Why lower IPPC thresholds?

UK - Long term, reducing herd-size thresholds will not markedly increase the number of pigs covered by IPPC, reports Digby Scott.
calendar icon 8 February 2007
clock icon 10 minute read

National Pig Association

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.

But it will hasten the demise of smaller commercial producers, who may be the very people who leave a smaller footprint on the environment. These producers would be driven out by red-tape and soaring costs. If the IPPC threshold were reduced from 750 sows to 350 sows, the extra cost to the United Kingdom industry would be nearly £12m, according to economists.

It could even be argued that on a cost:benefit analysis the most sensible thing Brussels can do is increase thresholds, not reduce them. However, the European Commission is keen to explore whether thresholds should be reduced, and whether dairy cows should join pigs and poultry under the IPPC umbrella.

“We have to vigorously oppose any attempt to lower thresholds because it would have a devastating affect on our industry,” says National Pig Association's Ian Campbell. “But unfortunately as we fight this battle we risk obscuring our key message, that the pig industry is very keen to reduce its impact on the environment and believes that with the right encouragement and framework it can make significant improvements.”

He stresses that all thinking pig-keepers are keen to reduce their output of nitrogen and phosphorus, their expenditure of carbon, and their use of water – not least because in so doing they will be cutting their costs of production.

“Unfortunately IPPC - as administered by the Environment Agency - is the worst mechanism imaginable to make this happen, because the red-tape costs it loads onto farmers burn up the very money that could otherwise be used to introduce greener management on the farm.”

Defra has calculated the annual cost of IPPC on pig and poultry units in England will be £20 million a year. Over 80 percent of this is attributable to actions farmers will have to take on farm, the rest from fees to the Environment Agency.

Reducing thresholds will greatly increase the number of pig units that have to apply for an IPPC permit but will lower the benefit to the environment per unit of production, according to the National Farmers Union.

It points out that reducing the lower limit of IPPC below, say 500 sows, would give little long term benefit as, given current trends, the majority of commercial units will be above 500 head anyway by 2020. All it will achieve is a stampede of smaller producers out of the industry.

It would be hard to find anyone in the pig industry, and perhaps even in Defra, who doesn't believe that IPPC is bad regulation as far as pigs and poultry are concerned.

  1. It adds cost.
  2. In adds bureaucracy.
  3. It is susceptible to gold-plating (as in England) and therefore distorts competition between European countries.
  4. It loads cost onto an arbitrarily selected size of producer, regardless of whether he produces more emissions per kilo of pigmeat produced.
  5. No targets are included in the legislation.
  6. No deadlines are included in the legislation.
  7. No estimation is given of the potential outcome of IPPC ‘Best Available Technique' implementation.

Farming organisations argue that IPPC is a classic example of bad regulation and should therefore be an obvious target under the Commission's declared aim to reduce and improve regulation.

One of the reasons IPPC is so disliked in England is that it is being implemented by the Environment Agency in a way that makes it impossible for pig-keepers to engage positively and enthusiastically with the process. This is an own-goal for the Agency and indeed for society at large, because the real victim is the environment.

So clear is the English pig industry that the Environment Agency's implementation of IPPC is flawed, it is considering creating its own voluntary scheme which will seek to carbon-print the industry. This will catapult pig-keepers into the limelight and help them add value to English pork and also to cut costs.

According to a report commissioned by the pig industry ‘carbon footprints' are gaining in popularity around the world - and a demonstrably green English pig industry would lead the way in agriculture, and go down well with consumers and retailers alike. The Environment Agency could have introduced IPPC in this proactive manner but pig-keepers believe it lacked the imagination and the will.

Instead it is turning farmers' potential investment cash into dead money by charging pig-keepers thousands of pounds every year for the privilege of having Agency employees painstakingly check, and double-check the process of IPPC, rather than concentrating on outcomes. “Working to saving the environment should be a win-win for everyone. It should be something we all want to engage with enthusiastically,” says NPA's Ian Campbell. “I can't help but think the Environment Agency, in its present form, has missed a major opportunity. Perhaps it just isn't the body for the job.”

There is every probability that Brussels will seek to extend IPPC at some point in the future. When it does, the outcome will be to load disproportionate cost onto smaller producers.

It may therefore be necessary for NFU and NPA to argue for a tapered system of subsistence fees, as someone with 100 sows could not be expected to pay over £2,000 a year to the Agency just for the privilege of having his unit forensically inspected. This would suggest less complex inspections for smaller units.

But NFU is clear that thresholds do not need lowering at all. It points out that as production continues to gravitate into fewer and larger units, the IPPC net will catch more pigs anyway. Herds below 500 sows have continued to fall in the United Kingdom.

United Kingdom breeding sows
Under 100 100 to 200 200 to 500 500 to 1000 1000+ Total
Animals 1997 118,028 140,188 274,197 158,240 101,231 909,912
Animals 2005 72,902 52,751 128,408 146,208 73,062 546,233
+/- percent -38 -62 -53 -8 -28
Farms 1997 6,549 987 892 237 61 15,274
Farms 05 5,947 373 407 200 51 12,924
+/- percent -9 -62 -54 -15 -17

Looking forward, it is expected this transition to larger herds will continue as producers below 500 sows either expand or quit. Meanwhile the relatively small contraction in the number of animals in the 500-1000 group suggests that herds within this group are expanding, to improve production and efficiencies.

(The small drop in herds below 100 head is a result of the combined effects of reduced herds between 20-100 head and an increase in small herds of below 10 animals.) Reducing the lower limit of IPPC to below 500 would appear to give little long term benefit as given current trends the majority of commercial units will be above 500 head by 2020 anyway. All a reduction in thresholds will achieve is to encourage smaller producers to leave the industry faster.

The same is true of the finishing herd, where the current IPPC threshold is 2,000 pigs. The 66 percent of pigs already in the 6 percent of herds of above 1000 head is likely to increase over time; therefore any reduction in the threshold is unlikely to significantly increase the number of animals covered, says the NFU.

So what would happen to the United Kingdom pig industry if IPPC thresholds were dropped to, say, 350 sows and 1,000 finishers? According to NFU, the number of pig finishing units covered by IPPC would increase from an estimated 370 to 925, whilst the number of sow units would increase from 160 to 454.

If the threshold were lowered to 350 sows/1,000 finishers
Animals covered
Current Increase Percentage increase
Sows 177,000 162,000 91
Pigs 1,300,000 833,000 64
Estimated annual permitting costs £
Current Increase Percentage increase
Sows 481,000 884,000 184
Pigs 1,112,000 1,668,000 150
Estimated total annual costs £
Current Increase Percentage increase
Sows 2,248,000 4,131,000 184
Pigs 5,199,000 7,798,000 150

The increased cost to the pig industry would be just under £12million a year. However the introduction of IPPC for dairy farms at even the 400 cow level would appear to affect only an estimated 1.6 percent of farms, and 8.3 percent of animals.

Farmers representatives will point out to the European Commission that increasingly producers must be competitive on the world stage and a level playing field across just the European Union is no longer sufficient. United Kingdom pig-keepers will need no reminding that increasing costs of production whilst simultaneously opening markets to competition is a recipe for disaster. The stalls ban halved the size of the industry.

The Swedish egg industry suffered similarly when conventional laying cages were banned there. Lizzie Press of BQP has acquired considerable experience of IPPC in the process of helping BQP contract breeders and finishers apply for their permits. Currently 11 percent of BQP pig-keepers are over the IPPC threshold, representing 11 percent of 25 percent of pig places.

She is clear that the Environment Agency is not proficient at disseminating ‘incomprehensible' paperwork and pig-keepers would have been sunk without the assistance of Nigel Penlington of BPEX and Diane Mitchell of NFU. And how, she wonders, can farms be expected to implement changes to comply with IPPC when their coffers have been sucked dry by Environment Agency charges of over £3,000 for processing each application?

James Black, one of the original negotiators on behalf of the pig industry, says the way IPPC is being introduced in the United Kingdom detracts significantly from the potential to achieve positive outcomes. ‘In spite of the considerable effort that went into negotiating with the Agency over reducing charges so that the financial burden of application would be removed, the Agency insists that ALL costs have to be recovered.

‘Fundamentally this means that instead of funds being used to attend to possible environmental improvements, they are being exhausted in paying what is tantamount to a tax on production for larger operators.' The natural consequence of reducing thresholds is that smaller operators will become even less viable.

‘The only way the fundamental ethos of IPPC - which is to lower harmful emissions - can be achieved is by a much greater engagement with industry in terms of understanding the issues and encouraging Best Available Techniques. ‘If the industry has already had all its financial resources sucked out in application fees and time taken up filling in paperwork – in other words, Process - there is very little left to attend to changing systems and practice – in other words, Delivering Outcomes.'

Like others in the industry he is convinced most pig-keepers are keen to engage in the process of reducing emissions. But he fears the Environment Agency has knocked the enthusiasm out of them. His formula for the way ahead: Set baseline emission targets, so that polluters pay and non-polluters don't.

Introduce charges scaled to emission levels rather than flat fees. Provide better information support. Encourage greater industry and scientific input into the mix for the development of Best Available Techniques.

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