Defra’s Health and Harmony consultation – FUW’s response

Defra’s Health and Harmony: the future for food, farming and the environment in a Green Brexit consultation, closed in april. Whilst large sections of the document relate directly to england, others are relevant to the whole of the UK, and in reality each one of the Defra proposals is in some way, directly or indirectly, relevant to Wales. Just some of the key points made in the fUW’s seventeen page response are provided below.

Farming families

The fact word ‘environment’ appears in the document three times more frequently than either the words ‘farming’ or ‘food’ speaks volumes; little more than lip-service is paid to the wellbeing of individuals, farming families, rural businesses and the rural and wider economy, as well as others involved in agricultural and food supply chains. It’s high time the interests of rural constituents and farming families were given the priority they deserve.

Food prices

Household expenditure on food has fallen by more than 50 per cent in the past sixty years, from 33 per cent in 1957 to 16 per cent in 2017, virtually eliminating food poverty while also having a range of other social benefits.

The UK Government seems to want to maintain the benefits of low food prices while removing the payments which have led to such low prices, with imports of cheap food from countries with lower standards than the eU filling the gap. This is naturally opposed by the fUW.

Capping English payments

The fUW has been a proponent of capping and tapering payments for more than a decade, and fully supported the introduction of the cap currently in place for Welsh payments. Doing the same in england would reduce market distortion and help avoid the disrepute brought about by very high english payments.

But a cap must be applied to both direct payments and environmental payments under any future system – failure to do so will have minimal impact on the majority of those who currently receive high levels of Pillar 1 support in england.

Given that the National Trust, rsPB, wildlife trusts and other charities are already amongst the recipients of the highest sums under the CaP, failure to introduce such a universal cap or taper could see more monies moving to charities and away from the family farms which play a central role in maintaining rural economies.

U Common Agricultural Policy It is essential that UK administrations take note of the
development of the next eU CaP and move to ensure any adverse impacts are mitigated, rather than taking a naïve inward-looking approach which exacerbates market distortion and places UK farmers at a significant disadvantage to their eU counterparts.

‘Leaving the environment in a better state than we found it’ The consultation refers to the Conservative manifesto commitment to ‘become the first generation to leave the environment in a better state than we found it’.

The fUW warns great care should be taken to ensure Government does not leave rural areas in a worse state than they have been since the agricultural depressions of the 19th and 20th Centuries, leading to catastrophic impacts for communities, the environment and landscapes.

Adopting new technology and ideas as well as removing legislative restrictions to new ideas, Governments should intervene where the development or adoption of new and existing technology is stifled because sectors are less profitable and therefore unattractive for companies.

Recognise all rural communities

risks and opportunities exist in all areas, including lowland, Disadvantaged and severely Disadvantaged areas, and traditional farming landscapes exist at all altitudes throughout the country. Policies which fail to recognise this would lead to severe local problems.

Incentivising large scale environmental action across more than one farm
The obstacles to doing this should not be underestimated, and nor should the risk that some charities or other bodies may seek to use such schemes as a means by which to fill their own coffers, preventing money going to rural communities. The degree to which such large scale schemes can create ‘postcode lotteries’ that exclude many areas and individuals, placing them at an economic disadvantage, should also not be underestimated.

Outcome based payments

Outcome based payments should complement a payment system which provides protection for farming families, secondary and tertiary businesses which wholly or partially reliant on agriculture, and rural economies, rather than replacing them.

Off setting

Interventions should be available or allowances made which make up for adverse impacts on production or efficiency. for example, where land is effectively taken out of production, it should be possible to off-set this by allowing improvements to other land, thereby maintaining the productive capacity in a way which also meets public goods targets.

Working with third parties to deliver environmental outcomes

armers can and do work with third parties, but the views of third parties must be fairly balanced against the needs, knowledge and experience of farming families; third parties cannot be allowed to become a local rural inspectorate with inappropriate powers.

Government pilots and other schemes which incentivise and deliver improved welfareGovernment should not run pilots schemes which incentivise and deliver improved welfare as numerous such schemes run privately already exist. safeguards should be put in place by Government to ensure schemes are not merely used by retailers and others to drive down the prices of ‘normal’ produce.

an inappropriate focus on animal welfare in the UK would lead to a net decrease in global animal welfare standards due to the displacement of UK production in favour of products produced to lower standards elsewhere. strict import rules which prevent unfair competition from producers in other countries should be applied.

Welfare improvements would be best achieved by Government interventions which improve animal health, for example by incentivising disease eradication programmes.

Connecting with rural communities and businesses post Brexit
There is an overarching need for Government to reconnect with rural communities in order to gain respect and understanding of these, and to do so in an open-minded way which is not coloured by the urban preconceptions and prejudices which seem so dominant in the UK compared with other countries.

Regulatory baseline could be improved

Improvements could be made to a host of regulatory baselines which would make them more proportionate and more accommodating given potential risks, while simultaneously improving their effectiveness in terms of preventing problems, and costs in terms of implementation and policing.

Agriculture and land management policy areas where a common approach across the UK is necessaryframeworks are needed which ensure, post-Brexit (i) Wales does not receive less than it would otherwise have; (ii) rural funding is ring-fenced; (ii) there is relative uniformity between UK nations in terms of how money can be spent; (iii) rules do not differ to the extent that markets are distorted and unfair advantages develop.

Cross-border farms

The bulk of cross-border problems are the result of rural Payment agency failings, whereas rural Payments Wales generally process cross-border farms expediently.

approaches must be found which prevent problems such as those which occur when two agencies are involved in processing two sets of maps, two sets of forms etc.

International trade

The likelihood that growth in new markets in distant Third Countries could easily make up for the loss of the large and affluent market which is on our doorstep, in the form of the eU, is small.

The UK Government has to be realistic about consumer priorities in markets which are already established for potential competitors such as New Zealand, given the evidence showing that British food has neither a ‘high quality brand’ nor a ‘world- class reputation for quality’: rather, the recent aHDB International Consumer Buying Behaviour report shows that in five of nine countries looked at, those with a negative perception of British food outnumber those with positive views.

The same report also shows that welfare and sustainability are the two lowest consumer priorities, while provenance also scores poorly compared with the two highest priorities – quality and price.

The fUW opposes the proposal to open up UK markets to non eU imports given: (i) The explicitly stated intention is to depress food prices at a time when cuts to farm support are being discussed; (ii) The likelihood that such food will be produced to far lower animal health, welfare and traceability standards than those required of UK farmers by law (iii) The risk that such liberalisation will result in imports from areas where dangerous diseases are endemic (iv) The risk that such products will be produced with the aid of chemicals and drugs which are prohibited in the UK (v) The risk that such liberalisation will compromise the ability of UK farmers to export to the eU without costly administrative burdens and long delays at borders.

Other measures needed in an Agriculture Bill

The agriculture Bill should include a multiannual financial framework which sits outside the Barnett formula and is agreed with devolved nations, which ensures fair levels of agricultural, environmental and rural funding for devolved nations, and continuity in order to avoid annual financial uncertainty for devolved nations, agriculture and the environment.

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