers.

Compensation

  The Commission's proposed flexibility over distribution of compensation would lead to unfair competitive distortions. The UK's compensation effectively represents 53% of the real price reduction (following the final price cut in 2007), not the 60% headline figure in the Commission proposals. These uncompensated elements should be incorporated into the national compensation envelopes.

Contractual arrangements

  Assuming a reform is agreed that does not discriminate against the UK, future viability and profitability still depends on viable new commercial arrangements between growers and processor. Working with growers, the NFU Sugar Board is developing a vision for the future that will require a commitment to real partnership from British Sugar/ABF Plc.

  Government must also recognise the stake that it holds within the industry, and do what it can to help processor and grower secure a robust commercial partnership.

INTRODUCTION

  The National Farmers' Union of England and Wales (NFU) is recognised in legislation as being the body substantially representative of the producers of sugar beet in the UK. As such, it negotiates on behalf of all UK sugar beet producers and welcomes the opportunity to provide evidence on the reform in the EU sugar sector.

1.  EXTENT AND TIMESCALE OF THE PROPOSED PRICE REDUCTIONS

Extent of price cuts and method(s) for achieving market equilibrium

  1.1  The NFU concedes that the EU is bound to implement a cut in price in order to satisfy a combination of internal and external pressures. Furthermore, the NFU acknowledges the need to achieve a balance in the market between EU production and imports on the one hand and domestic consumption and exports on the other.

  1.2  The NFU welcomes the fact that the Commission has proposed no compulsory quota cuts. The necessary adjustment in the volume of European production will be achieved by a combination of price cuts and a voluntary restructuring scheme.

  1.3  The level of price cuts should be carefully balanced. The reduction should be limited to what is necessary to drive the Restructuring Scheme and achieve the required reduction in European production, but allow profitable beet production to continue to be viable in the most efficient regions.

  1.4  We feel that a headline price reduction of 42.6% is unnecessarily severe in attempting to achieve these aims and will jeopardise beet production in even the most efficient EU Member States, including the UK.

Additional price cuts

  1.5  A headline reduction in the Minimum Beet Price of 42.6% over two years does not begin to tell the real story of the kind of price cuts that UK growers are likely to face. A combination of additional price cuts and factors not taken into consideration by Commission calculations will effectively mean that UK growers could face a price cut of approximately 54% (see Appendix 1 for summary). The additional cuts are described below.

Production Levy (applicable to all Member States)

  1.6  The stipulation that 50% of the "Production Charge" can be charged to the growers (Article 16) equates to a further price reduction of €0.78/t beet, or a Minimum Beet Price of €24.27 (an additional price reduction of 1.7%). In the current regulation, the production levy was introduced to finance the cost of the sale of quota sugar in excess of Community production. Following reform, however, production under quota to be sold on the Community market will always be lower than consumption because imports will significantly exceed exports of quota sugar. The Production Charge is therefore unjustified and should be removed altogether.

Flexibility Clause (applicable to all Member States)

  1.7  The "flexibility clause" (section 2.2 of Explanatory Memorandum) allows for a further 10% reduction in the Minimum Beet Price to be negotiated if the EU market price drops below the reference price. The NFU understands that the rationale for this clause is to enable factories to remain viable in times of adverse market price conditions. However, not only does this contradict the very notion of a minimum price, and put further pressure on growers' margins, it is also asymmetrical in its implementation. If growers are to help keep factories viable when the market price is lower than the reference price, they should be given the opportunity to benefit from a share in the extra margin when the market price is higher than the reference price. This inequity is symptomatic of the imbalance that has arisen in the grower-processor relationship over time. Activation of the flexibility clause would see the beet price reduced to €21.84/t (including the "production charge"), representing an overall price reduction of 50%.

Loss of Deficit Area Premium (specific to some Member States, including UK)

  1.8  The UK status as a deficit area producer—approximately 50% of sugar for domestic consumption is imported from African, Caribbean and Pacific (ACP) producing countries—has meant that growers have benefited from an additional €1.90/t of beet produced. While the NFU accepts that this status may no longer be applicable post-reform, we believe that the existence of the deficit area premium should be taken into account in the Commission's calculations and its removal compensated for in the UK national compensation envelope (see part 4 on compensation for more detail).

Merging of "A" and "B" Quota (specific to some Member States, including UK)

  1.9  The notion of implementing the 42.6% price cut on an amalgamated A+B quota discriminates against Member States with proportionally smaller B quota; these Member States, including the UK, will effectively face a greater percentage price reduction. It is crucial to note that this is not due to any kind of preferential treatment; UK growers face the same Minimum Beet Price as growers from all other Member States. Rather, the discrimination is a result of the differing A and B beet prices caused by the higher levy paid on B beet. In their pursuit to simplify the quota system, the Commission have unfortunately failed to take into consideration the discriminatory effect this will have across the EU.

  1.10  As a result of the proposed method, UK growers are likely to face an effective price cut of 2.3% over and above the 42.6% proposed by the Commission. UK growers must not be discriminated against, and the NFU disagrees with the notion of cutting prices on an amalgamated A+B quota. The Commission should devise an alternative solution that is equitable, taking into account the differing proportion of A and B quota across the EU.

SUMMARY

  1.11  The combination of these factors would mean that the UK neither starts at a price of €43.63/t beet, nor finishes up with a post-reform price of €25.05/t beet. Taking into account the UK's proportionally smaller B quota and including the deficit area premium means that the UK actually starts at a theoretical price of €47/t beet.[4] [5]

  1.12  At the other end, implementation of the Production Charge will bring the Minimum Beet Price down to just €24.27/t. For the UK, this represents a minimum total effective price reduction of:

  ((24.27 / 47.00) x 100)-100 = 48.4%

  If the "flexibility clause" is implemented, the Minimum Beet Price could be reduced to just €21.84/t, representing a maximum total effective price reduction for the UK of:

  ((21.84 / 47.00) x 100)-100 = 53.5%

Timescale

  1.13  The NFU's view on the time needed to implement the price cuts is largely dependent upon the final shape of reform compromise. Under the current state of play, the need to reduce prices in a relatively short period of time seems evident.

2.  EXTENT TO WHICH THE PROPOSED REDUCTIONS IN PRICE WILL BE TRANSMITTED TO THE CONSUMER

  2.1  It is widely held within the sugar, and subsidiary industries, that the consumer is likely to see little benefit from the reform of the EU sugar industry. While the price of sugar will be substantially reduced and consumers are likely to be able to buy cheaper sugar from supermarkets, the majority of sugar consumed in the EU/UK is in the form of processed food products. Historical evidence suggests that sugar users are unlikely in the first instance to pass on the cost savings to their customers, instead pocketing the difference to increase their own margins. In the longer term, the extent to which price cuts will be passed on to customers will depend on the degree of competition in the food chain.

  2.2  Given that most sugar is consumed in processed products, where the share of the total product price is trivial, and it is uncertain whether even this reduction would be passed on, it seems very unlikely that this reform will have any discernible impact on sugar consumption.

3.  THE IMPLICATIONS FOR UK AGRICULTURE, WITH PARTICULAR REGARD TO POSSIBLE ALTERNATIVE LAND USES

  3.1  The NFU has carried extensive consultations with beet growers, and the views put forward in evidence below are those of UK sugar beet growers, and represent all parts of the sector.

  3.2  The substantial reduction in price proposed will lead to a reduction in the numbers of farm holdings growing beet in the UK. The decision to continue or withdraw from production will be taken at farm level but there will be a number of common critical considerations:

    —  Soil type, impact on rotation and available alternative cropping.

    —  Distance to processing factory.

    —  Access to modern planting, harvesting and loading equipment.

    —  Scale of farm business.

    —  Age of owner/manager.

  3.3  Until the net beet price available to UK growers is fixed, and negotiations about detailed contractual issues concluded, there are too many unknown variables to support valid sensitivity analysis, either at industry or farm level. It is interesting to note however, that the Impact Assessment produced by the EU stated that "break-even" beet price for UK growers was €40 per tonne; the subsequent conclusion that the UK beet industry could operate within the "safe zone" post reform appears to be based on the assumption that processor and grower will work together to secure additional efficiency savings, and that these would be shared between both parties.

  3.4  It is clear to the NFU, however, that the reforms will lead to:

    (a)  A material reduction in the area (hectares) of beet grown in the UK; the current contract penalises growers that fail to meet their contract tonnage in two out of any three years by cutting the subsequent tonnage in future contract offers. Due to substantial variations in yield and sugar content resulting from different climactic and harvesting conditions, this practice has led to growers planting an additional area of crop for "insurance purposes". British Sugar has sold production from this area, together with any additional tonnage over A&B contract levels into the "C sugar" market. This practice can no longer continue; the C sugar market no longer exists, and growers simply cannot afford to plant and grow crops that will not attract the market price.

  3.5  Analysis by Savills Research[6] shows that beet production has been over quota by on average 17-18% over the last 10 years, varying from 7% to 28%. Over the last five years, the crop area has tended to decrease; main fluctuations are due to yield and the sugar quantities in the beet. Savills has calculated that the area of crop needed to meet quota based on the historic 10 year average yield of 53.3 t/ha would be nearly 20% lower than in recent years.

  3.6  The NFU will be involved in negotiations with British Sugar to find ways of better matching volume of sugar beet supply to tonnage of sugar quota.

  3.7  (b)  A reduction in the number of holdings on which sugar beet is grown. It is inevitable that some growers will find it impossible to supply sugar beet profitably to British Sugar under the terms of a new contract (yet to be determined). These businesses will include those for whom alternate cropping is a viable option, some for whom mono-culture becomes inevitable, and some for whom the only alternate is not to cultivate the land.

  3.8  (c)  An Increased Risk of Factory Closure; the impact on the processor is to be considered in a later question. It appears however that British Sugar do not plan to enter into the Restructuring Scheme; any subsequent factory closure will therefore not attract any EU restructuring payment as it stands.

  3.9  Sugar beet is an important crop for many holdings. It is relatively high output but labour intensive; it therefore supports labour costs across the remainder of the farm business. It is also a valuable spring sown break crop and offers substantial environmental benefits. [7]Its use as part of a viable rotation is of crucial importance on many sugar beet growing farms, where soil type makes the use of alternates such as oilseed rape, pulses and brassicas unviable or impossible.

  3.10  The loss of the crop on many holdings will have a direct impact on the level of labour that the farm is able to support, and so lead to further job losses. Many holdings are reaching a point where they are operating with the absolute minimum of labour; this inevitably means that the ancillary work to manage and maintain the landscape upon which the UK has become so reliant, cannot be carried out.




  3.11  It is inevitable, that in many instances where Sugar Beet is removed from the rotation, it will be replaced with a crop that offers fewer environmental benefits, increases the level of mono-culture and so directly affects biodiversity and countryside quality.

  3.12  Brooms Barn Research Organisation has produced a paper looking at the environmental impacts of sugar regime reform. [8]

  3.13  For a material proportion of growers, these alternate crops are also likely to produce a lower margin, and so erode further the profitability and viability of the business, not to mention the volatile effect this may have on the market balance of these alternative crops.

4.  THE PROPOSED ARRANGEMENTS FOR COMPENSATING EU PRODUCERS

Decoupling

  4.1  The NFU agrees that compensation should be decoupled from production. It is our strongly held view that this should be applicable to all Member States without delay. This is the Commission's proposal, but we see a serious risk that—as happened in June 2003—in order to obtain a majority in the Council of Ministers there will be a compromise introducing the option of "partial" decoupling. This must be avoided at all costs. Any form of coupling will encourage less efficient producers to remain in beet production, thereby hindering the objective of achieving an efficient and viable EU industry in the longer term.

Level of compensation

  4.2  Whether the level of compensation is acceptable will depend heavily on how compensation is to be administered, given that the Commission have allowed Member State flexibility over the right to distribute sugar beet compensation.

  4.3  Having said this however, what is apparent is that the Commission's headline compensation falls short of the 60% aim if the "real" price cut is taken into account. There are two aspects to this view. Firstly, that as a "deficit area" producer, UK growers are paid an additional €1.90/t quota beet. Secondly, implementation of the Production Charge to growers will reduce the Minimum Beet Price by a further €0.78/t beet to €24.27/t. While the first is specific to the UK and other deficit area Member States and the second is a valid concern for all Member States in beet production, both elements are omitted from the Commission's calculation for the national compensation envelopes, therefore are "uncompensated". In appendix 2 we show that in light of these factors, the UK compensation envelope effectively represents approximately 53% of the real price reduction (following the final price cut in 2007), not the 60% headline figure in the Commission proposals.

  4.4  It is the NFU's view that these so far uncompensated elements should be incorporated into the national compensation envelopes as they reflect the actual price reduction to be implemented, but without a reduction in the percentage commitment of 60%.

Single Payment Scheme

  4.5  We agree that compensation for sugar reform should be incorporated into the SPS, [9]but in practice this will make no difference in terms of cross-compliance. There is no such thing as a farmer who solely grows sugar beet. All growers would have been growing other arable crops that make them eligible for the SFP. In practice, therefore, sugar beet land is already subject to the full range of cross-compliance conditions.

Reference period

  4.6  The NFU is satisfied with the flexibility that allows each Member State to choose the reference period for compensation to be paid. Historical circumstances in each Member State will differ. In the UK for example, 2000-02 would not be a suitable reference period due to the 2001 Outgoers Scheme. The NFU would support the most recent reference period possible (without incorporating any future years) as being the most appropriate means of reflecting current industry.

Administration of compensation

  4.7  The Commission have offered Member States the flexibility to choose how compensation is administered nationally. Such flexibility will undoubtedly create competitive distortion among Member States with beet growers receiving historic compensation being placed theoretically in a better position to make efficiency gains and reinvest in the industry than those receiving regional compensation.

  4.8  While the NFU believes that the optimal method would be to avoid any potential distortion altogether by ensuring compensation is paid consistently across the EU, we are mindful that flexibility will likely be retained and that the UK Government may favour a transitional hybrid compensation system that will ultimately lead to fully regional compensation.

  4.9  Considering these circumstances, the NFU is actively exploring all possible options and outcomes with the aim of establishing a set of principles that will provide UK growers with maximum benefit for as long as possible and avoid being disadvantaged in comparison to our closest competitive rivals. The NFU would welcome the opportunity to discuss these principles with the UK Government at an appropriate time.

  4.10  It is the view of the NFU that compensation should be distributed on the basis of (contracted) tonnage as opposed to beet area. This will benefit growers with higher yields.

5.  THE CHANGES TO THE QUOTA ARRANGEMENTS

Amalgamation of A and B quotas

  5.1  The Commission's proposal to simplify the quota system by merging "A" and "B" quota into a new single quota and then cutting price causes disparity among Member States due to the differing proportion of A to B quota that each Member State holds.

  5.2  The price growers receive for A beet is higher than the price received for B beet due to the higher levy charged on B (approx. 38%) than A (approx 2%) beet. Coupled with a differing proportion of A to B beet across the Member States, this results in a different amalgamated or average price.

  5.3  The NFU therefore opposes the notion of implementing price cuts on an amalgamated A+B quota on the basis that it disadvantages Member States with proportionally smaller B quotas. The Commission should devise an alternative solution that is both fair and equitable, taking into account the differing proportion of A and B quota across the EU.

Restructuring Scheme

  5.4  The NFU acknowledges the need to reduce EU production in order to help achieve a long-term market balance and to meet our WTO obligations. The NFU agrees with the principle of a Restructuring Scheme as opposed to indiscriminate mandatory across-the-board quota cuts in order to achieve this aim.

  5.5  In a more liberal world trading environment, there can be no long term future for European sugar production unless it is more competitive. Production must be allowed to gravitate to the most productive regions, and not artificially maintained across the whole of Europe by a quota system.

  5.6  We support the offer of degressive aid over a four-year period that will hopefully encourage the least efficient regions in the EU to relinquish production gracefully, and sooner rather than later.

Purchase of additional quota

  5.7  The NFU also agrees, in principle, with the provision to allow the most efficient Member States the opportunity to purchase a proportion of 1 m/t of additional quota, of which the UK "share" is 82,847 tonnes. Given a fair and balanced reform, we are confident that the UK beet industry has the ingredients to continue to prosper into the future and should therefore be given the ability to expand.

Quota ownership

  5.8  The NFU has serious reservations over the detailed workings of both schemes. The Commission has neglected the legitimate rights and interests of growers by failing to provide an adequate role for growers in the decision making process involved in relinquishing quota under the Restructuring Scheme, and expanding quota under the additional quota purchase scheme.

  5.9  Just as the issue of "quota ownership" had been central to the proposed mechanism to transfer quotas across national borders, the NFU believe the issue remains pivotal in the decision to relinquish and/or expand quota. We are concerned that the lack of a balanced approach to such a central issue as restructuring may have serious consequences for the issue of quota ownership.

  5.10  The position in the UK is that the national Sugar Quota is held by the Government as custodian on behalf of the country, and made available to the sugar processor in order to provide access to the EU Sugar Regime for growers and processor.

  5.11  How is this position to be maintained with regard to the additional 82,847 tonnes of sugar quota available for purchase by the UK? Will the Government acquire this tonnage on behalf of the industry, without seeking to recover any of the cost of acquisition from the processor or grower? If not, on what basis will a contribution be sought from processor and/or grower? If money changes hands, what impact does this have on the ownership of the additional quota? Would processor or growers have any rights in respect of this Quota, how would it be dealt with in respect of future cuts in quota imposed by the EU?

  5.12  All these questions remain unanswered. It is imperative that the UK government enters into this debate as an active party, as custodian of the national sugar quota, and does not permit the tripartite relationship between Member State, grower and processor to be fundamentally altered or undermined.

  5.13  The Commission and Member States need to address the issue of ownership more explicitly and recognise the legitimate interests of growers.

6.  THE POTENTIAL IMPACT OF THE REFORMS ON UK-BASED SUGAR BEET PROCESSORS AND CANE REFINERS, AND THE LONG-TERM CONSEQUENCES FOR THEIR INDUSTRIES

  6.1  The UK processor is on record[10] that it expects the operating profit impact to be some £10 million in 2006-07 and some £40 million in 2007-08 and thereafter. It is also on record that it expects "these effects to be in part mitigated by cost reductions". It is inevitable that these cost reductions will be focused in two areas; efficiency savings within processing and administration, and contractual arrangements (of which headline price for sugar beet is one of many complex elements) with its supplier base.

Processing Efficiency Savings

  6.2  The NFU and growers have worked in partnership with British Sugar to extract maximum possible efficiency savings from plant and process. The NFU works closely with the processor to optimise communications with the 7,000 growers and minimise administration costs related to the annual contract cycle. The NFU and growers are not however, full partners in the processing of sugar beet, and have limited influence in decisions taken in that regard.

  6.3  The NFU fully expects British Sugar to seek further savings within process and administration, and a factory closure cannot be ruled out as part of any cost mitigation strategy. British Sugar currently operates at six factories having closed sites at regular intervals in the last decade.

  6.4  The Government has stated on record[11] that it believes that factory closures `are not a new phenomenon in the sugar sector' and that `those are commercial decisions for the company'.

  6.5  If this is the government's position, it should consider that previous closures have led to consolidation of supply, with growers offered the right to supply an alternate factory. Any dis-enfranchisement of growers in the event of future factory closure would be inequitable; even more so when the processor may have unilaterally rejected an EU Restructuring Scheme that provides for compensation for growers forced out of production by factory closure.

Cost Savings via Contractual Arrangements with Supplier Base

  6.6  The UK sugar beet industry has three key elements; the sugar quota holder (government as Member State); the processor (British Sugar a wholly owned subsidiary of Associated British Foods Plc, the international food, ingredients and retail group); and the growers, 7,000 individual farm businesses.

  6.7  The relationship between processor and supplier of raw material (sugar beet) is inherently unbalanced.

  6.8  In an effort to level this playing field, the supplier base is represented by the NFU Sugar Board, which carries out all negotiations and interaction with the processor on the growers' behalf, acting as agent. The Sugar Board consists of elected beet growers. The Sugar Board is supported by an NFU executive team of four, one senior advisor, one researcher/economist, a beet intake manager and an assistant. This resource is funded by a levy, charged against each tonne sold to the processor, and collected by British Sugar.

  6.9  The inherent imbalance between single private sector monopoly processor and diverse grower base was recognised in the 1956 Sugar Act, which governed this tri-partite relationship following the privatisation of the formerly state owned processor. At this stage the Government reserved the right to:

    —    give directions regarding the prices to be paid by the then British Sugar Corporation under contracts for the purchase of home-grown beet (section 17(2));

    —    give directions to the Corporation prescribing the total quantity of home-grown beet which the Corporation might contract to purchase for delivery in any period specified in the directions (section 17(4));

    —    prepare for each year a programme for carrying out research and education in matters affecting the growing of home-grown beet, and could by order make provision for carrying any such programme into effect (section 18(1)).

  6.10  In addition, section 23(1) ensured that neither the memorandum of association nor the articles of association of the Corporation could to be altered without the consent of the Ministers given with the approval of the Treasury.

  6.11  The direct involvement of government, and so protection of growers, has been watered down in subsequent legislation (most notably the Food Act, 1984), to a point where the only protection that growers can demand from the Minister is appointment of an arbitrator to resolve commercial disputes and to require the processor to provide information to support such resolution.

  6.12  Whilst statutory protection of the grower has waned, the processor has evolved from a fledgling, newly privatised single interest company to become a wholly owned subsidiary a multi-national corporation.

  6.13  Analysis by Savills Rural Research has assessed the three-year (2002-04) average profit made by British Sugar per tonne of processed sugar beet to be £18.01. That is £1 per tonne, or 5.5% higher than the minimum beet price proposed by the EU. These profit levels have generated an average return on net assets in excess of 30% over the last three years.

  6.14  The commercial relationship between processor and grower is now governed by the Inter-Professional Agreement (IPA) which covers a range of detailed matters relating to price, haulage, processing, sugar content, early and late delivery payments, contract tonnage entitlement, contract management, seed, traceability etc.

  6.15  It is anticipated by both processor and grower that the proposed reform will mean a radical re-negotiation of the IPA. This is likely to be a hard fought commercial negotiation; ABF Plc has been used to high levels of profitability from British Sugar; analysis by Savills Rural Research assesses their three year average profits to October 2004 at £165 million, and average return on net assets at 34%. ABF Ltd assesses the annual impact of the reform proposals on British Sugar's operating profit at £40 million from 2007-08.

  6.16  The future of British Sugar relies upon viable new commercial arrangements with growers; many of whom will not be in a position to fulfil supply commitments if the full impact of a 55% price cut is passed on to farm.

  6.17  The UK has perhaps the most efficient processing efficiency in Europe, but to maintain production British Sugar will need to share some of their additional processing margin with the grower. If the processor is to continue to prosper, it needs to secure a viable long term relationship with its supplier base that offers optimum efficiency and flexibility.

  6.18  Working with growers, the NFU Sugar Board is developing a vision for the future of a viable UK industry. It will require a considerable commitment to partnership from British Sugar/ABF Plc.

  6.19  This vision requires precisely the partnership response to reform that the EU envisages in its Impact Assessment. In recent years, the processor has not been slow to use its commercial muscle and greater negotiating resource to get the best deal. If this trend continues, the long-term viability of the sector, and so the processor, will be substantively threatened.

  6.20  Government must recognise the stake that it holds within the industry, and do what it can to help processor and grower secure a robust and "future proofed" commercial partnership.







4   As explained in the previous sub-section, it is important to note that the UK does not actually benefit from a higher Minimum Beet price, but that the Commission's theoretical EU "reference price" of €43.63 falls short of representing the UK situation principally because of the differing proportions and prices of A and B quota across the EU. Back

5   If the Deficit Area Premium cannot be retained post-reform its loss should be recognised in national compensation. Back

6   Savills Rural Research-Internal Briefing Note (Sugar Reform) 9 September 2005. Back

7   Sugar Beet supports up to half the world's population of pink-footed geese which feed on left-over beet tops in fields in Norfolk. Beet fields also help declining skylarks and lapwing because they provide feeding and nesting sites (RSPB). Back

8   The Environmental Impacts of Sugar Beet Reform; Brooms Barn Research Organisation, July 2005. Back

9   This does not, however, predicate how compensation should be administered by the Member State. Back

10   ABF Plc press release; Publication of the European Commission's proposals for the reform of the EU sugar regime 22 June 2005. Back

11   Elliot Morely, Defra response debate, 12 July 2005. Back


 
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