Select Committee on Environment, Food and Rural Affairs Appendices to the Minutes of Evidence


Memorandum submitted by the National Farmers' Union of England and Wales (G15)


  1.  The NFU welcomes the opportunity to submit evidence to the Committee in connection with its inquiry into the role of DEFRA, one year after the new Department was established. We have used the Committee's terms of reference as the structure for our comments. We have sought to adhere to the Committee's request for an overview on the direction the Department is taking, and to keep our evidence as brief as possible. The Department's responsibilities cover such a broad field, and it has been such an eventful year on a number of policy fronts, that it is not possible to attempt a comprehensive assessment of the Department's performance across the board: we have naturally concentrated on the Department's interface with the agriculture industry and the farming community who we represent.


  2.  Debate about the appropriate structure of Government machine for agriculture, the environment and rural issues has been ongoing over many years. Indeed as recently as March 2000 when the Prime Minister launched an Action Plan for Farming it was stated that he wanted to bring speculation about the future of the Ministry of Agriculture to an end and emphasised that MAFF would fulfil the task of implementing the strategy for farming and food. By the time of the publication of the Labour Party manifesto before the 2001 General Election there was a commitment to create a "Department for Rural Affairs" to lead renewal in rural areas. As DEFRA's Departmental Report 2002 rather coyly remarks "the creation of DEFRA allowed for little formal planning of the complex logistics of the merger" of former MAFF with parts of former DETR, and some Home Office staff. In short it is clear that there was little in the way of a detailed blueprint for the design and functions of the new Department before the election, and accordingly its construction and development has created an impression of some haste and improvisation.


  3.  The new Department could hardly be said to have had a flying start in life. Indeed it has had to face serious internal problems for example relating to different structures of staffing and pay amongst its civil servants, incompatible IT systems etc. From the agricultural point of view the new Department inherited a major crisis in the form of the worst outbreak of foot and mouth disease (FMD) recorded anywhere in the world. Although this disaster for farming had peaked in terms of daily cases before the new Department came into being, nonetheless the sheer scale of the outbreak, and the severe consequences for farming and for the wider rural economy are still very real issues some seven months after the last reported case. In these circumstances it is not perhaps surprising that the diversion of the new Department's attention and resources to tackling FMD has delayed some of the development of the new Department. The establishment of aims and objectives for the new Department has taken many months, commencing with the first thoughts of the Secretary of State in June last year, and followed by a consultation exercise in the autumn.

  4.  We support the Government's policy of opening up Whitehall to the commercial realities of the world which it oversees and regulates. We have therefore been disappointed that more use has not been made of the opportunity of DEFRA's creation to import into the new Department senior persons from the commercial world with expertise relevant to the Department's responsibilities. We note that this has been done to some extent, for example senior IT posts, but believe there is scope for more.

  5.  The Secretary of State's vision for the Department which appeared towards the end of 2001 is couched in somewhat Arcadian prose. It is worth noting the original vision statement which still appears on DEFRA's website states that "the pursuit of sustainable development . . . is vital to achieving this vision", whereas the prospectus document published by the Department in March of this year Working for the Essentials of Life adjusts this statement to the more ambitious line that "Through the practices of sustainable development . . . we will achieve our vision". This is perhaps symptomatic of the Department's decision to place all its eggs in a basket of "sustainable development" without apparently recognising the potential conflict or inconsistency of its stated commitments. For example, the Department rightly perceives the importance of global and international objectives in relation to the environment and climate change. Yet the delivery of the Department's objective of promoting a "sustainable, competitive and safe food supply chain which meets consumers' requirements" will require a much more robust sponsorship and promotion of the economic sustainability of British agriculture by DEFRA than has been apparent to date in the light of the support given to their agricultural industries by other countries amongst our competitors in Europe and the wider world. This must be accompanied by the application of significantly more resource to fund the achievement of the objective.

  6.  In assessing what would be required to achieve its vision through the practice of sustainable development, we question whether the Department has taken sufficient account of the fact that many of the key resources such as land are largely privately owned, and that there are existing and long-standing rights in respect of other resources such as water. These considerations should be more demonstrably integrated into the Department's approach.

  7.  The NFU welcomes the Department's commitment to raise the status and profile of science within DEFRA to deal with the Department's challenges. It is therefore right that the Department has set in hand a fundamental review of the organisation of science in DEFRA and has appointed a new Chief Scientific Adviser to lead this process. We welcome the important statements made by the Prime Minister in his speech to the Royal Society on May 23 2002 about the importance of making judgements on the basis of scientifically evaluated facts, and that "environmentalism is strongest when allied to hard science and empirical testing". However to turn the Prime Minister's statement into reality will require strong emphasis amongst DEFRA's science department and the Chief Scientist on proper development of both European and international policies. Already DEFRA's inability to secure review and revision of the discredited science which underlies the application of the EC Nitrate Directive to England shows that farmers face unnecessary regulatory costs as DEFRA implements existing EU legislation.

  8.  Given the difficulties it faced from the standing start, it is no surprise that the Department has struggled to determine its aims and objectives in life and to put the necessary structures in place to achieve them. Although it must be right to have conducted this exercise in a transparent and consultative manner, many of DEFRA's stakeholders have become increasingly impatient for the Department to get on with the job of tackling some extremely pressing difficulties within the Department's remit, most notably in the agricultural sector. The Department must now move on from infancy to a mature application of practical management of its responsibilities. This will inevitably require the provision of sufficient resource by DEFRA and equally the provision of necessary financial resources by Treasury to enable DEFRA and its related Executive Agencies and other associated bodies to better meet their responsibilities.


  9.  We remain deeply concerned that DEFRA is failing to give proper weight to the future of farming. DEFRA is the sponsoring Government department for farming at a time when farmers are in a long established financial depression. Moreover DEFRA took over from MAFF the role as the primary Government department for the management of the FMD outbreak. DEFRA naturally, and properly, devoted substantial financial and staff resources to controlling and eliminating the FMD outbreak. We welcome DEFRA's close contact with the NFU at both national and local levels and the strenuous efforts to secure a united approach to bringing the end of the FMD outbreak. However, we remain deeply concerned that other farming priorities which require Government action have not received the attention they deserve.

  10.  The NFU is particularly concern over the slow response from DEFRA, and Government as a whole, to the recommendations of the Policy Commission on the Future of Farming and Food. Some of the recommendations from the Commission's report have made significant progress but too many of the more major policy issues referred to in DEFRA consultation on "Sustainable Food and Farming, Working Together" remain the subject of slow moving consultation and decision-taking. No one can judge the value of the strategy for sustainable farming to which the Government has committed itself until these on-going processes, and crucially the question of adequate funding for them, have advanced much further.

  11.  We would argue that DEFRA's failure to take steps to help farmers across its wide agenda leads to it also running the danger of failing to deliver its food, environmental, conservation and rural affairs concerns. Farming remains the core of our food industry, our environment and our rural economy. We find it ironic that policy tensions on agricultural issues between former MAFF and former DETR often produced pressure within the system for solutions which more effectively balanced the needs of a competitive agriculture on the one hand with environmental and other public policy objectives on the other than we perceive happens now that the policy-making is housed under one roof.

  12.  The NFU continues to be very concerned over DEFRA's implementation of its regulation of farming. DEFRA quite rightly in Working for the Essential of Life undertakes not to impose unnecessary regulations and to ensure that care is taken on the economic consequences of regulation. The NFU and farming community do not see that this has yet been turned fully into operation. We remain concerned over "gold-plating", characterised by a tendency to err excessively on the side of caution apparently to be sure to escape infraction proceedings; and over DEFRA's failure to review regulation, whether existing or newly proposed, with stakeholders including the NFU. DEFRA should place even greater emphasis in ensuring that its negotiators, whether in world or EU discussions, fully understand the implications of policy development on farmers and the importance of pressing for new regulations to have the least adverse impact on farming.

  13.  Notwithstanding the huge pressures placed on Ministers and officials in the Department by the FMD crisis, in our view the Department continues to be under-resourced in terms of its ministerial complement. In our view DTLR received a more favourable complement of seven ministers from its creation after the election last year than did DEFRA which received an allocation of only five ministers to take on the responsibilities inherited from MAFF, DETR, and the Home Office. This more generous complement has been continued in the restructured arrangements for transport, and for local government and the regions, announced on May 29. We believe that there is a strong case for DEFRA to be strengthened by the appointment of a food chain minister at Minister of State level in the Commons, and that this would be of material assistance in progressing towards the Department's objectives for a sustainable farming industry.

  14.  The NFU has welcomed the establishment of the Rural Payments Agency, and the opportunity that has been taken to have a single cohesive unit for payments under the EU CAP and other schemes. However it is a matter of regret that morale in the RPA appears to be very low. For most farmers their only direct interface with DEFRA is through the RPA, and the difficulties and prolonged delays experienced in payments by the Agency have inevitably tarnished the new Department's image with many of these customers. Delays in payments under ERDP schemes are well-documented. It is most important that the RPA swiftly overcomes IT problems, clears backlogs in payments, and establishes a more positive relationship with customers. We appreciate that management of the RPA is aware of the need for this, but the sooner they can achieve it the better.

  15.  The NFU has examined the performance of DEFRA at the regional level. We detect a number of problems here. In general the Department's policy strategists are perceived to have worked hard to establish the new Department at regional level, in relation to the Government Offices of the various regions. It has however been pointed out that in some cases senior regional officials of DEFRA appear to spend a fair proportion of their time on matters which are not directly related to DEFRA. Whilst we see the importance of good working relations and other Government Departments at regional level, the very broad remit of DEFRA's responsibilities means that regional officials are hard put to do justice in any depth to the Department's remit, let alone that covered by other Departments.

  16.  It is perceived that there is some notable confusion in the minds of officials themselves about their exact role and how their responsibilities within DEFRA relate to the rest of the Department and to other departments in the Government Offices of the regions. It is has also been noted that in some cases there appears to have been some tension between regional DEFRA and regional Government Offices regarding lines of responsibility and functions. These conditions have inevitably led to a somewhat cautious attitude by officials who can appear very conscious of demarcation lines, and frustration for customers arises when a 'pass the parcel' attitude is encountered. Stakeholders and customers who had been promised that the new arrangements would provide a more integrated, joined up approach, have too often had to share officials' confusion, and there is a danger of disillusionment with the young Department setting in.

  17.  In summary we believe that DEFRA has made a well-intentioned but often under-resourced start to many of its responsibilities, and that much work must be done to convince stakeholders and customers of the Department's understanding of their problems and of its commitment and ability to provide a service at a level which will see them efficiently and effectively addressed.


  18.  These groups brought with them to DEFRA some issues which have a high profile, for example the implementation of the new right of access to open country under the CRoW Act 2000, the introduction of Environmental Impact Analysis regulations, and the Water Framework Directive. We perceive that in addition ministers have tended to put most emphasis on the environmental aspects of agriculture, perhaps to indicate a desire for an integrated approach to the new Department's responsibility in the name of sustainable development. The real test of a balanced approach within the Department will come on such issues as cross-compliance of environmental payments to farmers, and the extent to which the needs of agriculture as a primary user industry will be recognised in the bringing forward of the Water Bill.


  19.  DEFRA's Objective no 2 is "To enhance opportunity and tackle social exclusion through promoting sustainable rural areas with a dynamic and inclusive economy, strong rural communities and fair access to services". Although some of the powers and mechanisms for achieving that objective fall within the DEFRA remit, the fact remains that much of it is delivered through the policies and programmes of other departments of state—for example DTI, and what was DTLR but now further separated (from the original DETR empire) into the Department of Transport, and the Office of the Deputy Prime Minister covering such matters as local government, housing and planning. We are not convinced that DEFRA has been able to establish the "clout" for rural issues that we believe a Department with formal responsibility for Rural Affairs should have. What influence, for example, has DEFRA had over policy for the future of rural post offices?

  20.  The Countryside Agency's recent report on progress with "rural proofing" did not give DEFRA a good assessment on embedding rural proofing in policy making procedures, or on promoting proofing checklists, or on setting and monitoring rural targets or on enhancing rural awareness through staff training. DEFRA should be leading the way—not falling behind other departments which are notorious for their insensitivity to the rural dimension. We welcome the expression of ministerial regret for this position in the Lords debate on rural policy on April 30, and in principle we welcome the development of a new classification of "urban" and "rural" based more on land use, settlement patterns and economic activity. However do not find the minister's statement in the debate very reassuring that "we shall then have a suite of definitions on which we can draw as appropriate but as understood for various different purposes". It is of concern that the new classification is apparently at least 18 months away, and even then it may not be so helpful in more clearly defining "rural" for policy purposes given that this is a long-standing and already well-researched issue.

  21.  DEFRA has the potential to take a positive lead on rural affairs. For a variety of historic, cultural, resource, managerial and not least political reasons it runs the risk of failing and becoming inward-looking. For the sake of farming and our unique countryside this must not be allowed to happen.

May 2002

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