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Rural development programme for England 2007 - 2013

22 May 2006

Thank you for the opportunity for FAWC to comment on proposals for the next Rural Development Programme for England 2007 – 2013.

Our detailed comments are outlined below:

• The Secretary of State, Margaret Beckett, states that the aim of the Rural Development Programme (RDP) is to “focus the resource on action that will add most value to rural policy outcomes”. The complete omission of animal welfare from the Programme, as expressed in the consultation document, significantly detracts from this aim.

• A core principle stated in the consultation document (Point 14.(i)) is to focus funding to support Defra’s strategic priorities and government commitments, such as those in the Strategy for Sustainable Farming and Food. This Strategy includes the aspiration that “the promotion of animal welfare and protection against animal disease is at the core of the way in which we farm and live”. Thus the proposed RDP is inconsistent with this core principle and it is essential that this inconsistency be addressed (moreover, under the Protocol on Animal Welfare annexed to the Treaty of Rome, EU Member States are required to pay full regard to the welfare requirements of animals in formulating and implementing agricultural and other policies).

• The proposed three themes of the RDP are based on the axes of the EU Rural Development Regulation (RDR). Axis 2 is ‘Improving the environment and the countryside’ (Theme 1 of the RDP). Animal welfare could be explicitly included under this Axis/Theme but is not.

• Mention of animal welfare (specifically “animal welfare payments”) is included amongst the measures listed under Axis 2 (given as Annex A in the consultation document), as envisaged under the EU RDR. This is the only explicit mention of animal welfare in the RDP. However, there are other measures under the three EU axes that could beneficially include animal welfare.

• It is likely that there will be an increase in the use of livestock as environmental management tools and an increase in conservation managers using livestock (including rare breeds) to improve habitats. It is important that all relevant parties are appropriately competent and trained to protect animal welfare, and that the use of rare breeds is appropriate and their welfare safeguarded.

• Environmental Stewardship (Point 27) should include provision for protection and improvement of animal welfare.

• Proposed priorities under the RDP (Point 41) do not mention animal welfare and this should be included, for example under 41.(v) which could read ‘Protect natural resources and animal welfare’.

• Theme 2 should include welfare considerations in helping to develop market niches for animal welfare ‘friendly’ livestock products which can help to make livestock producers more competitive. This could include ‘skills and knowledge transfer’ concerning good stockmanship and good practice. This would improve welfare to better meet market requirements, and encourage ‘innovation’ in the collaboration between producers and others in the food supply chain to improve animal welfare (e.g. by good practice during transport, at markets and at slaughter, and by shortening time and distance of animal transfers). It would also encourage development of new markets for high welfare food products. Business improvement tools such as benchmarking need to include welfare considerations, such as welfare benchmarking.

• Theme 3 could include animal health and welfare plans under Point 54. Key challenges for this Theme should include mention of welfare under Point 56., alongside the environment.

• Under Point 58. on Leader, FAWC believes that animal welfare considerations are part of an integrated development approach.

• In Annex A, Axes and Measures, animal welfare considerations should be included under –

Axis 1

Improving competitiveness of the agricultural and forestry sector:

(i) vocational training and information actions (e.g. on welfare friendly systems and market demands),
(ii) use by farmers of advisory services and setting up of advisory services (e.g. regarding high welfare systems and markets),
(iii) agricultural holding modernisation (e.g. for higher welfare production systems), and
(iv) adding value to agricultural products (e.g. by developing market niches for high welfare products which add value and obtain price premia).

Axis 2

(i) agri-environment payments – in terms of cross compliance with welfare standards and the explicit inclusion of welfare within Environmental Stewardship,
(ii) specific welfare payments to producers for higher welfare production systems,
(iii) handicap payments for farmers (e.g. to those who may be disadvantaged in producing livestock to higher welfare standards due to the high costs of changing to welfare friendly production systems), and
(iv) support for non-productive investments (e.g. to improve welfare).

(Axis 3 appears to contain little of direct relevance to animal welfare.)

Annex C of the consultation document gives reasons from Defra as to why it is proposed that certain measures be excluded from the RDP. These include:

(i) Helping farmers to adapt to demanding standards.
FAWC would recommend that consideration be given to (short term/transitional) welfare payments to livestock producers to help them to adapt to higher welfare systems
(ii) Supporting farmers who participate in food quality schemes.
FAWC would recommend consideration of such support to farmers participating in new high animal welfare schemes, and
(iii) Animal welfare payments.
FAWC would recommend consideration of such payments, at least in the short run, to encourage higher animal welfare production practices.

Specific comments on the Uplands Reward Structure Consultation Document

• 1.9 Environmental Stewardship should explicitly include animal welfare considerations.
• 1.16 should read ‘Protecting the countryside, natural resource and animal welfare’. The sustainable farming and food heading does include animal health and welfare - unlike the main RDP strategy document – which is inconsistent.
• Nothing is actually said about welfare in the document. The emphasis is on payments to SDA farmers based on participation in agri-environment schemes. It is important that animal welfare considerations are incorporated into these schemes.

In summary, the consultation document for the new RDP is disappointing in its almost complete omission of animal welfare. It appears to the reader that Defra has either decided that animal welfare (unlike ‘the countryside and environment’) does not need to be explicitly addressed in the RDP but is better addressed using other policies, or has failed to give animal welfare due consideration. This is not an appropriate way forward and should be rectified otherwise –

(i) the RDP will not be wholly consistent with other policies, and
(ii) an opportunity will have been lost to improve animal welfare (and animal health) to the overall benefit of both livestock producers and society generally.

We hope that these comments from FAWC are helpful.