FAWC has frequently
looked forward to the reform of the Common Agricultural Policy (CAP) as
offering prospects for a beneficial impact on animal welfare. Freeing
agricultural production from the longstanding framework of price support
and output-related subsidies represents a new environment for (at least
some sectors of) livestock production, and the likelihood that there might
be meaningful incentives for the ‘public good’ elements of
agricultural production in the new policy structures had been widely anticipated.
Now the operational details of the June 2003 agreement have become clear
it is possible to better assess the prospects of these hopes being realised.
There would appear to be three distinct ways in which animal welfare could
be affected by CAP reform.
1. ‘De-intensification’.
There is a widespread
impression that the CAP has been responsible for an increase in the ‘intensity’
of agricultural production and that this therefore led to a worsening
of animal welfare on farms. Because subsidy payments under the new CAP
are unrelated to the level of output (‘decoupled’) it is assumed
this will reduce the pressures to intensify and animal welfare will therefore
improve. However, this proposition is too simplistic.
High support prices
and protected markets for agricultural products have undoubtedly led to
a greater intensity of land use (i.e. more productive inputs used per
unit of land) and expanded output, but it is less clear how all this has
affected animal welfare. Stocking rates have risen, but this in itself
is not a welfare concern as long as there is adequate grazing/forage on
the land; 10 sheep per hectare is not necessarily less desirable in welfare
terms than six. There have been increasing numbers of cattle and sheep
on the hills in response to headage payments, but again this is not obviously
welfare negative unless one considers hill livestock farming to be intrinsically
a bad welfare system, or the land has been overstocked to the extent that
animals could not be adequately cared for. There might have been instances
but this seems implausible as a generalisation. The acknowledged welfare
pressure on dairy cows is not simply a consequence of price support causing
farmers to maximise yields because milk quotas have restricted that kind
of response. And in the pig and poultry sectors – where, arguably,
the welfare problems from ‘intensity’ have been greatest -
there has been no support regime, so the CAP cannot be blamed for any
effects that have occurred.
Economic reasoning
indicates that, if farmers have pursued productivity gain at the expense
of animal welfare, it is not CAP pricing policies that are the cause.
Rather, it has been the successive generations of livestock production
technology (advances in the science of nutrition, disease control, genetic
selection, controlled environments, substitution of capital for labour,
etc) that have created the possibilities for exploiting the commercial
potential of farm animals as biological resources, with consequent threats
to their welfare. CAP policies have done nothing to inhibit the uptake
of these possibilities, but they did not cause them to happen in the first
place.
Indeed, it is possible
that the withdrawal of output-linked subsidies, with its widely acclaimed
effect of causing farmers ‘to produce for the market rather than
producing for the subsidies’, could result in incentives to push
animals even harder and thereby make the welfare situation worse. Those
who stay in livestock production will do so for one of two reasons. Either
they will keep livestock largely as a sideline to their core income-generating
activities – an increasingly important motive, and possibly one
that supports good welfare, but this will not represent the bulk of the
production sector. By contrast, those who rely on livestock production
for commercial survival will become increasingly dependent on their ability
to produce competitively in the face of the lower prices from global product
markets, which in turn implies achieving the highest levels of technical
efficiency. This will create renewed pressures to seek the economies of
large scale production, incentives to adopt the latest animal technologies,
a constant search for cost reductions, and a stimulus to exploit further
the biological production potential of the farm animal, thereby loading
more of the externality costs of production on the animals themselves.
The prospects could therefore be for further intensification of livestock
use - the obverse of the naively formulated view of CAP reform. In addition,
the projected fall in total livestock numbers and their concentration
into geographically more dispersed units could mean a decline in the infrastructure
of large animal veterinary practices providing the animal health and welfare
support to farms.
2. Cross compliance
for the Single Farm Payment (SFP).
Support payments are
now to be decoupled from the level of an individual farmer’s output
and embodied in a single annual payment determined by historical claims
in 2000-2002, or paid at a flat rate per unit of farmland, or a mixture
of both depending on country. The receipt of this SFP is subject to satisfying
specified ‘cross compliance’ conditions, and many believe
that these conditions will ensure satisfactory animal welfare in livestock
production, or even lead to its improvement.
There are two elements to the cross compliance conditions. The first -
that farmers keep their land ‘in good agricultural and environmental
condition’ – is unrelated to livestock production. The second
is that claimants must meet the Statutory Management Requirements (SMR),
a set of conditions embodied in 19 EU Directives covering minimum standards
of farming practice; these relate largely to environment, animal identification,
plant and animal health, with only three specifically focussed on animal
welfare (protection of calves, protection of pigs and protection of animals
kept for farming purposes).
Overall the cross
compliance conditions appear unlikely to represent a stringent set of
requirements. The welfare requirements are no more than the existing statutory
minima, and do not approach the Code standards that we broadly equate
with FAWC recommendations, so it is difficult to see any prospect of cross
compliance leading to an improvement in welfare levels on farms. Also
the penalties for non-compliance appear to be quite minor – a 3%
deduction in the SFP for any one non-compliance accumulating to 5% for
more than one case. An inspection regime will ensure that at least 1%
of claimants are visited each year, but even with all the qualifying statements
(‘inspections will be based on a risk assessment’, etc) the
enforcement framework looks to be pretty weak. And the question remains
as to whether, in the light of the prominence that environmental, biosecurity
and food safety issues hold in the scheme of things, animal welfare non-compliance
will be as noticeable or as looked for as the other things on the list
– or even any more than they are now. And again, cross-compliance
in itself can impinge little on welfare standards in the pig and poultry
sectors where producers have nothing in the way of historical claims to
put at risk and may have little land area upon which to claim a flat rate
payment.
It is difficult to
avoid the conclusion that cross compliance under the CAP is vastly over-rated
as a force for better animal welfare, and in reality it is likely to deliver
nothing beyond what the enforcement system achieves already.
3. Payments under
Pillar 2 – the Rural Development Regulations.
A major new element
in the CAP was introduced in the Agenda 2000 reforms in which a new distinction
was created between funding for farm income support (‘Pillar 1’)
and funding for wider economic development in the rural economy (‘Pillar
2’). The 2003 reforms strengthen this distinction with clear objectives
to progressively transfer monies from Pillar 1 to Pillar 2 in the CAP
budget. The process by which this is accomplished (so-called ‘modulation’)
is to reduce the SFP by a specified percentage each year to create funds
for rural development programmes. However, there will be many demands
on these resources.
Many see the real
hope for a beneficial impact on animal welfare in the prospectus of potential
schemes in the Rural Development Programmes. Those schemes include the
possibility of paying farmers if they commit for at least 5 years to apply
more than the usual good animal husbandry practice (undefined), support
being paid on the basis of income foregone and the additional costs resulting
from the commitment given. Annual payments can be up to €500 per
Livestock Unit (i.e. a cow equivalent), but limited to €10,000 in
total; apart from anything else, this implies that the incentives are
progressively weaker for a farm with more than 20 LUs, meaning that virtually
all commercial livestock production in the UK (where, as argued earlier,
welfare pressures are likely to increase) will find little to attract
them in the new arrangements.
There must remain
a question as to what share of the available funding will be directed
specifically towards ‘animal welfare’ schemes. Animal welfare
is grouped under the ‘land management’ heading of funding
areas, along with agri-environment schemes, support for hill areas and
forestry- and this does not augur well for the prominence it is likely
to attract, since the environment and forestry have much more strongly
established images as appropriate candidates for ‘public good’
funding. The other nominated headings under the proposed Rural Development
Regulation for the years 2007-2013 are: ‘competitiveness of farming’
- covering training, new entrants, advisory services, farm modernisation,
food quality and producer group schemes; ‘diversification of rural
areas’ – development of non-farm businesses, tourism, rural
services; and the LEADER schemes which promote local initiatives for local
problems. None of these offers direct incentives for animal welfare improvement,
but all represent a formidable array of options for spending the limited
Pillar 2 monies.
This is disappointing
to those who believe that something more will be achieved, because on
paper the Pillar 2 programmes represent the most plausible possibilities
for the reformed CAP to have a directly beneficial impact on animal welfare.
The reality is, however, that the creation of Pillar 2 funding is intentionally
directed towards objectives of developing activities in the wider rural
economy and quite explicitly shifting the emphasis away from a focus on
agriculture as the core recipient of rural support. In such a context,
incentivising changes in the way animals are treated on livestock farms
will, almost inevitably, come a poor second to the more ‘popular’
objectives of farm diversification, environmental enhancement and creating
employment for the rural population which the reformed CAP will now embrace,
and which will therefore take the lion’s share of the money.
Conclusion.
Overall, while there
are some possibilities (but really only in the Pillar 2 frameworks) for
CAP reforms to beneficially affect the welfare of farm animals, it is
questionable how much those possibilities will be turned into realities
in practice. The likelihood is that it will be patchy and unsystematic,
with some interesting special cases, but overall not providing the kind
of widespread pressures/incentives for the uniform adoption of the ‘appropriate’
welfare standards that FAWC advocates.
We therefore reach
two conclusions. First, the new CAP policy measures will almost certainly
not deliver more than, and possibly not even as much as, market-based
initiatives such as the wider participation in farm assurance schemes
and the demand-led growth of welfare branded products. More critically,
it is difficult to see what CAP reform will do to ameliorate the obvious
welfare problems in modern livestock farming which continue to concern
FAWC. These include lameness in cattle and in broilers, skeletal damage
in laying hens, sheep scab and internal parasites, behavioural stress
in fattening pigs and poor stockmanship.
FAWC is firmly of the view that clear and strong Ministerial support is
essential if the possibilities for animal welfare improvement under Pillar
2 funding are to be realised. We urge Ministers to explore the different
ways in which future policy in this area can include significant incentives
to improve the way in which animals are treated on livestock farms, and
to ensure that such schemes receive adequate emphasis.