Responsibility and cost sharing for animal health and welfare:
next steps - your views matter
Response form
December 2007
How to respond
1. This response form should be read in conjunction with the main
consultation document “Responsibility and Cost Sharing for Animal
Health and Welfare: Next Steps.”
2. All the questions contained in the main document are repeated below,
along with the paragraph numbers to which they relate.
3. We would welcome your comments on any or all of the questions.
There is also a box for you to add any other comments.
4. If you are using the response form electronically, the answer boxes will
expand as you add text. If you are using a paper version, you can
continue your answers on a separate sheet. Please mark the question
to which you are responding on any supplementary sheets you use.
5. Annex D of the consultation document advises you how to get your
response to us. You do not have to use this form.
6. The Department for Business, Enterprise and Regulatory Reform has
produced six consultation criteria. These are available at
http://bre.berr.gov.uk/regulation/consultation/code/criteria.asp
7. Please ensure your response reaches us by 15 April 2008.
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If you are completing the form electronically the boxes will automatically
expand as you type. If completing a hard copy, please continue on a
separate sheet of paper (clearly showing the question you are answering).
Please provide the following information, to help us deal with your response:
 Your name:
Prof. Wyn Grant, Dr Justin Greaves, Prof. Laura Green, Prof. Matt Keeling,
Prof. Graham Medley, Prof. John McEldowney and Dr Jonathan Cave
 Your organisation (if applicable):
The Governance of Livestock Diseases RELU project, The University of
Warwick
(see http://www.warwick.ac.uk/go/gold for more details of participants)

Your postal address:
Prof. Medley, Dept. Biological Sciences, University of Warwick, Coventry CV4
7AL

Your email address
graham.medley@warwick.ac.uk

Would you like your response kept confidential?

Would you like to be sent further information in future about our plans?
NO
YES
Please send this form to:
Mike Weavers
Defra Responsibility & Cost Sharing Programme
Area 310
1a Page Street
London SW1P 4PQ
Or you can email an electronic version to: rcsharing@defra.gsi.gov.uk
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Response form
2. Reasons for our proposals
Background
para 2.1-2.2
Q1:
Do you agree that a partnership approach to managing disease
control and prevention will lead to reduced disease risk? If so why?
The group has set out its detailed views (in an attached memorandum and in
the responses below) as to the necessity of having a co-ordinated reponse in
disease control and management strategies.
The impact on disease (control, risk etc.) will be disease-specific; partnership
per se will not necessarily reduce the incidence or impact of disease. The ideal
partnership structure for reducing disease (rather than other aims) will vary for
each disease.
The role of Government and industry
para 2.6-2.15
Q2:
If you agree with the approach to handling the risks of animal
disease as set out above, please explain why.
The Government desire to achieve shared responsibilities with different
stakeholders is to be encouraged because it will lead to the more effective
development and implementation of policy. We set out in an attached
memorandum how this might be achieved.
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Q3:
If you disagree with this approach to handling the risks of animal
disease, please explain why.
N/A
Q4:
If you agree with the move away from Government alone
determining intervention, please explain why.
The agricutural sector is one where participation by the various stakeholders
should be encouraged and advanced. This is because relevant knowledge
and expertise are quite widely dispersed and can be most effectively
mobilised through a governance approach that utilises a range of networks,
especially epistemic (i.e. expertise based) communities. This move also offers
advantages in terms of cost (generally cheaper) and compliance (often
higher) as the loci of decision and control move closer to front-line actors. In
particular, giving farmers a genuine voice in determining intervention can
encourage engagement, limit opportunism or free-riding and generally help
align industry and societal interests.
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Q5:
If you disagree with the move away from Government alone
determining intervention, please explain why.
N/A
Q6:
How could the industry demonstrate that the decisions it takes
are objective and take account of the wider interest of the rural
community?
This might best be achieved through some form of regulatory body to engage
with different stakeholders. Its procedures would need to be transparent and
would have to take account of the views of a wide range of stakeholders.
Care has to be taken to balance rights and responsibilities. The livestock
industry is only one aspect of the rural economy. Whilst the industry has
obligations to a broader range of stakeholders (e.g. permanent members and
visitors to the rural community), the rural community has reciprocal
responsibilities to the livestock industry. For example, if tourism gains value
from animal welfare, then it should have a responsibility to support animal
welfare.
The remit of such a body should include harmonisation of the stakeholders'
interests and activities and sustainability of rural communities as well as
animal health and welfare. The possibilities for firms resemble those arising in
the ‘Corporate Social Responsibility’ area - in particular, the promise of
models based on multistakeholder governance (see e.g. National Consumer
Council (2003) “Three Steps to Credible Self-regulation.”)
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3. Responsibility sharing – Vision
Progression from stakeholder engagement to a greater degree of shared
responsibility
para 3.1-3.7
Q7:
Should different sectors be able to proceed with responsibility
sharing at a different pace? If so, does this give rise to any specific
issues in relation to more formalised responsibility sharing as described
in Chapter 6?
Currently, different species receive different levels of government support, but
all comply with the current legal framework. Each sector (species, but taking
into account market sectors such as meat, milk, breeding stock, etc.) should
continue to work within the same framework however it develops. We think
that the sector as a whole should move to a more integrated approach to
animal welfare taking account of the prevention of disease and improvements
in animal health.
Whilst it is inevitable that different sectors will proceed at varying pace, care is
required to ensure that inequalities between sectors are small, temporary and
well-justified in a joined-up policy sense. This does not mean lock-step
development; specific problems affecting e.g. pig farmers or the dairy industry
may argue for a different pace. Note that overlapping stakeholder participation
in sectors will place natural limits on divergence.
Step approach to increasing responsibility sharing
para 3.8
Q8:
Please describe any advantages or disadvantages you foresee
with a stepped approach to developing responsibility sharing.
The advantage of a stepped approach is that it seeks to engage and cooperate with the stakeholders in the agricutural industry. It permits
opportunities for appropriate policy learning to occur as policy develops. It
also has the potential to take into account the ‘natural experiment’ capability
of stakeholders to learn from experience – building the necessary trust and
understanding must proceed incrementally (starting with ‘low-hanging fruit’).
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Q9:
Please describe any additional steps in this approach to
developing responsibility sharing.
Evaluation of the processes and steps to ensure that animal health and
welfare are benefitting from the changes, as well as increasing sustainability,
transparency and cost-sharing.
Q10:
Are there alternative approaches to responsibility sharing that in
your view could be pursued? If so, what are they?
One possibility is to structure the proposed groups as platforms for
‘responsibility trading’ – a forum where people affected by disease (in
different ways) and people with knowledge and power to act can negotiate
over who does what and when. This differs from responsibility sharing in
taking a more flexible approach to the allocation of responsibilities, and in
placing greater emphasis on the development of a suitable mix of individual
and collective responsibility. This balancing would not always occur with either
one-sided or ‘joint and several’ responsibility. Another possibility is a set of
‘natural experiments’ to see what works best in different circumstances.
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4. Responsibility sharing: Current situation
No questions.
5. Responsibility sharing: Possible Future Developments
Joint industry-Government groups
para 5.2-5.4
Q11:
If you agree that disease-based groups is the correct approach,
please explain why. If you disagree, can you suggest an alternative
approach?
Disease-based groups are, in principle, the most effective way to mobilise and
utilise knowledge and expertise relevant to the particular disease. However, it
is not feasible to have a group for every disease / species combination. Care
needs to be taken that this specificity does not come at the expense of a
‘joined up’ approach to disease management as a whole. In particular,
interventions targetted at one disease are likely to affect the epidemiology of
all the others. Consequently, disease-specific groups within sectors (e.g. host
species) should be closely linked. There will be issues that cut across
diseases. There are also issues that cut across regions and across market
sectors (e.g. meat). There may nonetheless be advantages in clustering
around specific diseases if this makes it easier to identify or attract the 'best'
participants and to engage their most public-spirited efforts (or effectively
regulate against attempts to 'capture' or subvert the process).
It seems reasonable that disease-orientated groups could enhance continuity
by monitoring the changing course and impacts of a given disease. Unaided,
such groups might nonetheless struggle to address
1) Overall animal health and welfare (e.g. completing the evolution from
treatment to disease management to health and welfare promotion) and
2) The economic impacts and drivers of compliance and reporting behaviour
'joined-up' at the farm or market sector level.
The currently suggested disease-based groups are determined by the trade
and human health implications of the diseases. Stakeholders are likely to
promote diseases in which they have special interests. Consequently,
diseases for which there is no trade or human health implication but which
have a great impact on welfare and sustainability (e.g. ovine footrot, bovine
mastitis) are likely, as now, to be neglected. This would be an opportunity
missed to improve health and welfare.
The basis for formation of disease-specific groups should be transparent and
evidence-based. It should be possible to develop new groups in response to a
variety of pressures (welfare, sustainability etc.). Old groups should be
disbanded when appropriate. In particular, there is a risk that diseases about
which relatively little is known (principally endemic diseases) will continue to
be neglected since there is less evidence to motivate the formation of a
specific group. Responsibility sharing for these diseases should be as strong
as for those affecting trade or human health.
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We believe that an over-arching structure is needed to ensure the coherence
and completeness of the disease-specific groups. There is further value in
picking up lessons at the regional and sectoral level, and in considering
economic impacts and welfare per se on their own terms, as well as jointly.
Likely participants in the proposed responsibility-sharing groups will be
motivated by a combination of these elements, so a 'steering group' with
economic and welfare subgroups could provide this overarching view across
diseases. The economic group could consider issues grouped by market
segment and layer (farms, processors, supermarkets, etc.); the welfare group
could address e.g. species issues. They could coordinate on e.g. impacts of
globalisation, intensification and (critically) evidence gathering and
maintenance. In this way, the advantages of consistency, flexibility, and
transparency could be maintained while strengthening reasons to participate
actively and allowing
• groups to form, coalesce or dissolve as things change without losing
continuity of effect;
• support for groups around diseases with little economic (or welfare) footprint;
• adaptation of the issues considered by different groups (from a common
template) to fit disease specifics; and
• balanced management of specific diseases to ensure that economic impact
is not minimised at the expense of welfare (or vice versa)
Q12:
If you agree that these are the correct responsibilities for the
Groups, please explain why. If you disagree, can you suggest
alternatives?
We welcome the intention that such groups should cover endemic as well as
exotic diseases. We think that the responsibilities outlined in paragraph 5.4
are appropriate. In particular we think that sharing information and developing
the evidence base for disease prevention and control is of crucial importance
to successful action, along with identifying opportunities to modify the
behaviour of relevant actors such as farmers.
If the collection of the evidence base is entirely within the responsibility of
disease-specific groups, then evidence and knowledge will never develop for
diseases for which there is no group. See our response to Q11 for more
discussion of this issue.
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Q13:
Do you think such groups should tackle policy or delivery or
both? Please explain why.
They need to address both. Any separation of policy and delivery is artificial.
The governance literature stresses the importance of successful
implementation if policy is to achieve its goals in a cost effective fashion.
But this focus depends on the level of aggregation. Policy is necessarily
centralised, but implementation may not be. If local differences (in farm size,
location, animal stocks, mixture of disease threats, market access, financial
stability, etc.) argue for a differentiated 'first-best' approach to disease
management, a centralised group concerned with policy and keenly aware of
the value of decentralised discretion might do better than a centralised group
charged with overseeing implementation (and thus naturally inclined to onesize-fits-all).
Para 5.5
Q14:
If you agree that these are the correct areas to be addressed,
please explain why. If you disagree, can you suggest alternatives?
The areas named reflect current policy challenges, particularly in relation to
introduction of disease at national, EU and international levels. However, they
are proximate aspects, and do not directly address the ultimate concerns of
animal health and welfare, sustainability, transparency and cost-sharing.
Whilst these example areas will be appropriate for some diseases, they will
not be appropriate for others. The production of one list of areas for all groups
carries a danger of overloading groups with non-essential topics; groups
should be given the responsibility of determining their own topics within the
overall aims of improving health, welfare, sustainabiltiy etc.
The ‘federated’ structure suggested above would be one way to address this
– the ‘steering group’ would own the set of issues and monitor the need for
change.
Para 5.6
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Q15:
If you agree with the overall approach to this stage, please
explain why. If you disagree, can you suggest alternatives?
We are in agreement because the groups would have the scope to identify
and examine where they thought that initiatives could deliver better regulation
and enhanced value for money. This has to be at the core of policy.
Para 5.7-5.13
Q16:
If you think these initiatives build on responsibility enough,
please explain why. If you disagree, can you suggest additions /
alternatives?
The aspect missing is the integration between disease groupings suggested
in 5.8 and the other initiatives.
Industry is only one stakeholder grouping. The first steps in establishment of
groups should include all other stakeholder groupings.
Moreover, there is a need for greater clarity regarding the identities and
standing of different parts of the “industry.” For instance, while large food
retailers with a high level of market concentration do not manage animals
themselves, the contractual incentives they create have a profound impact on
practices at the farm level. There is also a need to clarify responsibility,
liability and accountability. At present, these terms are somewhat conflated,
but their precise relationship is the key to design of a successful sharing
mechanism.
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Q17:
If you think opening Defra Programmes and Projects to industry
will allow better decision making, please explain why. If you disagree,
can you explain why?
Industry possesses relevant knowledge and expertise. More effective policy
can be delivered if there are arrangements through which its views can be
taken into account. If industry, or its representative bodies, are in agreement
with policy, then effective implementation is more likely as resistance to policy
measures should reduce.
Industry is only one stakeholder grouping. The participation of all other
stakeholder groupings should be sought from the outset and all subsequent
stages.
This engagement also allows (in principle) a more sensible combination of
collective and individual management. However, care must be taken that
industry involvement does not lead to greater market distortion or regulatory
‘capture’, or that, conversely, too wide participation does not imperil the
coherence and effectiveness of the process.
Q18:
If you believe that sourcing policy leads from industry will result
in better policy, please explain why. If you disagree can you suggest an
alternative approach?
It is likely to improve both policy and implementation. However, policy should
ideally be developed from a multidisciplinary knowledge base, and with a
multi-stakeholder perspective. Including policy leads from one stakeholder
group will not necessarily produce better or optimal policy.
It is also important to note that these proposals move some way in the
direction of self- and/or co-regulation. The full power of this approach (in line
with the principles of Better Regulation) should be explored to identify
appropriate models.
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Q19:
How do you think we could recruit suitable individuals from
industry with the appropriate skills and knowledge to work as a policy
lead?
This is not a straightforward matter because the most able or knowledgeable
individuals often have other commitments. It is also important in this area to
try and ensure that gender imbalances are not too great or to have too
substantial a reliance on the semi-retired. Care has to be taken that the
remuneration structure does not exclude any grouping. Advertising and
contact with representative organisations is clearly an important recruitment
route. The placement of appropriate stories in the farming press might be
helpful. However, it may be necessary to use more innovative methods to
recruit individuals who might think ‘outside the box’. Possible sources here
include universities, think tanks and stakeholder organisations outside the
usual range of consulted bodies.
The industry is currently represented by established bodies that are politically
active. Ideally, individuals would represent industry on the basis of their
expertise and demonstrable skills.
Q20:
If you believe the proposals in this Chapter provide sufficient
opportunity for the industry to demonstrate its ability and gain the
confidence of Ministers and the wider community including consumers,
please explain why. If you disagree, can you suggest an alternative
approach? Do you think this is possible and why?
See our attached memorandum for a detailed discussion of this point.
It is important to note that lack of confidence is not confined to industry alone,
but touches the entire network of stakeholders, all of whom could exploit the
interactions envisaged by these proposals to build trusted relationships and
effective partnerships.
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Q21:
Are any of the proposals that you do not think are suitable for
sharing with industry and why?
An inclusive discussion, no matter how uncomfortable, is likely to improve
responsibility-sharing.
Q22:
Do you agree with this approach at this stage? Please explain if
you think it is challenging enough or too challenging.
See our memorandum attached.
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6. Responsibility sharing: Possible legal structures
Para 6.1-6.7
Q23:
The current approach is to separate animal health and welfare
policy from delivery. Do you agree that any new or revised
organisational structures should continue to reflect this approach? If not
why?
Q24: Do you agree that any new or revised organisational structures
should embrace responsibility for the full range of animal disease
prevention and control activities, including animal welfare? If not why?
[Problems with the electronic form mean that we have included the response
to the previous question here]
Q23: Separation of policy from delivery does not represent the optimal route
for ensuring effective delivery, although there may be reasons for doing this.
The governance literature would emphasise the need for a continuous
feedback loop between policy development and its delivery. In particular,
delivery is essential both to ensuring that the concrete meaning of policy is
understood by those engaged in managing disease and also to informing the
policy level about actual impacts and the need for adaptation in specific
circumstances.
Q24: Yes. We set out in our attached paper our responses to this question in
terms of a regulatory agency.
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Q25:
In recognising that Great Britain is a single epidemiological unit
for the purpose of animal disease prevention and control, should any
new arrangements continue to reflect this? If not why?
Yes, see our memorandum.
Q26:
How could any new or revised organisational structures reflect
that policy for animal health and welfare is devolved, whilst continuing to
recognise GB as a single epidemiological unit for the purpose of animal
disease prevention and control?
See our memorandum.
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Q27:
Do you believe that the creation of a formal responsibility
sharing structure or structures is an appropriate arrangement for an area
of policy which is devolved? If so why?
See our memorandum.
Q28:
Do you believe that the creation of a formal responsibility
sharing structure or structures is an inappropriate arrangement for an
area of policy which is devolved? If so why?
See our memorandum.
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7. Cost sharing – establishing a fairer and more efficient approach to
animal health and welfare funding
Para 7.1-7.30
Q29:
How do you think animal disease risks can be lowered by
Government, livestock producers and other supply chain operators
through cost sharing, bearing in mind that responsibilities will also be
shared?
Any strategy needs to be implemented in a sensitive way to take account of
current difficulties in the livestock sector.
Risk perception is influenced by knowledge and responsibility. Sharing of
knowledge, costs and responsibilities by all stakeholders will change risk
perceptions. As stakeholders, hopefully, come to a better, common
understanding of the true costs, benefits and effectiveness of disease
management options, their understanding of who the real stakeholders are
and how they relate to each other will also improve.
Note that “animal disease risk” is not well defined. It could be taken as the risk
of an individual animal developing disease, the epidemic risk of an exotic
disease, the likely evolution of an endemic disease, or the uncertain impacts
of any of these in economic or welfare terms.
Depending on how disease risk is defined, it may be increased or decreased
by responsibility sharing.
We believe it likely that cost-sharing and responsibility-sharing for animal
disease provides a good environment for agreement, acceptance and
implementation of good practice that affects a number of diseases. For
example, poor biosecurity results in increased costs for all, and may be
improved if these costs are known and borne appropriately. In this
environment, liability for disease risk arising from purchase of animals might
move from a basis of "buyer beware" to strict liability.
Page 18 of 32
Q30:
What cost sharing mechanism(s) do you consider to be best in
driving behavioural change?
As a general principle, incentives are more effective than penalties.
Livestock producers need to be rewarded for adhering to good practice.
Introduction of any mechanism may have different effects from those
intended. For example, charging farmers for bovine TB testing might reduce
the numbers of cattle tested. Similarly, changing behaviour (e.g. increasing
testing) may increase or decrease the risk (see above Q29) associated with
different diseases.
Careful monitoring of the impact of any mechanisms introduced will be
essential to detect and compensate for ‘rebound effects.’ The monitoring
should consider impacts on the whole of animal health and welfare and not
just a specific disease or issue. It should also consider behavioural changes
throughout the value chain and across different regions and farm sizes.
As a general rule, cost shares that are too sensitive to individual stakeholder's
behaviour encourage decentralised changes in behaviour (like compliance
with existing standards) but provide relatively little (or even perverse)
incentives for cooperation and coordinated behaviour (e.g. costly individual
efforts to improve standards or others' performance). Under such rules,
individuals only capture a fraction of the aggregate savings their efforts
produce. Conversely, fixed cost sharing rules may discourage co-operation
and encourage free-riding.
Q31:
Should an animal health disease cost sharing mechanism(s) be
limited to livestock keepers, or should it also apply to those farming
sectors that derive significant benefit from livestock production e.g.
cereal producers? If not why not?
In principle other sectors, such as cereal producers, should contribute, but
devising an effective mechanism for achieving this is a substantial challenge.
The transaction costs incurred may exceed the benefits derived.
It is essential that non-primary producers (stakeholders) such as markets,
supermarkets appreciate that there will be increased costs in livestock
sectors, and hence in costs of products if we are to maintain and improve
animal health and welfare.
Markets will pass on some of the costs in any case, but not necessarily in an
efficient manner (inefficient cost transfer can undermine disease control).
Policy should simply ensure that farmers are able to do this effectively, and
are not unduly constrained by asymmetry of market power. This is not a
matter for Defra on its own, but should if possible be highlighted by Defra in
consultation with market regulators (e.g. the Competition Commission) as
occasion arises.
Note in general that the power of farmers to recover these costs is distinctly
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less for sectors exposed to global competition (e.g. meat) than for more
localised sectors e.g. fresh milk.
Q32:
Are there any other sectors upstream or downstream who derive
significant benefit from livestock production who should also contribute to
the costs of preventing and controlling animal diseases? If so why?
The supermarkets derive substantial benefits in terms of general consumer
confidence in livestock products. In principle they should be invited to
contribute – particularly as they strongly influence farmers’ financial
incentives.
Members of rural communities and users of rural environments (e.g. tourism
and tourists) who benefit from improved animal health and welfare should
likewise be invited to contribute.
Different upstream sectors may wish to contribute differentially to cost-sharing
strategies given that they have different concerns and priorities. For example,
some sectors will be more concerned with exotic (vs. endemic) disease, while
some others will be more concerned with food-borne zoonoses (vs.
environmental contaminants).
Page 20 of 32
Q33:
What incentives would you like to see that help drive
behavioural change whilst discouraging perverse behaviour?
Q34:
Do you think Disease Categorisation is a useful mechanism in
helping to decide how costs may be shared and achieving principle 5
‘Sharing costs only where the activity provides a clear benefit or
service’? What factors should be taken into account in categorising
diseases to determine responsibility and cost sharing? Can you think of
any alternative mechanism for deciding how costs should be shared?
[Problems with electronic form mean that our response to the previous
question is contained here.]
Q33: The answer to this question in part depends on the development of CAP
measures following the completion of the Health Check and also on what form
EU policy takes after 2013. However, in principle cross compliance
mechanisms have an effective role to play in terms of enhanced payments for
good practice and the withdrawal of payments for perverse behaviour. In
practice this requires effective monitoring and one has to avoid over intrusive
mechanisms or those that incur high transaction costs. This means that
outcomes have to be monitorable.
This can be placed on a more secure footing by improving the ability of the
various stakeholders to negotiate behavioural changes with each other in
order to identify synergies. In relation to the EU environment, it is also
important to ensure that effective harmonisation trumps a potential "race to
the bottom".
Q34: Good animal welfare is a characteristic of an advanced society. It is in
the public good that all diseases are controlled to an appropriate level, and, at
least in principle, that the costs of the control are shared.
There is a distinction to be drawn between non-infectious disease (where the
risks are solely the responsibility of the individual animal keeper), and
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infectious disease (where risks are not independent). Consequently, category
4 non-infectious diseases could be regulated through the single farm payment
or equivalent (as in Q33); whereas, category 4 infectious diseases may be
best controlled through cost-sharing at a regional or higher level (see
response to Q11). Thus, it is unlikely that any disease will not incur public
expenditure.
The categories are driven by trade and human health issues. The overt
suggestion that the public share of costs is reduced through the four
categories, will encourage stakeholders, by and large, to attempt to drive
diseases up the category list, while government will, by and large, attempt to
drive them down. One consequence is that there is pressure to reduce public
money for research into category 4 diseases (endemic, non-zoonotic).
Time is an important factor in determining responsibility and cost-sharing.
Costs are paid to reduce future risks of disease. The sharing of current costs
and future risks has to be equalised to reduce the possibility of perverse
behaviour. Stakeholders will vary in their degree of risk aversion, and thus in
their willingness to pay to reduce risk. Risks have to be appropriately shared
to ensure that there is a shared benefit to costs of control.
A principal distinction between Cat 1. and Cat 2. diseases is the degree to
which they are "readily controllable". However, this definition is circular, in
that the degree of control is determined by the governance of control. Under
this categorisation, care should be taken that the level of public intervention is
sufficient to ensure that diseases do not move down the categories (especially
from 1 to 2), as this would indicate failure of control.
New & emerging diseases are not included in the categories. The
categorisation is from a government perspective - different stakeholders will
produce different categorisations. For best policy, all stakeholders should be
involved in redefining a categorisation scheme.
Whilst this categorisation might be logical when considering cost-sharing
initiatives, it does not necessarily make sense at an epidemiological level. For
example, good biosecurity will benefit control of diseases in all four
categories, and therefore the cost may be inappropriately allocated.
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Q35:
Creating a reserve from which funds can be drawn at a time of
disease outbreak provides a tool that would help industry meet its
financial obligation under a cost and responsibility sharing agreement.
There are advantages and disadvantages in collecting funds either
prospectively or retrospectively. A combination of both may offer a way
forward. What do you consider to be the most appropriate method?
A key consideration here is what rate of interest would apply to any accrued
funds relative to inflation. A combination of both is probably the best way
forward as it would avoid too sharp peaks and troughs in the sums required.
In effect, what is proposed is an industry-wide co-insurance scheme.
Structured in this way, and priced through appropriate (re)insurance markets,
this could be of considerable value. Note that the market impact of animal
disease risk can run in two directions.
An outbreak of a non-transmissible disease and/or one with little (perceived)
health impact will hurt the affected farmer and help others. In this case, there
is no (or even negative) systemic risk and a mutual insurance scheme will
work well. In other cases, systemic risk may threaten the credible viability of
such insurance.
The issue of prospective or retrospective collection is one of ‘disease futures.’
Financial risks associated with animal disease control could be unbundled
from commodity futures and traded separately (as e.g. weather risk is today).
However, this may not be wholly sustainable in the current climate. Note, too,
that some past disease management strategies have tended to concentrate
rather than diversify risk. In this case, insurance in the ordinary sense is not
viable to avoid moral hazard and perverse subsidy problems, a ‘pay or play’
provision should be included to encourage innovation.
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8. TSE related activities to be cost shared (stopped, made more efficient,
transferred, charged or funded by levy)
BSE testing of cattle sold for human consumption: laboratory analyses
para 8.2
Q37:
Do you agree that abattoirs should fund the cost of BSE tests for
cattle sold for human consumption? Can you explain why? If you
disagree, can you suggest a different way of providing a better balance
of costs between abattoirs and the taxpayer?
No response.
Page 24 of 32
BSE laboratory approvals
para 8.3
Q37:
Do you agree that laboratories should pay the full cost of
becoming approved to carry out BSE testing and for maintaining that
approval? Can you explain why? If you disagree, can you suggest a
different way of providing a better balance of costs between laboratories
and the taxpayer?
No response.
Meat Hygiene Service (MHS) costs for verifying controls on BSE testing,
SRM removal and hygiene for OTM cattle
para 8.4
Q38:
Do you agree that abattoirs and cutting plants should bear at
least a proportion of MHS costs for verifying controls on BSE testing,
SRM removal and hygiene for OTM cattle? Can you explain why? If you
disagree, can you suggest a different way of providing a better balance
of costs between abattoirs and cutting plants on the one hand and
taxpayers on the other hand?
No response.
Page 25 of 32
BSE testing of fallen cattle aged over 24 months
para 8.5-8.7
Q39:
Do you agree that farmers should bear some or all of the normal
cost of disposing of fallen adult cattle? Do you agree that the costs of
taking and analysing brainstem samples could be a candidate to be
funded for example through a revenue raising mechanism (e.g. a levy)?
Can you explain why? If you disagree, can you suggest a different way
of providing a better balance of costs between producers an the
taxpayer?
No response.
Page 26 of 32
National Scrapie Plan (NSP) - Breeding Programme
para 8.8-8.9
Q40:
Given that the public health driver for public funding of the Ram
Genotyping Scheme has significantly diminished, the Government
intends to withdraw funding unless there is a compelling business case
to do otherwise. We therefore seek your views on:
A:
whether the RGS should be closed and why? or
No response.
B:
whether responsibility for running and bearing the costs of the
RGS should be passed wholly to the members of any such scheme and
why?
No response.
Page 27 of 32
C:
Whether there is a compelling business case for any alternative
to A or B and what the justification for this would be?
No response.
National Scrapie Plan (NSP) - Sheep Semen Archive
para 8.10-8.11
Q41:
Once semen collection is completed in 2008, how can the
industry or an appropriate Non Governmental Organisation assume full
responsibility for the Semen Archive’s maintenance and future use of the
Semen Archive?
No response.
Page 28 of 32
Scrapie Monitoring Scheme (SMS)
para 8.12-8.13
Q42:
Given that SMS members are the principal beneficiaries of the
scheme (and that there is an alternative route by which sheep and goat
producers may export breeding animals in compliance with Annex VIII),
we seek your views on:
A
whether the SMS should be closed, or
No response.
B
whether responsibility for running and bearing the costs of SMS
should be passed wholly to the members of any such scheme.
No response.
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How you can get the most out of this consultation
The Cabinet Office advises citizens and Government Departments on how to
make consultations work effectively. Their advice to the public 1 is:
Be brief. Use one short sentence to explain each point you want to make.
This will help the reader understand your opinion. You can always add more
detail afterwards if necessary.
Focus on what is really important to you. Put the issues you care most
about first, so the reader can see your biggest concerns. If you want to make
more detailed comments, put them in an appendix to your response or in a
separate document.
Provide evidence. Your arguments will be more convincing if they are
supported by evidence or information. If you are responding by post or email,
send in copies of supporting documents rather than information about where
to find them.
Send your response as soon as possible. The earlier you send in your
views, the longer the Department has to consider them. This is particularly
important if you are providing new information or evidence.
Reply to the questions. Where the consultation asks for your views on
particular questions, clearly state which questions you are answering before
setting out your views.
Say who you are. Say whether you are commenting as a private citizen,
representing other citizens, or on behalf of an organisation.
Say if you want your response kept confidential If you do, please read the
Data Protection Act note at the end of this document. This sets out the
circumstances under which we may not be able to keep your response
confidential. The main document contains further information at Annex D
para 1.5.
Thank you for taking part in this consultation.
1
http://www.direct.gov.uk/en/Dl1/Directories/PublicConsultations/DG_10035670
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What we shall do with your response
At the end of the consultation period copies of the responses we receive will
be made publicly available through the Defra Information Resource Centre,
Lower Ground Floor, Ergon House, 17 Smith Square, London SW1P 3JR.
We shall also publish a summary of responses.
If you do not agree to this, you must clearly request that your response be
treated confidentially. Any confidentiality disclaimer generated by your IT
system in email responses will not be treated as such a request. You should
also be aware that there may be circumstances in which we shall be required
to communicate information to third parties on request, in order to comply with
our obligations under the Freedom of Information Act 2000 and the
Environmental Information Regulations.
The library will supply copies of consultation responses to personal callers or
in response to telephone or email requests (tel: 020 7238 6575, email:
defra.library@defra.gsi.gov.uk Wherever possible, personal callers should
give the library at least 24 hours notice of their requirements. An
administrative charge will be made to cover copying and postage costs.
If you have any comments or complaints about the consultation process,
rather than the content in the consultation paper, please send them to
Marjorie Addo, Defra Consultation Co-ordinator, Area 7B Nobel House, 17
Smith Square, London SW1P 3JR, or email
consultation.coordinator@defra.gsi.gov.uk.
Page 31 of 32
Data Protection Act 1998 - Fair Processing Notice
The purpose of this Fair Processing Notice is to inform you of the use that will
be made of your personal data, as required by the Data Protection Act 1998.
Defra is the data controller in respect of any personal data that you provide
when you complete the response form above.
Defra will use your personal data for the purposes of administering the
“Responsibility and Cost Sharing for Animal Health and Welfare: Next Steps”
consultation, and for keeping you informed of future developments in this
area, if you have indicated that you wish us to do so. We will not use this
information for any consultations that do not relate to Responsibility and Cost
Sharing.
Defra may be required to release information, including personal data and
commercial information, on request under the Environmental Information
Regulations 2004 or the Freedom of Information Act 2000. However, Defra
will not permit any unwarranted breach of confidentiality nor will we act in
contravention of our obligations under the Data Protection Act 1998.
Defra or its appointed agents may use the name, address and other details on
your application form to contact you in connection with occasional customer
research aimed at improving the services that Defra provides to you.
If you wish to obtain a copy of your personal data held by Defra, please follow
the procedure at www.defra.gov.uk/corporate/opengov/personaldata.htm.
Please note that you may be charged a fee of £10 for this service. You may
also be asked to provide proof of your identity and for information that will help
us locate the data you are seeking. Defra’s public service guarantee on data
handling, which gives details of your rights in respect of the handling of your
personal data is also available on this website. If you don’t have access to
the internet, please telephone the Defra helpline 08459 33 55 77 and ask to
speak to the Data Protection Officer.
If you believe that any of the information we hold concerning you is incorrect
or out of date, please provide us with the accurate information in writing
together with supporting evidence (if appropriate). You should address your
correspondence to:
Mike Weavers
Defra RCS Programme
Area 310
1a Page Street
London SW1P 4PQ
email rcsharing@defra.gsi.gov.uk
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