Agriculture Bill

Written evidence submitted by Bristol Veterinary School, at the University of Bristol (AB52)

Bristol Veterinary School [1] , at the University of Bristol, welcomes the opportunity to aid scrutiny of the Agriculture Bill, and would be happy to have further discussions with the Committee if required.

This Bristol Veterinary School (BVS) response represents the evidence-based views of researchers who participated in a workshop to discuss the aims, intentions, and individual components of the Agriculture Bill, supplemented by specialist expertise of individuals [2] . Further information can be sought in the first instance from Dr Christine Whiting [3] (Research Support and Development Manager) or Ms Rhiannon Wilson [4] (PolicyBristol coordinator, Health and Life Sciences).

This submission considers the overarching aims and intentions of the Bill and does not propose amendments. It seeks to provide evidence to support further scrutiny of the Bill, shaped by the questions raised by the committee in their scrutiny to date.

Part 1 New financial assistance powers

1. We welcome the move to a new system of public money for public goods, and to see that animal health and welfare are prominent on the agenda. There will be benefits to both human and animal health from this new agricultural policy. However, this must not be to the detriment of sustainable food production. Food production will always, to some extent, have an environmental impact, but we have evidence for measures that both improve biodiversity and productivity [5] .

Behaviour Change

2. There is evidence that paying people to change behaviour works [6] , and we are at the forefront of research in this area. However, evidence shows that if payments stop, behaviour change stops. [7] If multiple payments are badly designed, they reduce the effectiveness of the policy aim [8] .

3. Payments should be part of a wider approach; good animal welfare requires working closely with farmers to persuade and support them, providing financial rewards, education and consumer change [9] . Farmer-first approaches work; empowering groups of farmers through group working and allowing them to take ownership of solutions for their farm is an effective way to change behaviour [10] .

4. These sorts of approaches need skilled and professional facilitation [11] . A government-funded, easily accessible pool of trained facilitators to assist farmers in trialling new technologies/innovation, as well as sharing ideas and experiences to enable them to change and adapt, will ultimately make farming communities more resilient.

Animal Welfare

5. We are clear that payments for good animal welfare should not be based on legal minimums. It should be aspirational. For animal welfare inspection to achieve these aims, it needs to be more complex than the current processes and look at animal behaviour [12] , rather than solely compliance with the ‘five freedoms’ [13] .

6. Tiered certification approaches [14] should be considered. Reduced inspections for farms that are demonstrating good animal welfare standards could be considered; prioritising resources towards where risk is highest. However, this assumes that fewer inspections are an incentive for farmers, which may not be the case.

7. The government should consider how to incentivise membership of retailer or certifier schemes whose requirements include activities considered eligible for public good payments. This could both increase and incentivise uptake of activities eligible for assistance and reduce the administrative burden of compliance.

8. The Bill should make it possible for public good payments to be used to mitigate the negative, or transitional, effects of any policy change which will have long-term benefits e.g. to create depots for animals if live export practices change.

9. Animal welfare standards should be at or above EU standards, to give the UK flexibility to exclude imports if not to UK standards.

Definitions of Public Goods

10. We strongly underline that much more detail will be required to define the outcomes that will be measured e.g. water and air quality improvements. A strong evidence base is essential, and payments for improved outcomes is good for science; testing the effectiveness of measures leads to continuous improvement and advances our understanding.

11. However, the UK must balance the need to obtain the highest level of evidence before implementing policy, against the potential risks of delay where the evidence may be less conclusive. The need to obtain quality data before implementing policy can be a barrier where the risks of inaction outweigh those of implementation; progress on antimicrobial resistance is an example of this [15] .

12. We are clear that public goods must incentivise measures to improve animal health and welfare, such as the genetic diversity of stock, or the reduction of antimicrobial resistance.

13. Equally, there are many examples of where the farming industry, or certain sectors, is ahead of the aspirations of the Bill, such as the use of cattle electronic identification tags [16] . AMR research is being implemented rapidly across livestock sectors, evidenced by falling antimicrobial use. It is important that the Bill does not reduce aspirations by providing a limited view of what is achievable or rewarding practices that are becoming increasingly standard.

Inspection and Enforcement

14. There have been suggestions that the new system will require a new lead agency and national framework. We support better collaboration between existing bodies, such as the Food Standards Agency, sector-specific organisations and levy boards, potentially through a cross-body agency.

Part 2 Chapter 1, Clauses 4 -8 - Financial support after Exiting the EU – Direct Payments

Economic Impact of Withdrawing Direct Payments

15. There needs to be further consideration of whether farm support will be based on income foregone or delivery of services.

16. The new system may lead to a changed relationship between the public and farming community; if public perception of what constitutes ‘good’ farming is based on inaccurate assumptions, e.g. dairy cows in housing, there may be opposition to specific public payments or allocations, and the politicisation of eligibility or methods.

17. We are concerned that with the loss of £3 billion of support, agricultural land use will drop, resulting in a price crash. The composition of the farming landscape would change dramatically, and the future of the uplands is uncertain.

18. The existing narrative on the impact of Brexit has been made on commodity price and land price separately. However, these are simultaneously determined variables and must be modelled within a streamlined framework.

19. Evidence of the economic impacts of withdrawing Direct Payments can be derived, and has been derived, using the general equilibrium modelling approach [17] . The approach has produced reasonably accurate estimates of the aforementioned impacts for trade negotiations that took place elsewhere in the world.

20. This approach, however, does not generally provide sufficient insight into the intra-economy distribution of wealth, meaning that implications on domestic income inequality need separate analysis. One way to incorporate this question into the main analysis is microsimulation, although this would require a larger set of socioeconomic data.

21. As net exporters of lamb and importers of beef, Brexit and the withdrawal of the Basic Payment Scheme will result in different strains on the different sectors, and different areas of the UK.

Sheep Sector

a. Uncertainty in this sector is already being seen. Farmers are not sending tups (breeding rams) into some flocks this season due to uncertainty about where the lambs will go in 2019.

b. The potential effect of land price crash is that, due to the resulting low cost of lowlands, no sheep will be kept in uplands. The UK sheep sector will face huge pressure as a result.

c. Recent research [18] demonstrated that sheep numbers will decline and there will be a change in how we see and use the uplands.


d. Grazing livestock in uplands have more roles than food production; such as supporting rural communities, or control of bracken and gorse. We reiterate that, to support rural communities, production must be balanced with public good. Production must be part of a livestock farmer’s business even if it becomes a smaller part, with the rest associated with farming for public good (as defined under Clause 1).

Beef Sector

e. This sector would benefit from reduced land prices. If the UK population continues to consume the same amount of beef, the price of mince is predicted to increase.

Dairy Sector

f. The dairy sector will see opportunities for cheap grazing from reduced land prices. There would potentially be more inclination to have cows out grazing than housed, due to the cost of concentrate feed.

Labour Force

22. As proposed, the new payment schemes in the Bill will require a resulting increase in Official Veterinarians to check, enforce and monitor, adherence with the system, as well as increased numbers of Farm Animal Veterinarians. There is evidence that this career path is not currently popular; recruitment must be considered alongside the implementation of the new financial assistance schemes [19] .

23. Introducing any new system can result in unintended consequences; a larger inspectorate will be needed to identify and resolve any problems as early as possible.

24. The availability of on-farm labour is a current issue affecting farming and will have repercussions on innovation uptake and farmer resilience to adapt to changing landscape [20] .

Part 3 Data collection

25. We welcome the commitment to improved data collection in the agri-food supply chain, and have undertaken, and are carrying out, several research projects of interest. The current situation is that lots of data is collected, but not in a form which ensures all the necessary information is collected, nor is readily shareable. There should be more emphasis on centralisation or standardisation of existing data rather than funding focused on improved technology.

26. Our work collecting antimicrobial resistance/antimicrobial use data has shown that farmers do not want to repeatedly enter data in different systems; a system that relies solely on farmer-entered data could be flawed. [21]

27. We know that existing traceability systems, such as the pig traceability system eAML2 [22] , are not being used to maximum effect. We have examples of how data sharing can be used to improve animal welfare [23] . We need to know what is happening to animals (i.e. medicine usage) rather than simple movements data. The bill should emphasise cross-industry collaboration and sharing of existing data.

28. Technology advances to help farmers collect and record data should be the focus rather than requiring more data points to record. Our work shows that this system is inefficient and prone to human error. For instance, vet prescription data, which is not farmer-recorded data, is proven to be a good proxy for antimicrobial use on farms [24] . Funding will be required to ensure that data is collected, well, and in a usable format e.g. for purchase of barcode scanners, or NFC devices.

Responsible data collection and use

29. If the Bill sets out a premise to have greater access to data, then it also needs to set out the basis to allow this data sharing.

30. Given the commercial nature of many components of the agri-food supply chain, there is a reluctance to share data that is commercially sensitive, even for research purposes. Limits to how Government-collected data can be used must be considered, or there is a risk that data will not be provided.

31. The Government should provide leadership on what data should be collected, pooled and shared between all parties/industries, and could learn from Danish and Dutch models of AMR data collection and centralisation [25] .

32. Researchers may be better placed to look at and maximise the use of data. We advocate learning from mechanisms for human health data [26] to define how animal data can be used for research purposes.

33. Mandating the responsible sharing of data for research/public good purposes, and not for commercial purposes, could allay the above concerns. Clarification as to who is the data controller for farm data could be made explicit in the Bill.


34. There are concerns that the measures proposed in this bill do not consider the specific nature of smallholdings, which is a growing sector. Smallholders are usually not members of assurance schemes or producer organisations. Standardised, centralised technology for food-producing species could be one way to help smallholders meet both their legal obligations and thresholds for incentive payments.



35. Further discussion will be required on how research needs will be identified and funded by industry; the current process - delivery through levy boards – is unlikely to result in research that supports the aims of the new agriculture policy as defined in this Bill. For example, forestry research would not be funded through a livestock levy board without opposition.

36. Allocation of research funding should consider going direct to research via stakeholder groups, such as the successor of AHDB, rather than via producer levies. Where production falls, the need to address research questions may intensify at the very time producer levies generate less money to support research. As a consequence, research ‘for the public good’ should be centrally funded. Any discussions about how to allocate research funding will also need to consider that research institutions have higher overhead costs.

November 2018



[2] Mick Bailey, Professor of Comparative Immunology; David Barrett, Professor of Bovine Medicine, Production and Reproduction; Andy Butterworth, Reader in Animal Science and Policy; Dr Liz Cresswell, Clinical Veterinary Science PhD student; Michael Lee, Professor of Sustainable Livestock Systems; Jon Massey, Clinical Veterinary Science PhD student; Lisa Morgans, Clinical Veterinary Science PhD student; Gwen Rees, Clinical Veterinary Science PhD student; Taro Takahashi, Senior Lecturer in Sustainable Livestock Systems and Food Security; Eleanor Walsh, Senior Research Associate






[5] Wilkinson, J., & Lee, M. (2018). Review: Use of human-edible animal feeds by ruminant livestock. Animal, 12(8), 1735-1743. doi: 10.1017/S175173111700218X


[6] Bennett, R. , Balcombe, K. , Jones, P. and Butterworth, A. (2018), The Benefits of Farm Animal Welfare Legislation: The Case of the EU Broiler Directive and Truthful Reporting. J Agric Econ. doi:10.1111/1477-9552.12278


[7] Evidence from a systematic review and meta-analysis of health behaviour has shown that financial incentives are effective in encouraging behaviour change but these effects stop within 3 months of payment  cessation : Mantzari E, Vogt F, Shemilt I, et al. (2015) Personal financial incentives for changing habitual health related behaviours: a systematic review and meta-analysis. Prev Med. doi : 10.1016/j.ypmed.2015.03.001


[8] B.A. Bryan & N.D. Crossman ( 2013 ) , Impact of multiple interacting financial incentives on land use change and the supply of ecosystem services. Ecosystem Services 2013; 4: p 60-72 doi : 10.1016/j.ecoser.2013.03.004


[9] Reaping the rewards from UK leadership in farm animal welfare: time for a national strategy, PolicyBristol, January 2018


[10] Farmer Clusters, Game and Wildlife Conservation Trust

[10] AHDB Dairy webinar: A farmer-led approach to responsible antimicrobial use on UK dairy farms:

[10] The future of farming policy in the UK: giving farmers a voice in development and delivery, PolicyBristol, January 2018


[11] Rose, D. C., Keating, C., Morris, C. 2018. Understanding how to influence farmers’ decision-making behaviour: a social science literature review, report for the Agriculture and Horticulture Development Board, supported by UEA Consulting Ltd.

[11] Thia Hennessy & Kevin Heanue (2012) Quantifying the Effect of Discussion Group Membership on Technology Adoption and Farm Profit on Dairy Farms, The Journal of Agricultural Education and Extension, 18:1, 41-54, doi: 10.1080/1389224X.2012.638784


[12] Pioneering animal welfare approach with AssureWel, University of Bristol, October 2018


[13] Five Freedoms, Farm Animal Welfare Council [archived]


[14] Red Tractor to launch suite of toughened new standards, The Grocer, September 2018


[15] Targets Task Force Report 2017 in "Industry task force announces new farm antibiotic targets", RUMA (Responsible Use of Medicines in Agriculture) October 2017


[15] Mills, HL., Turner, A., Morgans, L., Massey, J., Schubert, H., Rees, G., Barrett, D., Dowsey, A., Reyher, KK.

[15] (2018) Evaluation of metrics for benchmarking antimicrobial use in the UK dairy industry

[15] Veterinary Record 182,379. doi: 10.1136/vr.104701


[15] Veterinary Antimicrobial Resistance and Sales Surveillance 2017, Veterinary Medicines Directorate


[16] Livestock buyer’s guide: EID readers compared, Farmers Weekly, September 2018


[17] A noteworthy example is the Global Trade Analysis Project, Purdue University

[18] The Future of the Uplands workshop, Birmingham, May 2018, Bangor University – conference report forthcoming

[19] No deal Brexit risks shortages, delays and lower standards, warn vets, British Veterinary Association, September 2018,-delays-and-lower-standards,-warn-vets/


[20] Cofre-Bravo, G., Engler, A., Klerkx, L., Leiva-Bianchi, M., Adasme-Berrios, C., & Caceres, C. (n.d.). Considering the farm workforce as part of farmers' innovative behaviour: a key factor in inclusive on-farm processes of technology and practice adoption. Experimental Agriculture, 1-15. doi:10.1017/S0014479718000315


[21] Rees, G., Barrett, D., Reyher, K., Mills, H., & Buller, H. (Accepted/In press). Storage of prescription veterinary medicines on UK dairy farms: a cross-sectional study. Veterinary Record.


[22] AHDB Pork, Electronic Movement Licensing


[23] Innovate UK awards for studies into sustainable livestock production and improving chicken welfare, University of Bristol, August 2018


[24] Rees, G., Barrett, D., Reyher, K., Mills, H., & Buller, H. (Accepted/In press). Storage of prescription veterinary medicines on UK dairy farms: a cross-sectional study. Veterinary Record.


[25] DANMAP, Danish Programme for surveillance of antimicrobial consumption and resistance in bacteria from animals, food and humans

[25] Dupont, N.H. VETSTAT – Monitoring usage of antimicrobials in animals, ICAR 2013 Health Data Conference

[25] MediRund, database for the central registration of antibiotics in the beef sector, the Netherlands


[26] For example the Clinical Practice Research Datalink


Prepared 13th November 2018