Session 2017-19
Agriculture Bill
Written evidence submitted by the RSPCA (AB08)
Summary
The RSPCA welcomes much in the Agriculture Bill, as it defines animal welfare as a public good to ensure a new subsidy support system, promotes the adoption of higher welfare standards and abolishes ‘business as usual’ for farmers to get payments for merely meeting basic legislative compliance. The RSPCA supports funded pilots from 2020 to deliver measurable goals to incentivise and deliver improved animal welfare, including animal health.
However there are concerns that the Bill contains no financial framework for farm spending post 2022, so there is no guaranteed funding to meet the Government's ambition as set out in Clause 1 to fund and imrpove public goods such as animal welfare and to improve England’s animal welfare and environment. To rectify this the RSPCA recommends a minimum spend is set to pay for deliverable animal welfare improvements. Finally the Bill needs to read across to the Trade Bill and ensure the Government is mandated to stop imports of products produced at lower animal welfare standards than in the UK.
Introduction
1. The RSPCA is pleased to respond to the Bill Committee on the Agriculture Bill. The Bill is the most defining event for farming and how we support farmers in England since the 1947 Agriculture Act. We will limit our comments to what is good in the Bill, what needs to be changed and look at this through the prism of the Second Reading on October 10.
2. The RSPCA has developed species-specific higher welfare standards for farm animals, which are used by RSPCA Assured, the UK’s only farm assurance scheme that specifically and solely focuses on animal welfare. Members of this scheme currently are responsible for c.50% of eggs produced, 24% of pigs raised, 31% of turkeys raised and 61% of salmon farmed in the UK.
3. As context, the EU’s Common Agricultural Policy (CAP) sets the farm support policy framework for the UK, but is not specific in how the policy is delivered by the UK Government. Although EU funding has been available for farm animal welfare since 2007, the amounts are small: 0.5% of the 2018 budget. In England no funding has ever been given for animal welfare payment schemes though one scheme existed in Scotland 2007-13 and proved to be one of its most popular. As the policy has been historically geared towards Pillar 1 funding, based on the size of the farm, this has failed to support higher welfare systems of production and created conditions allowing more intensive farming methods.
4. The RSPCA set out in Into the fold: targeted financial support to improve farm animal welfare [1] . The RSPCA proposes a two tier farm payment system: Tier one is a 'transitional payment tier' whereby payments are awarded to producers for implementing measures that help them towards meeting Tier two. Tier two payments are awarded to producers that are members of a formally recognised higher welfare farm assurance scheme, i.e. schemes that deliver the RSPCA's higher welfare standards or equivalent, cover the whole life of the animal (birth/hatching to slaughter), apply validated welfare outcome assessment, and apply the Good Scheme Framework1 to deliver continuous welfare improvement over time.
5. Although the UK has had only one animal welfare scheme since 2007, there have been 50 different animal welfare schemes which have operated in the past 11 years across nine different countries. These have funded around £2 billion worth of animal welfare programmes. The 2017 Commission reviewed the first tranche found these programmes, and recognised their value, outputs and outcomes. Some of these programmes, such as access to pasture for dairy cattle or reducing mutilations in pig farming through payment for intact tails at abattoirs, are in the RSPCA list of suggested pilots.
6. The Bill is essentially an enabling Bill which allows the Minister to make legislative changes under secondary legislation so it is difficult to anticipate what this legislation will propose.
What is good in the Agriculture Bill
7. Animal welfare is defined as a public good (Clause 1) and gives the power to introduce measures to incentivise animal welfare outcomes such as allowing farm animals to express their natural behaviour (Clause 1(f)). This is reflective of the Health and Harmony consultation where over 4,300 responses expressed a desire to see improvements in animal welfare, 52% of respondents to Defra’s consultation selected world-class animal welfare as the most important public good that government should support and 72% felt the Government should set standards to ensure greater consistency in information to improve understanding of welfare at the point of purchase. It is also reflective of the 2nd Reading where a number of MPs highlighted the importance of animal welfare.
8. The Bill sets a new direction for farm support away from direct payments and, instead, towards payments that reward farmers producing goods that better meet public interests, such as products from animals that have been reared to higher welfare standards. (Clauses 7 and 8). The trials to fund improved animal welfare will be crucial in assessing what schemes would work most efficiently post 2027. The RSPCA has submitted 50 schemes that could be trialled in eight different sectors. The RSPCA proposes a two tier farm payment system1: Tier one is a 'transitional payment tier' whereby payments are awarded to producers for implementing measures that help them towards meeting Tier two. Tier two payments are awarded to producers that are members of a formally recognised higher welfare farm assurance scheme, i.e. schemes that deliver the RSPCA's higher welfare standards or equivalent, cover the whole life of the animal (birth/hatching to slaughter), apply validated welfare outcome assessment, and apply the Good Scheme Framework1 to deliver continuous welfare improvement over time..
9. It sets a final date for the end of direct payments (Clause 8) which gives enough time, seven years, for farmers to complete the change over from the present system. However the final date is only seen as a recommendation as the Secretary of State has the power to extend this transition period.
10. The Bill grants powers to improve transparency in the supply chain (Clause 12) including amending marketing standards allowing the introduction of mandatory method of production labelling in sectors such as broilers or pigs (Clause 21).
11. It also outlines a common UK approach to ensuring that the UK meets the WTO rules under the Agreement on Agriculture (Clause 26) whilst allowing devolved authorities to set out their own detailed programmes (Clauses 27 and 28).
Where improvements are needed in the Agriculture Bill
12. The Bill has no funding attached to it and the Government has only agreed funding to 2022, five years prior to when the new system is fully operational. EFRA recommended in July that "Government should commit to fully fund the future agricultural policy and ring-fence the funds that are released from the withdrawal of Direct Payments to fund the rural economy and the environment [2] . The RSPCA agrees. To ensure that there is adequate funding to run the animal welfare pilots from 2021 and there is funding available for these pilots to be part of the new farm system post 2027, the Bill should establish a minimum animal welfare financial envelope as there is no agreement on funding post 2022 (Clause 1).
13. The Bill should also place a duty on Ministers to set multi annual budgets to give farmers funding security to allow long term decisions to be made on what schemes they will operate (Clause 1).
14. The Bill does not contain any goals or future outcomes from the funding streams it is setting up. As an enabling Bill, it may not be able to set specific goals but it should mandate a future Secretary of State that ambitious goals under the framework for future investment need to be set. This could include parameters such as increasing the number of animals in a sector that are being produced under higher animal assurance schemes, and/or reducing animal and health problems by setting disease reduction targets (Clause 2)
15. The market does not work efficiently in many sectors either because the willingness of the consumer to pay more can only be realised where there is mandatory method of production labelling to give them clear advice or where the consumer is able to comparatively easily understand the welfare issues. EFRA recommended that "Government improves country of origin labelling following the UK’s departure from the EU and introduces mandatory method of production labelling." [3] Neither are in the Bill and the RSPCA recommends Clause 21 is amended to specifically allow secondary legislation to be brought in on mandatory method of production labelling in sectors that do not presently have it.
16. The Bill’s Guidance Notes clearly set out that the intention is to improve animal health and welfare and particularly in areas where the outcome would be to reduce use of antimicrobials, such as to counter mastitis in dairy cattle or lameness in sheep and cattle. The RSPCA supports this outcome. Some farm assurance schemes, such as RSPCA Assured, already deliver better animal welfare and through it better animal health. Assurance scheme members are also known to be a lower risk of contravening baseline farm Codes and standards [4] . However the Bill while stating that other operators can be given financial assistance does not define that this can include higher farm assurance schemes to improve animal welfare (Clause 2(4)). We recommend that this is clarified.
17. EFRA recommended "Defra clearly states that it is Government policy that trade agreements should always contain provision to prevent food which does not meet our environmental, animal welfare and food safety standards from entering the country." [5] The RSPCA agrees. Although the Secretary of State has given assurances to EFRA and Parliament that any future trade deals would not be agreed if they allowed in products produced at lower standards to the UK, the Government voted against such an amendment to the Trade Bill in June. As there is no specific obligation on the Government to deliver on this promise the RSPCA recommends that Clause 27 is amended to include language to ensure that improvements in farm animal standards do not leave UK producers at a competitive disadvantage when negotiating future trade agreements.
October 2018
[1] http://politicalanimal.org.uk/wp-content/uploads/2018/03/Into-Th-eFold-web-version.pdf (accessed 02.10.18)
[2] Para 36 https://publications.parliament.uk/pa/cm201719/cmselect/cmenvfru/870/87002.htm (accessed 02.10.18)
[3] Para 106 https://publications.parliament.uk/pa/cm201719/cmselect/cmenvfru/870/87002.htm (accessed 02.10.18)
[4] http://sciencesearch.defra.gov.uk/Default.aspx?Menu=Menu&Module=More&Location=None&Completed=0&ProjectID=16613 (accessed 02.10.18)
[5] Para 105 https://publications.parliament.uk/pa/cm201719/cmselect/cmenvfru/870/87002.htm (accessed 02.10.18)
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