GFA Opposes Gamebird 'Tax'
22 June 2009
The Game Farmers’ Association has joined forces with the National Gamekeepers’ Organisation in a forthright rejection of the Government’s plans for a new ‘tax’ on all animal keepers in England.
The two organisations say that a proposed 4p levy on every gamebird kept, combined with an even more expensive compulsory insurance against exotic diseases, will cost the industry millions of pounds and drive chick production overseas. They believe it will be counter-productive in terms of managing disease.
A spokesman for the two organisations said, “These proposals are grossly unfair. A game hatchery, owning a chick for just 24 hours, would pay the same as a game rearer keeping a bird for several weeks. Shoots could then be paying a third time for the same bird during the period it was in their release pen. What is more, uniquely among the livestock industries, game rearing is currently liable for business rates, so we are already paying our whack.” The two organisations, whose members between rear them nearly all of the 42 million gamebirds released annually in the UK, said the proposals should be scrapped or completely re-worked. They argued that a proposed new body to run animal health in England would lead to complications with Scotland and Wales, which do not support Defra’s plans.
The GFA and the NGO have made a formal written response to Defra condemning the proposals as follows:
A Joint Written Response to Defra’s
Responsibility and Cost Sharing Consultation
Introduction
We have carefully analysed the consultation document and the impact assessment in relation to the UK game farming/game shooting industries. We have also attended Defra regional workshops to hear what Government officials and the other livestock representatives had to say. We have already given Defra a list of 30 areas of concern, some general and some specific to the game sector. These were discussed at a 3-way meeting between Defra’s RCS team, the GFA and the NGO on 2 June. This response has been informed by that discussion.Position of the Gamebird Sector
Our overall position on Responsibility and Cost Sharing is quite simple:We don’t want it to be applied to the game industry.
We have three main reasons for taking this position:1. The proposals would increase disease risk in the game sector, not reduce it.
The proposed new levy and insurance premiums implied by the consultation papers will make game chick production in the UK completely uneconomic, resulting in almost total reliance on imports, with consequent increased risks of exotic disease. Overseas producers, aided by a better climate, local tax breaks and a labour system that favours seasonal game production, have been progressively and aggressively targeting the UK market for many years. About half of all pheasants released in the UK, and 90% of all redleg partridges, have their origins in an egg or a chick produced abroad, mainly in France. It is already very hard for a UK game rearer to make any money from game chick production. Profit margins are just a few pence per bird. Any levy or insurance related to game chick production would frankly finish it, driving all production overseas and increasing the movement of birds around Europe with consequent exotic disease risks. This would be wholly contrary to what we in the industry, the Government, FAWC, specialist vets and the poultry industry have all said should happen. We want more production at home from closed flock game farms selling locally, not pan European movement of millions of live birds plus whatever they happen to be carrying at the time. This is a key issue unique to our sector and it makes gamebirds a special case. There is, however, a further reason why RCS would be counter-productive in disease management terms. Registration requirements, levies, and insurance premiums will drive the worst parts of every livestock industry underground and off the disease control radar. For example, small units will be exempt, leading to flocks being split and ‘ownership’ and ‘keeping’ arrangements being deliberately fudged in order to avoid registration and payment. We do not applaud such tactics but believe they would be an inevitable consequence. Control of notifiable diseases would become more difficult, not easier.2. Game rearers are already paying their way.
Game rearers already incur extensive costs in relation to disease prevention and cure. Their rearing systems are designed, built and run to reduce disease risks. They pay large bills for medicated feed, preventive advice and veterinary treatment. They also bear the brunt of any market collapse in relation to notifiable disease outbreaks – usually without compensation. In many cases they pay insurance premiums related to disease. For even a small ‘husband and wife’ game farm, these many costs will total over £25,000 a year. We appreciate that the above argument will be invoked by every livestock sector but that does not devalue it. Furthermore, we think there is a particular reason why the game industry should be regarded as a special case: The game-rearing sector, uniquely among all the livestock groups, is already liable for business rates. For archaic and wholly illogical reasons we do not benefit from the ‘agricultural exemption’. Business rates are paid to Local Authorities, not central Government, and they are not hypothecated to disease management, but they are nonetheless a unique and substantial tax already affecting our entire industry. A medium-sized game farm may typically spend in the region of £5,000 a year on business rates.3. The proposals are unfair.
We have already indicated that aspects of UK game farming are at the economic margins and that overseas producers have competitive advantage from climate, tax breaks and labour arrangements. Despite what EU law says, the playing field on which we operate is not level and we are facing up the slope. Imposing further costs on English game producers can only increase the incline, not just in relation to mainland Europe but between the home nations of the United Kingdom. This in itself would be unfair. Why should a game hatchery just over the border into Wales be able to produce chicks for the English market whilst our own game farms are hampered by a compulsory levy and insurance so they cannot compete? As presently envisaged, a bird keeper would pay the same levy for a chick worth 60 pence as for a poult worth £3.50. That is unfair. He would pay the same whether he owned the bird for 24 hours or for a year. This too cannot be right. Such anomalies would surely be ridiculed in a Parliamentary debate. If this Government, or the next, is determined to drive ahead with RCS for gamebirds despite what we have argued above, there has to be recognition of the seasonal nature of game farming, the duration of ownership and the actual profit potential in what is being kept. To make flat rate charges for all gamebirds irrespective of their value, time in ownership and based solely on gross profit margins in the very different poultry industry would be indefensible. On grounds of affordability and short duration of ownership, there is a strong case for excluding all game chicks from RCS. Because of problems with the legal definitions of ‘keeping’ and ‘owning’, and the uncertainly of whether they are ‘kept’ at all - and if so for what number of days - there is a strong case for excluding all gamebirds in pens from which they can depart at will (ie. release pens on shoots).As an absolute minimum we would require all the above issues to be fully addressed before we could countenance any support for the inclusion of gamebirds in a re-vamped RCS scheme.
Further Concerns We also believe that:4. The new body may not work
Others have expressed concern that splitting health from welfare, assigning the former to the new body whilst leaving the latter with Ministers, could be a recipe for disaster. Since this criticism first emerged and the strength of feeling about it has become clear, Defra has added more layers of complexity to the proposed arrangements in an attempt to overcome the communication difficulties that such a split would imply. The better answer is to drop the idea of a new body altogether, not least because it has already been rumbled for what it is – a rather poor ‘responsibility’ sugar lump to sweeten the cost-sharing pill. Specifically we are concerned that the new body would be most unlikely to have anyone knowledgeably representing the game sector at board level, so we would effectively be denied our part of ‘responsibility sharing’ anyway. The fact that the new body would start with 240 staff moved directly across from Defra does not inspire confidence that its thinking and culture would be as new as the consultation suggests. We are also concerned that in the event of any serious exotic disease outbreak, health decision-making would pass back to Ministers under the Cobra system, meaning that costs could be incurred by Government with which the new body disagreed and yet to which the livestock industries would subsequently have to contribute 50%. It is surely significant that the Scottish and Welsh Governments believe a new body to be unnecessary and dangerously complex.5. The proposals may not drive the improvements that Defra hopes for
The ways in which imposing new charges on industry might drive reform in pursuit of discounts have not been explored in the consultation document in any depth. There is a vague assumption that such reforms will happen, yet no detail. But this is a major plank of the ‘improvements’ that the consultation promises and predicted savings arising from it have already been taken into account in the impact assessment provided. Take the game industry as an example: Officials have told us that membership of something like the Poultry Health Scheme might qualify a game farmer for a levy discount. But to join the PHS costs money, so there is unlikely to be an overall saving to encourage uptake. If the discounts are not based on existing schemes like the PHS, there will have to be new schemes to enable accreditation and verification. Those too would cost money and presumably the livestock sectors would have to pay. Again, no overall saving, just more paperwork for farmers. It was suggested in meetings that indoor poultry units might pay less than outdoor systems. That may make sense for domestic fowl but it doesn’t work for game. We need to be outdoors to produce fit, competent, wild-type birds. We aren’t producing just a piece of meat. To make any sense at all, such discounting schemes would have to be sector-specific and take account of what was being produced and why (eg. chicks, poults, birds for the food market, birds for release to the wild etc). Agreeing and then verifying all this would be an administrative nightmare; a real turn-off for potential participants and therefore highly unlikely to achieve the health improvements Defra hopes for. Far better to abandon the RCS idea altogether.- The proposals are hideously complex.
7. There has been no ‘rural proofing’ or impact assessment relating specifically to the game sector.
Several of the above shortcomings of the current proposals could have been resolved had there been proper ‘rural proofing’ of the scheme. Despite rural proofing being a legal requirement for proposals like these, the subject attracts just three lines of text in well over 100 pages of consultation papers. The possible impact of RCS on the game industry and on shooting, both of them so vital in many rural parts of England, gets no mention at all. Were these matters to be looked into properly, we are confident that the downsides of imposing RCS on gamebird keepers would heavily outweigh any possible gains. Indeed, we believe that economically, as well as in disease management terms, the whole enterprise could well prove counter-productive. We are happy to help officials and economists with such an assessment but we are not equipped to undertake it on our own. Conclusions:Defra should either:
(a) Ditch the RCS idea altogether because the more detail emerges the clearer it becomes that RCS would be unfair, burdensome, and economically damaging for all the English livestock sectors. (b) Take gamebirds out of the proposals for the unique reasons we have given - in particular that RCS would fuel imports and so be counter-productive to disease management, and that the game sector already pays business rates. (c) Make radical changes to the RCS proposals to render their application to the game sector fair, workable and positive in disease management terms. If this is the option taken, there will be a great deal more work to be done and we would want to be fully involved. Our clear preference is for (a) over (b) over (c). Game Farmers’ Association National Gamekeepers’Organisationwww.nationalgamekeepers.org.uk
June 2009
Date Added: May 28th 2009