Letter to Alison Pinto of Defra's FMD Livestock Schemes Team, dated 11 June 2001, in response to consultation on proposed amendments to the Livestock Welfare Disposal Scheme.

Thank you for the opportunity to comment on possible amendments to the LWDS. Apologies for missing your deadline by a couple of days but this issue is of intense concern to our Council members and I have therefore sought views widely.

FAWC welcomes any revisions to the scheme that would improve the prioritisation of genuine welfare cases. Clearly, as more markets are opening, it is wrong that an animal fit to travel, fit for human consumption and eligible to be moved in terms of disease control should be presented under the LWDS. However, our main concern is that if the scheme is undermined or overwhelmed, there is a real danger that those with a genuine and significant welfare need will not receive sufficient priority.

Disposal may not be the only solution to what may appear to be serious welfare problems. The concept of "Welfare Vouchers" to enable livestock keepers to purchase items which would improve the circumstances of their animals should be investigated. Such Welfare Vouchers could be used to buy fodder/feed and to pay for the practical assistance required to get fodder, shelter or other necessities onto the farm. This kind of practical help is likely to be more popular with farmers who would prefer to keep their herd/flock than to receive monetary compensation for livestock destroyed.

It is important that a veterinarian experienced in this field does the assessment of welfare, preferably SVS staff reporting to the Divisional Veterinary management structure. Private veterinarians, whilst clearly competent to assess welfare problems, may nevertheless find themselves with a conflict of interest when faced with assessments of their own clients' situations.

FAWC would not support rigid adherence to the first two options bulleted in paragraph 15 of the consultation letter. The Council would find option 3 acceptable, that payments be restricted to farms within Infected Areas or subject to Form D restrictions, provided also that option 4 which includes farms outside these areas is available in the most exceptional of cases. Veterinary assessment, as outlined above, should help to determine the need in all cases.

It is our overriding view, however, that where a farmer is clearly neglecting the welfare of his stock, even after assistance has been offered/provided, then FAWC would expect effective action to be taken rapidly under the relevant animal welfare legislation.

In closing, we would mention that farmers need sensible interpretation of the real risks associated with movement in order to make good decisions regarding their own stock. There also needs to be quicker communication to farmers than has so far occurred when Form D restrictions are lifted.