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IPPC red-tape could cause mass exodus from pig industry

by 5m Editor
7 October 2004, at 12:00am

UK - Although it is stable now, the national pig herd could fall to below half a million sows in 2006 because producers don't think there is sufficient profit in pigs to justify the expensive and time-consuming task of attempting to comply with pages and pages of Integrated Pollution and Prevention Control small print.

National
Pig
Association

National Pig Association
THE VOICE OF THE UK PIG INDUSTRY

NPA is active on members' behalf in Brussels & Whitehall, and with processors, supermarkets & caterers - fighting for the growth and pros-perity of the UK pig industry.

Nobody has the faintest idea how many producers will apply for IPPC permits come the January deadline in two years - including the Environment Agency, which is responsible for interpreting, implementing and policing the rules.

But some leading producers are in no doubt the deadline will be the trigger that makes several hundred producers downsize or quit the industry altogether.

"Today there may be five hundred producers who will need an IPPC permit - but when it comes to January 2007 there will be only a hundred because four hundred will have decided they just can't do it," predicts Yorkshire producer John Rowbottom.

This view is supported by Nick Green, operations director of Somerset-based Alvis Brothers. "If IPPC isn't handled carefully it could be the final straw. It could be the downfall of the British pig industry," he told a recent NPA meeting.

When pig producers in Britain asked for a delay in the implementation of IPPC they were given to understand that Defra officials were unimpressed by their whingeing. The request was curtly dismissed.

But the quantity of new legislation being heaped on intensive livestock farmers is now widely viewed by pig producers as out of control and posing a serious threat to the industry's survival. In such circumstances, the suggestion they are whingeing instead of 'being positive' is seen by many as both unhelpful and insensitive.

However, despite the industry's cry for help over IPPC being dismissed, Defra has recognised that the legislative burden on farmers has now become serious, particularly as most farms are small family businesses without dedicated staff to look after the growing red-tape workload.

Defra has set up a new unit - the Farming Regulation Strategy Division - to look at the cumulative effect on farmers of the growing burden of rules and regulations, most of which are being introduced by Brussels and which in turn have to be implemented in this country by our government.

The unit will produce a strategy - in about a year's time - that has the potential to make a significant difference to the ways farming and the countryside is regulated. It is expected that the strategy will impose new disciplines on Defra and more importantly on the department's associated agencies, such as the Environment Agency.

One strand of the work will be to look at whether the current drive to control every aspect of farming life is actually achieving what Brussels and government wants to achieve. Another, will be to consider the size of a farm in relation to its ability to handle new regulations.

Although assurance schemes are theoretically voluntary and in any case are nothing to do with Defra, the department's red-tape unit recognises such schemes place a considerable load on farmers, and therefore it is important to avoid duplication.

It will also investigate claims by producers that new rules imposed by Defra - or more likely its agencies - sometimes conflict with other rules. Yesterday Yorkshire producer Richard Longthorp highlighted such a difficulty. As a member of his local internal drainage board, one of his concerns is the legislation flowing from Brussels' on habitats, waste and nitrates, which is likely to impact on how frequently ditches can be sludged out and what happens to the sludge.

None of these constraints seems reflected in the proposed cross-compliance good-agricultural-and-environmental-condition rules which state that ditches should be kept clear to help the flow of drainage water. "There does appear to be something of a conflict here," he observes.

As a result of the Defra red-tape unit's work, it is anticipated that in future new regulations will not be introduced in isolation. Defra will first consider their cumulative impact on the industry and it will look at them in context with all other regulations.

Defra's Darius Campbell says the intention will be to ensure the department does not inadvertently introduce the straw that by breaks the camel's back. "Our overall aim is to look at legislation in future from the farmer's perspective, rather than the administrator's perspective," he told a recent NPA meeting.

Importantly for pig producers, when the new red-tape strategy is introduced, it will also apply to the non-government organisation agencies as well. And it is likely to insist on more transparency - so that if, for example, the Environment Agency wants to increase (again) the IPPC permit charges, it will first have to explain how it has arrived at its figures.

"The agencies, rather than Defra, are my greatest concern," said Nick Green at NPA's September Producer Group meeting. Organisations such as the Environment Agency could produce so much red-tape when implementing Defra policy that the whole exercise became counter productive… "and some producers just refuse point blank to look at it."

NPA policy manager Ann Petersson is worried that the implementation of new regulations can be out of proportion to the problems they are designed to overcome, especially where Britain's shrinking pig industry is concerned.

In many cases the pig industry contributes only a few percent to environmental problems and IPPC measures, for instance, can therefore be disproportionate, particularly bearing in mind the national herd has shrunk 40 percent over the past few years and is therefore a smaller polluter anyway.

"Contrary to what some parts of Defra may think, the pig industry is different from other industries; pig producers cannot recoup extra costs from the market."

There have been concerns in the past that cost assessments carried out by Defra, before introducing new legislation from Brussels, have not accurately portrayed the true cost to pig producers. "Our main message is to be very careful about the cost impact because the cumulative effect on our industry is considerable."

Another problem facing British pig producers is the catch-all nature of legislation coming out of Brussels. The absurdity of trying to produce legislation that is meaningful to a continent made up of different countries and cultures is highlighted by Ian Campbell, NPA regional manager. In Britain, for instance, and in marked contrast to the continent, a third of our breeding herd is outdoors and rules that apply to indoor production invariably fail to make sense when imposed on outdoor producers.

Producer Charlie Allen has made a plea for simplicity. "I'm happy to comply with everything but can I have it in one block, including assurance? Otherwise we may all as well go home." He says producers are doing their level best to come to terms with the flood of new red-tape "but there is a limit to how many hours of the day we can spend filling in forms."

The problem for pig producers is that on the one hand they are struggling with the costs imposed by new regulations, and on the other their buildings are falling apart because of lack of profitability in the industry.

"The last thing I want to do is put my hand in my pocket and invest in my pigs if in three years there are lot more new measures that we don't even know about yet," said East Anglia producer Simon Watchorn. "Borrowing money to invest is a very big risk for pig producers and that is why so many are just limping along and when their buildings are completely worn out they will retire," he told NPA Producer Group.

John Rowbottom said: "We haven't made money for five years and it is going to be very difficult to make money in the next four or five years. It just doesn't add up. I would laugh at all this legislation if I had a profitable pig business."

The problem for producers of any size is that at the moment they simply cannot tell whether IPPC is something they will be able to come to terms with, or whether the Environment Agency's interpretation of how it should be implemented will prove untenable.

Not all the omens are bad, however. Whilst it is true that putting together an IPPC permit application requires the collection of copious quantities of data, much of that data may already be on the farm computer in one form or another. So the red-tape burden may not be as great as is currently imagined.

The industry's task now is to constantly scan the horizon. It is likely that even as you read this someone, somewhere in Brussels is drafting new rules that have the potential to create havoc on farms in ten years. Farmers' organisations need to be ceaselessly vigilant so that they can start making representations as soon as they see storm clouds gathering.

  • Applications for IPPC permits must be submitted between November 2006 and January 2007 by producers with 750 places or more for sows; or 2000 places or more for production of pigs (over 30kg). Current charges for an IPPC permit are 32950 for a standard application; 35900 for a small non-standard application; 36900 for a large non-standard application. The Environment Agency will require pig producers applying for an IPPC permit to prepare a huge amount of detailed information. With this in mind Defra is paying Adas Consulting Ltd 3119,000 to produce for pig producers an understandable package of tools, in the form of model applications, or templates. The templates will use straightforward language and, where applicable, a concise bullet point format.

Source: National Pig Association - By Digby Scott - 6th October 2004

5m Editor