The Royal Association of British Dairy Farmers (RABDF)

Livestock Recommendations - Farming Regulation Task Force

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At the Oxford Farming Conference the Secretary of State announced: 

  • From 2016, the introduction of a generic 10 mile rule for CPH allocation across farmed species, alongside a new solution for dealing with land being used for temporary grazing within 10 miles of the home holding; 
  • From 2017, the abolition of all CTS Links and Sole Occupancy Authority (SOAs) licences; and 
  • In 2018, a full review of existing whole farm standstill arrangements in England. 

Background 

The Task Force on Farming Regulation made recommendations for a simpler and more consistent set of rules around CPH allocation and how livestock holdings are defined and allocated (recommendations 8.15 and 8.16) and the six day standstill (recommendation 8.17). 

CPH Changes 
The current rules that define livestock premises and movement reporting requirements are complicated and result in poor quality livestock location data (i.e. we do not know where animals are all of the time). Unless location data is improved, government and industry remains exposed to significant risk and reputational damage in the event of an exotic disease outbreak such as FMD. The proposed changes will mean that we are better prepared to respond to any disease outbreak. Our ability to be able to respond quicker to a disease outbreak will also benefit industry for example through a reduction in the time it takes to enable movements of livestock to recommence. 

Key differences between the current sheep and cattle/pig regimes will be removed by aligning the CPH allocation rules and providing flexibility to manage land used for temporary grazing within 10 miles of a farmers permanent CPH (holding). The complex rules for linking livestock premises (via SOAs and CTS links) which mask both legitimate and illegal animal movements resulting in significant disease risks will be removed. The increased burden of reporting movements and observing standstills when CTS links and SOAs are removed will be largely mitigated by the solution for land used for temporary grazing, which will avoid the need to record and report movements to land parcels within 10 miles of the main CPH as well as avoiding the need to servise standstill. 
Implementation will require complex changes to numerous existing IT systems, many of which are managed by RPA, who are also responsible for the IT systems used to support CAP. It is therefore necessary to delay rollout until after 2015 to avoid jeopardising the successful delivery of CAP reform (including the development and roll-out of the CAP payment and customer and land registration IT systems) in 2015. Rollout of the changes to the CPH landscape will therefore be phased in over a two year transition during 2016/17. 

Standstill 
The Task Force recommended that there should be changes to the standstill arrangements once the review of the CPH landscape had been delivered. Specifically they recommended farm to farm moves should be exempt from standstill but that whole farm standstills should be retained for moves out of markets unless livestock from such moves are isolated in on farm separation units (SUs). The necessary underpinning IT and alteration to business processes to manage such changes would be expensive for Government and establishing “approved” Separation Units would be expensive for individual farmers and moreover uptake is expected to be low. 

The proposed changes to the CPH landscape will however reduce the impacts of standstill as farmers are likely to take advantage of the improved flexibility around holding definition. This will reduce the number of movement reports of livestock with an associated reduction in the number of holdings subject to standstill. 

It therefore makes sense to wait and see what impact the changes to the CPH landscape have on standstill and review the measures again at that point in time (2018). A review could usefully include whether there was scope to look at more flexible and innovative ways in which standstill can be managed, including possibilities around individual animal standstills which could be facilitated by individual\ electronic identification of cattle and all sheep from 2015. 

Longer Term Objectives 
The Task Force also recommended in the longer term that the Government should give consideration to developing a multi species database. The proposed CPH changes are an important step in that process and will deliver a platform from which any new database would be delivered. 

Q & A Brief 
Index 
Q1. Why is Defra making changes to the CPH landscape? 
Q2. What did the Task Force recommend? 
Q3. What will Defra be delivering? 
Q4. What are the benefits for farmers? 
Q5. Will all farmers benefit? 
Q6. What are the benefits for Government? 
Q7. Why do we have to wait so long for the CPH changes to be implemented? 
Q8. What is the proposed implementation timetable? 
Q9. Why have you not taken forward the recommended standstill changes? 
Q10. When will you review standstill? 
Q11. What do you mean by being open to possibilities of individual animal standstill? 

Livestock Recommendations – Farming Regulation Task Force 
Q1. Why is Defra making changes to the CPH landscape? 
A1. The current rules that define livestock premises and movement reporting requirements are complicated and result in poor quality livestock location data (i.e. we do not know where animals are all of the time). Unless land and animal location data is improved, government and industry remains exposed to significant risk and reputational damage in the event of an exotic disease outbreak such as FMD. 

Q2. What did the Task Force recommend? 
A2. The Task Force recommended that we should deliver a simpler, consistent set of rules around how livestock holdings are defined and allocated and remove the complex rules for linking livestock premises via SOAs and CTS links. They also recommended the removal of whole farm standstill for moves between farms but to retain standstill for moves via markets, unless the animals moved are isolated in on farm separation units. 

Q3. What will Defra be delivering? 
A3. Defra will be: 

  • Increasing the existing 5 mile holding definition rule for sheep to 10 miles so that it is consistent with the rules for cattle and pigs. 
  • Removing the complex rules for linking premises via SOAs and CTS links. 
  • Introducing a new flexible approach for industry to manage land used for temporary grazing (within 10 miles of the keeper’s home holding). 

Q4. What are the benefits for farmers? 
A4. Sheep (and goat) keepers will benefit significantly from the alignment of the holding definition rules because they will no longer have to report moves within 10 miles of their main holding. All keepers will benefit from the new flexible approach to managing temporary grazing land because this will also reduce the number of movements that they have to report within 10 miles of their main holding and reduce the number of movements which trigger standstill. 

Q5. Will all farmers benefit? 
A5. Most farmers will benefit, but those that currently move animals more than 10 miles away via CTS links or SOAs will not. Such moves in the future will have to be reported, but we believe this increase in movement reporting burden for a small sector of the industry (85% of movements are estimated to be within 10 miles of the main holding) is proportionate given the increased disease risk with moving animals over longer distances. Movements of breeding sheep beyond 10 miles will also need to be individually recorded and reported. 

Q6. What are the benefits for Government? 
A6. The main benefit for Government is the provision of improved livestock location data. This will mean that we are better prepared to respond to any disease outbreak. Our ability to be able to respond quicker to a disease outbreak will also benefit industry for example through a reduction in the time it takes to enable movements of livestock to recommence. 

Q7. Why do we have to wait so long for the CPH changes to be implemented? 
A7. RPA are responsible for the IT changes to the new CAP system (payments, customer and land registration) as well as the IT changes necessary to effect the CPH changes and many of the expert staff work on both IT systems. It would not be responsible to require RPA to rollout both changes together because this could have a detrimental effect on their ability to successfully deliver the CAP reform changes in 2015 which could impact on 2015 CAP payments. 

Q8. What is the proposed implementation timetable? 
A8. Changes will be phased in over a two year transitional period:

  • 2016 – Keepers will be able to apply to RPA to amalgamate land they own within 10 miles of their main holding. They will also be able to apply to AHVLA to associate land they rent on a temporary basis within 10 miles of their main holding. These are essential first steps in the change process as they mitigate against a potential increase in reporting burden as a result of the later withdrawal of CTS links and SOAs.
  • 2017 – All CTS links and SOAs will be removed but the impact of this will have been largely mitigated by the CPH changes made in 2016. For example a keeper who has a CTS link within 10 miles of his main holding can in 2016 amalgamate his land or associate temporary land to avoid having to report movements within 10 miles when his CTS link is withdrawn. Similarly as the standstill is triggered by a movement report the reduction in the number of movements that must be reported under the new CPH rules will reduce the number of movements that trigger a standstill.
  • 2018 – A review of the standstill arrangements which will take account of the impacts of the CPH changes and consider more innovative ways in which standstill might be managed. 

Q9. Why have you not taken forward the recommended standstill changes? 
A9. As the implementation of the new flexible approach to land management will reduce the number of standstills that have to be served, the current standstill burden is likely to be significantly reduced. It is therefore sensible to assess the impact of the new CPH landscape rules before implementing any changes to the current standstill arrangements. Moreover, the Task Force itself acknowledged the need rationalise the CPH landscape before embarking on any change to Standstill. The decision to review Standstill in 2018 in the light of changes to the CPH landscape is therefore consistent with the Task Force recommendation. 

Q10. What do you mean by being open to possibilities of individual animal standstill? 
A10. The Livestock industry has been pressing us to consider adopting a similar approach to standstill that now applies in NI. NI has moved away from whole farm Standstills and now operates a system which applies standstill to individual animals in certain circumstances. They have been able to implement these changes because they require the individual identification of cattle and sheep as well as recording all movements of sheep and cattle at an individual level. Our recent decision to introduce electronic identification for all sheep from 2015 will provide us with a platform to consider whether individual animal standstill arrangements might operate in England. Cattle are already individually identified and movements reported on an individual basis. 

Glossary and explanation 
CPH number –County / Parish / Holding number the geographical identifier for agricultural land including any location where livestock is kept 

CTS Links. Some cattle keepers who regularly move cattle between two holdings have been allowed to “link” administratively the holdings within the Cattle Tracing System (CTS). Movements of cattle between linked holdings only have to be recorded in the on-farm Register and do not need to be reported centrally to the CTS Database. However CTS Links do not remove a keeper’s legal obligation to comply with other aspects of movement and disease controls such as standstills or pre-movement tests for bovine TB. These national measures are inconsistent with European law (which requires all cattle movements between separate holdings to be reported). 

Sole Occupancy Authority. SOA’s were introduced to help keepers of cattle, sheep, goats and pigs to manage 6 day standstill requirements arising from movements within their businesses i.e. those who farmed separate holdings as a single business. Movements of livestock from premises outside the SOA onto any premises in the SOA puts the entire group under standstill but movements between the different premises in the SOA are still allowed. These movements have to be reported either to the CTS for cattle or to Local Authorities for sheep, goats and pigs.

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