Memorandum submitted by Dr Tom MacMillan
on behalf of the Food Ethics Council
1. The Food Ethics Council is a charity
that works as an independent think tank and advisory body. The
organisation promotes ethical decision-making that leads to better
food and farming. The Council is chaired by a farmer and its members
include consumer advocates and leading academic researchers.
2. The Council welcomes the Committee's
inquiry and this opportunity to comment, and would be glad to
provide further evidence on request.
3. This short response draws on research
for a discussion paper that the Food Ethics Council published
in December 2006, which fed into a policy workshop organised by
the Sustainable Development Commission. Copies of that discussion
paper and a report of the workshop have been submitted with this
memorandum [not printed].
4. We respond below to three of the questions
posed in the Committee's call for evidence.
Question 1: Objectives of the CAP
5. Many areas of the economy and public
life are subject to special policies, including health provision
and the defence industry. While the founding rationale of the
CAP has weakened, agriculture needs a distinctive policy framework
into the future because:
— Agricultural supply is less
elastic and more insulated from changes in consumer demand than
other sectors due to its dependence on ecological processes and
the structure of the supply chain.
— Food production has a major
impact on public health.
— Agriculture has a disproportionate
impact on land use, the environment and animal welfare compared
with other economic activities.
— Agricultural trade has an exceptional
impact on the wellbeing of people in developing countries who
depend on farming for a livelihood.
6. A common policy framework for the EU
is essential because only a common approach can:
— Redress the harmful legacies
of previous CAPs.
— Command the resources needed
to safeguard the common environmental, social and cultural heritage
in EU agriculture.
— Enable member states to be a
progressive influence within international negotiations on agriculture.
7. The CAP of the future should help to
make EU agriculture sustainable and the sum of its products healthier.
It should:
— Promote public access to safe
and nutritious food.
— Enable viable, diverse and dignified
rural livelihoods.
— Respect the biological limits
of natural resources, combat climate change and be a net contributor
to the environment.
— Achieve consistently high standards
of animal health and welfare.
8. It should pursue these aims:
— Now, yet also sustain the social,
economic and natural resource base into the future.
— Within member states and for
all third countries that the CAP affects.
— Recognising that agriculture
supports and depends on other aspects of rural development.
9. Interventions under the CAP are only
justified when the market would not otherwise meet these aims,
and if they comply with the following principles:
— Public spending may only be
made to reward the provision of public goods.
— Public goods are rewarded at
best value to the taxpayer, taking into account that agricultural
systems are ecologically and socially complex.
— Public investment must reduce
the need for such payments in future.
— Price and trade interventions
(market mechanisms) must counteract the dumping of agricultural
produce internationally.
Question 4: Market mechanisms
10. Reform of the CAP's market mechanisms
is necessary in the interests of EU consumers and taxpayers, and
in the interests of international development.
11. Broad consensus exists about the need
for some of the specific reforms that have been proposed, for
example in HM Government's Vision for the CAP. Principal
among these is the proposal to eliminate export subsidies.
12. The advantages to international development
and to EU citizens of altogether eliminating other market mechanisms,
including import tariffs, are less clear. While it is expected
that the removal of many current mechanisms would yield widespread
benefits, it does not follow that having few or no market mechanisms
at all offers the best outcome.
13. The claim that eliminating market mechanisms
is to the best advantage of people in poor countries, which is
the most persuasive rationale for pursuing such an approach, may
rest on at least three questionable assumptions:
— That less market intervention
is best for international development—The World Bank view
that eliminating market mechanisms in the US would help to raise
world prices has been challenged by researchers at the University
of Tennessee, commissioned by Oxfam USA.[9]
According to their models of US agricultural reform, market management,
where some market interventions are maintained, offers the best
deal for poor countries. The US analysis does not translate to
the EU, of course, but in the absence of similar research on the
CAP it raises the question of whether proposals to date have considered
a sufficiently broad range of plausible policy scenarios.
— That other conditions will be
met—As the Vision for the CAP notes, major benefits
to poor countries from EU liberalisation depend fundamentally
on additional conditions being met, including investment in the
infrastructure needed to trade, help with adjusting to "preference
erosion" and protection for poor countries from forced liberalisation.[10]
These conditions are not being met and it is questionable whether
they will be, since they are not integral and enforceable components
of the agricultural trade framework. In making informed comparisons
of the pros and cons of different CAP reform packages for international
development it is important to consider their effects under scenarios
where these accompanying conditions are not fully met.
— That rising GDP trickles down
to the poorest people within poor countries—It is widely
accepted that eliminating market mechanisms in the EU would lead
to pronounced winners and losers among poor countries. So, too,
within them. Where poor countries benefit economically from liberalisation
of the CAP, a substantial portion of those rewards may fall to
large landowners and international companies. Corporate concentration
in the food supply chain creates its own market distortions and
puts producers in a weak position to benefit from increased access
to EU markets.[11]
Indeed, EU market access is irrelevant to many small-scale producers
who will continue to depend on local and regional trade, including
the half of the world's 852 million hungry who live in remote
rural areas.[12]
If the effects of CAP reform on international development were
modelled in broader terms, with a greater focus on distributional
issues compared with GDP, the optimal reform package might not
be wholesale liberalisation. It is unclear how far current analyses
of the effects of alternative CAP reform packages rely on GDP
as a proxy for international development, compared with broader
concepts of wellbeing in keeping with the principles of sustainable
development.
14. By questioning these assumptions we
do not mean to imply that introducing new mechanisms is necessarily
preferable to eliminating them in the manner that HM Government
proposes. However, it would seem prudent to explore, for example
through economic models, the possible effects of a broader range
of CAP reform scenarios, beyond simply dismantling current market
mechanisms.
15. Alternative reform scenarios might consider,
for example, the effects of mechanisms that reduce imports of
animal feeds or the effects of market mechanisms designed to offset
any indirect subsidy to production from CAP payments to EU farmers
under Pillar 2.
16. In evaluating the possible effects of
different packages of market mechanisms, it is crucial to ensure
that the criteria used correspond to the objectives of CAP reform.
If a major objective is to promote sustainable development internationally,
in keeping with Defra's notion of "one planet farming",
then evaluation criteria need to consider likely environmental
impacts beyond the EU, for example to biodiversity or climate
change. If an objective is to promote international development
and combat poverty, then evaluation must go further than simply
considering the effects on the GDP of poorer countries.
Question 9: the CAP and climate change
17. The CAP can contribute to the mitigation
of, and adaptation to, climate change because it is an important
factor affecting land use across the EU. It can include incentives
and penalties that encourage land uses that result in lowered
emissions of greenhouse gases or act as carbon sinks. It can also
speed up changes in land use to adapt to a changing climate.
18. A wide array of instruments under the
CAP might contribute to these ends. In designing and implementing
such instruments, it is crucial to consider that:
— The UK and the EU's food will
come from somewhere and climate change is a global problem. Hence,
measures that lower the climate change impact of land uses within
the EU, for example by reducing agricultural production, may result
in a net increase in greenhouse gas emissions from our land use
and from the food we eat. If we produce less food domestically
then we will transport more from further away often, though not
always, having a bigger impact on the climate.
— There is more to climate change
than carbon and more to the environment than climate change. In
"greening" the CAP, we must look for win-wins that mitigate
and adapt to climate change, that bring other environmental benefits,
for example to biodiversity, that are good for public health,
and that contribute to vibrant rural communities and economies.
— In order to identify such win-wins,
it is important to have a well thought-through vision of what
"one planet farming" might look like in practice. At
the moment, there is welcome direction of travel towards a lower
impact food system, but little analysis of whether the trajectory
we are moving along could result in EU land uses and a food system
that could be sustained within its share of the planet's resources.
For example, a "one planet" farming and food system
for the EU might require major shifts towards low-input agriculture
and curtailing food transport by road between EU member states—the
CAP is one package of instruments that could help us rise to that
challenge.
— Even if we recognise that climate
change is a major problem, it does not follow that farming and
our food system should make no net contribution to climate change.
The UK or the EU could make a political decision that food and
agriculture could be net contributors to climate change, offset
by greater savings in other areas, or net sinks, potentially allowing
for greater emissions from other activities. A precautionary approach
would suggest that it is most rational, given the complexity of
climate change and severity of its impacts, to err on the side
of reducing greenhouse gas emissions more than might seem essential
across most activities, including agriculture and food production—this
is the approach taken by Government, in saying that agriculture
should make a net positive contribution to the environment, and
it is an approach that we endorse. However, the political issues
this raises have not been fully resolved. For example, some reductions
in climate change impacts may come at a disproportionately high
social or wider environmental cost. The current debate over cutting
back the air-freight of produce to the UK from poor countries
is a case in point—at issue is not only the climate change
impact, but how sustainable the export of fresh produce is as
a development model.[13]
Such issues warrant more direct policy and public debate.
— Biofuels development, mooted
as one way of mitigating and adapting to climate change, covers
a broad range of activities. At one end of the spectrum, agricultural
waste can be used on farm as fuel, creating a relatively closed
system with a low environmental impact. At the other, energy-inefficient
industrial biofuels production, subsidised at the expense of EU
taxpayers, promises to repeat the economic, social and environmental
mistakes that sustainable development sets out to avoid.
29 May 2007
9 Ray, D, De La Torre Ugarte, D and Tiller, K 2003.
Rethinking US agricultural policy: changing course to secure
farmer livelihoods worldwide. Agricultural Policy Analysis
Centre, Univeristy of Tennessee, Knoxville, TN. Back
10
HM Treasury and DEFRA 2005. A vision for the Common Agricultural
Policy. HMSO, London, December: 7, 56. Back
11
Murphy, S, 2006. Concentrated market power and agricultural
trade. IATP, Minneapolis, MN, August. Back
12
UNDP and FAO estimates cited in Windfuhr, M and Jonsen, J, 2005.
Food sovereignty: towards democracy in localised food systems.
ITDG Publishing, Bourton-on-Dunsmore, March. Back
13
MacGregor, J and Vorley, B, 2006. Are air miles fair miles?
Food Ethics 1(4): 13. Dalmeny, K, 2007 Low-carb diet. Food
Ethics 2(2): 9. Back
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