British Horse Industry Confederation Consultation Response Draft Animal Health Bill
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British Horse Industry Confederation Consultation Response
Draft Animal Health Bill
1. Summary
Getting animal health and welfare policy right is extremely important to the millions of people
in the UK involved in breeding, riding and caring for horses. How Government and industry
work together to tackle animal disease in the future will impact on a sector which makes a
major and unique economic, sporting and cultural contribution to Britain1. The British Horse
Industry Confederation (BHIC) welcomes the opportunity to contribute to this consultation.
The BHIC speaks with a single voice on behalf of the UK’s equine industry. This consultation
response builds on the views expressed by the sector in its June 2009 submission to Defra’s
initial Responsibility and Cost Sharing (RCS) consultation2 as well as the ongoing
contribution of the BHIC to the RCS Advisory Group chaired by Rosemary Radcliffe. The
horse industry’s overall view of the Bill is that:
• In its current form, the legislation is not workable. The creation of an Animal Health
Organisation (AHO) would take accountability away from Ministers and Parliament at
a time when there are widespread call for more transparency and accountability. It
complicates the process of managing disease and so ultimately leads to the
imposition of an unrealistic financial burden on horse owners without tangible
benefits in return. It unrealistically mixes a complex sector with a significant leisure
component, and includes not for profit welfare groups, with a dominant commercial
sector without clear protections for smaller sectors
• The proposals do not explicitly address the universal concern (with the sole
exception of Defra) that relevant welfare policy is being separated from animal
health.
• The proposals are neither costed nor tested for value for money. Based on figures
contained in the Impact Assessment which accompanies the draft Bill, it is clear that
funding the proposed AHO via a levy charged to horse owners would be financially
unworkable.
• The complete lack of detail on funding, and indeed concerns that those figures that
are available are inaccurate, and information that the ‘cost sharing’ elements will be
pursued by HM Treasury in a future Finance Bill, combined with the extra costs of
complexity and reduced accountability, with a lack of any visible benefits to horse
owners has led much of the sector to view these proposals as a crude cost recovery
exercise. This is fundamentally unfair given the existing cost sharing already
occurring in the horse sector and the lack of public funding, which is enjoyed by the
farm livestock sector.
• Pre-legislative scrutiny of any proposals in this area cannot meaningfully begin
before the RCS Advisory Group has had a chance to submit its report to the
Secretary of State to its agreed timetable.
We are firm in our view that the draft Bill as it stands is not a viable way forward. The horse
industry remains supportive of the underlying principles of sharing costs and responsibility
for animal health (see point 3.1, below). However the publication of the draft Bill has in itself
1
http://www.bhic.co.uk/downloads/sizescope.pdf
2
http://www.bhic.co.uk/about/pressarchive/news.php?32
British Horse Industry Confederation Limited (Limited by Guarantee) www.bhic.co.uk Company Registration: 03793493
Registered Office: Stoneleigh Park, Kenilworth, Warwickshire, CV8 2RH Tel 02476 698871
Members: British Equestrian Federation, British Horseracing Authority, Thoroughbred Breeders’ Association
Chairman: Professor Tim Morris, British Horseracing Authority 75 High Holborn London WC1V 6LS Tel 0207 152 0000undermined this support and reduced trust and the equine industry does not believe the
current proposal would deliver these principles. Where possible we will continue to work
constructively with Government on this issue.
2. Key Points of Opposition to the Bill
The Draft Animal Health Bill Impact Assessment outlines the following core aims for this
legislation:
• “Reduce the overall levels and total costs of animal disease;
• Deliver effectiveness, efficiency and economy from investment in disease prevention
and management;
• Share responsibility between the main beneficiaries and risk managers; and
• Improve confidence of the livestock industry and other stakeholders in the way
disease risks are managed.”
Defra’s letter of invitation to respond to this consultation states that views would be
especially welcomed on whether or not the legislation will effectively achieve its aims3. In the
horse industry’s view the proposed legislation in its current form will not be effective in
achieving the above aims, for the reasons set out below:
2.1. The creation of an AHO would undermine Ministerial Accountability
It is the horse sector’s view that in order for responsibility to be shared in a fair, effective
and transparent way, Ministers must retain day-to-day accountability for animal welfare
and be answerable directly to Parliament on issues relating to disease management. The
horse community at present works closely with constituency MPs to ensure that effective
scrutiny of Ministers in Parliament can take place. This scrutiny is also significantly
enhanced by existence of a Minister for the Horse, which we would like to see continue.
The creation of an independent body seriously undermines this scrutiny and would
reduce transparency in the decision making process on animal health.
It is inconceivable that Ministers and horse owners would not be involved in disease
outbreaks. Under the proposed system of a new AHO, the equine sector would merely
be one minor stakeholder within a system likely to be dominated by the farm livestock
industry, without the checks and balance of parliamentary accountability.
In our view, therefore, undermining Ministerial accountability will mean that the aspiration
to share responsibility and improve confidence will not be fulfilled.
2.2. The creation of an AHO would complicate the process of dealing with animal
disease, increasing costs and bureaucracy without tangible benefits in return
The horse sector can see no evidence that the creation of an AHO will deliver
effectiveness, efficiency and economy in the way we approach animal disease.
Indeed the lack of a robust financial analysis on the extra complexity is a key deficiency
in the proposals (see 3.3). In recent years both the horse industry and Defra have
worked hard to improve the way in which Government and industry interact on issues
relating to disease prevention and management. Establishing an AHO at arm’s length
from Government adds unnecessary complexity to the process. It does not seem
3
http://www.defra.gov.uk/corporate/consult/draft-ahbill/letter-consultees.pdfcompatible with the Government recent proposals4 on Arm’s Length bodies: “the
Government will create a new hurdle that departments must overcome in order to
propose a new ALB. A new ALB must be absolutely the last option.”
In addition, with public expenditure under significant pressure, the cost of creating and
running a new body does not represent value for money to taxpayers. The proposals
focus solely on structure and costs, and the horse industry sees no tangible benefits for
improved disease control. We see no evidence to suggest that this overly-complex
approach would change the good work underway and being developed and so “reduce
the overall levels…of animal disease”.
2.3. The separation of policy on animal health from that on animal welfare is
illogical
The public, the farm livestock community and other stakeholders have not called for the
separation of policy on animal health from that on animal welfare, and should this move
go ahead it would significantly undermine confidence in the system, rather than improve
it. Perhaps most importantly, veterinarians (including the British Veterinarian Association5
and the British Equine Veterinary Association6) have stated very clearly that animal
health and welfare should not be separated.
In Defra’s response to 2009 consultation and policy development7 (published alongside
the draft Bill) it states that: “Animal welfare for wild, farmed and companion animals is of
wide public interest and direct Ministerial accountability is important.” Whilst the BHIC
would not disagree with this statement, our view is that it does not follow that “direct
Ministerial accountability” can or should be taken away from animal health. This
document goes on to state that “the new body and Defra will work together closely to
deliver policy objectives” and that “the body will need to take account of animal welfare
policy via formal arrangements”. In the horse industry’s view, this is one example of the
additional level of complexity, confusion of roles and unnecessary bureaucracy that
establishing an AHO would lead to.
2.4. Pre-legislative scrutiny should wait until after the RCS Advisory Group
publishes its report
We understand that the findings of Rosemary Radcliffe’s review will be published later in
the year. The industry is deeply concerned that the Government has decided to press
ahead with the publication of the draft Bill before these findings are available. This
concern is widely shared across other sectors. The recommendations of the Advisory
Group must be fully considered before pre-legislative scrutiny can usefully begin, and the
publication of the draft Bill at this time undermines the repeated assurances made by
Ministers that the major decisions have not yet been made on RCS.
In addition, whilst there have been many years of consultation with the livestock industry
on RCS there has been insufficient consultation with the horse sector (1-2 years),
resulting in a set of proposals which are not in the interests of the equine community.
4
http://www.hm-treasury.gov.uk/budget2010_armslengthbodies.htm
5
http://www.timesonline.co.uk/tol/comment/letters/article6882915.ece
6
http://www.bva.co.uk/newsroom/1544.aspx
7
http://www.defra.gov.uk/foodfarm/policy/animalhealth/sharing/ahbill/documents/ahbill-briefing.pdf3. Funding the proposed Animal Health Organisation
The BHIC understands that the question of financing of the proposed AHO will be dealt with
in a future Finance Bill. A major concern for the sector, therefore, is that the decision to defer
this important issue to a later piece of legislation could mean that there will be inadequate
consultation on any such proposals.
The wording used by the Treasury in the Government’s March 2010 Budget in relation to the
draft Bill – omitting any mention of the equine industry or other sectors and simply referring
to the “farming sector” – adds to this concern:
“The Government’s draft Animal Health Bill published in January 2010 proposes
steps to share responsibility for animal health within the farming sector, helping to
reduce the impact and cost of future outbreaks. The Government will explore the use
of financial incentives and cost-sharing to help bring about changes in farm
management, and will introduce such measures through appropriate future
legislation.”8
The issue of funding is extremely important to the equine community, given that Defra’s
initial RCS proposals suggested that the horse sector would be subject to charges which the
BHIC considers to be unfair and not properly costed. Following the publication of the draft
Bill Defra has stated that the Government “remains committed to cost sharing as a means of
incentivising animal keepers to take on their full responsibility for the management of animal
health issues.”9
The equine industry wants it to be quite clear that it has received completely discordant
messages on funding: on the one hand from Defra that it is ‘cost sharing’ on the other hand
from the Treasury that this is ‘cost recovery’. It has no confidence that the former will apply
and, given no visible benefits, is working from the position that cost recovery is the overall
primary aim of this Bill.
Given these concerns on the implications of this Government commitment to cost sharing
we feel it is relevant here to highlight the following key points :
3.1. The horse sector already shares costs and responsibility voluntarily
Horseracing alone contributes around £750,000 per year in funding towards preventing
and controlling infectious diseases, as part of a £2.5 million veterinary research budget.
For every thoroughbred horse in the UK (total population around 70,000) £32 per year is
spent by the industry on veterinary research, and £11 of this is focussed on disease
surveillance (see table 1, below).
This is done without the sector benefiting from a public subsidy comparable to that
received by the farming industry (which we estimate to be around £1 billion per year for
farm livestock). No other livestock sector already does more on cost sharing.
We would also note that all horses benefit from this funding such that even if this
veterinary spend were distributed pro rata to the circa 1 million total UK horse population,
(£2 per horse) we consider this covers the sector contribution fully ( see 3.3.)
8
Budget, March 2010
9
http://www.defra.gov.uk/foodfarm/policy/animalhealth/sharing/ahbill/documents/ahbill-briefing.pdfTable 1: Horse Industry Spend on Veterinary Research and Disease
Prevention10:
Spend for all
thoroughbreds (70,000 Spend per
animals) thoroughbred
Total spend on
veterinary research and
disease prevention £2,250,000 £32
Spend on disease
prevention £750,000 £11
3.2. The horse industry is significantly different to the farm livestock sector
The horse community is primarily engaged in activities which are leisure-orientated, the
cost of which is paid out of the taxed income of participants. The broader agenda which
this draft Bill takes forward needs to take into account the fact that those proposals
relevant to the farm livestock industry will not always be appropriate to the equine sector.
The sector is deeply concerned that equine issues may become increasingly
marginalised as these proposals continue to develop. There is also a significant not for
profit welfare sector, for example the main donkey charity cares for over 3000 animals
and spends several hundred thousand pounds a year on research11.
3.3. The draft Bill’s Impact Assessment does not contain a robust cost and benefit
analysis. A levy to fund the activities of the AHO would not be economic to
collect
It is clear from the costing information provided with the draft Bill that the proposed levy
on animal owners would be uneconomic to collect.
According to Defra’s figures from the draft bill documentation (see table 2, below), the
total annual Departmental spend on animal health and welfare is in the region of £446
million. If Defra was to attempt to recover the full costs of preparing for and dealing with
animal disease outbreaks, therefore, it would be asking horse owners to pay a huge
amount – even based on a more modest expenditure of £300 million, horse owners
would be paying £30 per animal (if we assume, generously, that the horse sector
represents around 10% of total activity in terms of disease management, and given that
there are around 1 million horses in the UK). This would leave the farming industry with
an inconceivably high bill of £250m.
10
http://www.hblb.org.uk/sndFile.php?fileID= 71
11
http://drupal.thedonkeysanctuary.org.uk/view/projectsTable 2: Defra Animal Health and Welfare Budget12:
Defra Budget Analysis Cost (£m)
Defra animal health and welfare budget, 266.548
2008-09
Animal Health Executive costs, Aug 2008 128.043
Exotic disease outbreak costs 52
Total 446.591
The figures above therefore indicate that the stated aim of RCS – to levy just £22m –
would recover the costs of only a small proportion of Defra’s full expenditure. However,
this smaller amount could only be collected at uneconomic cost. Under the current
proposals (based on a target of £22m), the BHIC estimates from the costs attributable to
horses that horse owners would be asked to pay £2 per animal (Defra’s initial
consultation proposed a levy of £10.50 per horse per year. This £2 levy, and even
Defra’s £10.50, would be totally uneconomic to collect if we use collection charges for
two existing comparable levies – ‘best case’ [British Cattle Movement Service (£7 per
animal)] and ‘worst case’ [Rural Payments Agency (£15 per animal)] as a guide.
So under the current proposals it is uneconomic to collect from horse owners and the
scheme as a whole would make a relatively small dent in Defra’s expenditure on animal
disease. However, if Defra looked to levy more than £22 million and push for greater cost
recovery, this would quickly begin to place a massive burden not only on horse owners
but also on farmers. Referring back to the stated aims of the legislation noted in section
2 above, it is clear that this uncosted levy will not serve to “reduce the… total costs of
animal disease” – but will have the opposite effect.
Our understanding is that the costs from Defra are still in fact unclear and are being
further reviewed within Defra and by the Treasury. Estimates for cost of TSEs and
Bovine TB range form £60-100 million a year, none of which would be attributable to
horses. Total costs may be lower than £446 million a year, by as much as £80 million.
Such inaccurate figures make a fair and reasonable cost benefit assessment impossible.
4. The Horse Industry’s Approach
The industry has consistently made the point that creating a new body and imposing a
levy is the wrong approach to implementing the responsibility and cost sharing agenda. It
is clear that Defra has not costed this proposal properly and in practice it would be
unworkable. The horse industry wants to build on what has already been achieved with
Defra on the reduction of disease risk. The creation of an AHO would jeopardise the
progress which has been made on this front in recent years. The publication of the draft
Bill has eroded this trust.
Whilst the horse sector has been a critic of the Defra’s RCS proposals in their current
form, we are committed to working with the Government to improve our collective
response to the problem of animal disease outbreaks. Throughout the development of
these proposals the sector has taken a constructive approach. The BHIC has put forward
alternative proposals for RCS implantation along the lines of an “Office for Animal
Health”, which would be embedded within Government but would bring industry into the
policy process without compromising Ministerial accountability.
12
Source: Draft Animal Health Bill Impact Assessment, January 2010An Office for Animal Health would:
• Be spearheaded by a Government Minister charged with leading the agenda and
working with all stakeholders via the Office. The role of Lord Drayson in
spearheading the Office for Life Sciences (see quotes below) has helped to make
that body a significant success.
• Would bring together Ministers, industry representatives and officials across
Government to agree policy priorities, with an initial blueprint of action published
following an initial six months of discussion. A strong overall strategy is what is
currently needed to improve the response to animal disease outbreaks
• Champion industry leadership and responsibility without taking accountability
away from Ministers
• Encourage greater input into the policy process from veterinarians and
academics
• Be cost effective, avoiding the costs involved in setting up a separate agency
whilst drawing on the administrative assistance of stakeholders to support the
work of the Office, such as full utilisation of the National Equine Database
• Promote cross-industry working by providing a neutral platform for all
stakeholders to make their voices heard
• Promote better cross-Government working. The Office would be staffed and
meetings represented by civil servants from a number of relevant Government
departments. An Office for Animal Health could be responsive to issues which
concern more than one department.
A Strong Precedent: The Office for Life Sciences (OLS)
“If we can establish, as I hope we are doing, that this is a good model for cross-Government
working where you have civil servants from each of the Government departments which
have an impact on an industrial sector sitting down with key industrialists and key
academics, if this is a model which at the end of the six month process is seen to have been
successful, then this is something that we will replicate across Government.”
- The Minister for Science and Innovation, Lord Drayson, giving evidence to the House of
Commons Innovation, Universities and Skills Select Committee, 18th May 200913
“The OLS has created a new way of working, across Government ad industry, requiring a
fresh perspective from industry as much as from Government… The OLS process has
required the life sciences industry not just to articulate the challenges facing the industry in
the UK, but to work in partnership with Government and other key stakeholders to plan novel
solutions”
- Office for Life Sciences Blueprint, July 200914
13
http://www.parliament.the-stationery-office.com/pa/cm200809/cmselect/cmdius/169/9051802.htm
14
http://www.bis.gov.uk/assets/biscore/corporate/docs/l/life-sciences-blueprint.pdf5. Summary of BHIC Recommendations
The Government should:
5.1. Scrap the proposed independent Animal Health Organisation. Such a body would
add extra complication and bureaucracy to the process of managing animal disease,
would be uneconomic to fund and would take away crucial Ministerial accountability
for animal health
5.2. Consider other approaches such as the establishment of an Office for Animal
Health, embedded within Government and directly accountable to and spearheaded
by Ministers. Such a body could represent the best way forward for the successful
implementation of the RCS agenda, which the horse sector supports in principle
5.3. Rethink how the RCS agenda can move forward without forcing an unnecessary and
illogical separation of animal health and animal welfare policy. The two must not be
split and would not be in a structure where there was an Office for Animal Health,
which would be embedded within Government and directly accountable to and
spearheaded by Ministers.
5.4. Wait to hear the recommendation of the RCS Advisory Group later this year before
making any further policy announcements on the RCS elements of the draft Animal
Heath Bill. The Advisory Group’s recommendations must be given genuine
consideration by the Government and its views must be reflected in the policy
decisions which Ministers make on RCS going forward
5.5. Reconsider the position of the equine sector in the current RCS agenda and the
draft Bill. The horse industry, as with other smaller sectors, should not be treated in
the same way as the farm livestock sector, and nor should its views be marginalised.
5.6. Consult with stakeholders at the earliest available opportunity on the issue of the
cost sharing proposals to be dealt with in a separate Finance Bill. The views of the
RCS Advisory Group should be taken very closely into account as this legislation is
developed
5.7. Ensure all policy proposals are based on accurate published costs.
5.8. Scrap the proposed levy on animal owners, which would be uneconomic to collect
and place an unfair burden on horse owners as well as livestock farmers.
Ends
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