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Who should decide animal health policy and pay for disease costs?

Last post Sat, Apr 4 2009 9:26 by viewfromtheothersideofthefence. 29 replies.
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  • Thu, Jun 19 2008 15:16

    Who should decide animal health policy and pay for disease costs?

    DEFRA's responsibility and cost sharing initiative could have massive implications for all farmers and the associated trade. The government aims to have it in place by about 2011 and DEFRA genuinely wants to hear from farmers.

    There are two parts to the initiative. On the responsibility sharing, the industry could see a new body created, a bit like the Food Standards Agency, made up of farmers and government officials deciding animal health policy. So we could see farmers having a say on badger culling for TB.

    The options outlined in the DEFRA consultation document are:

    A      More or less status quo

    B      Advisory body like FAWC, but the minister still decides

    C      New industry/government body

    D      Industry mutual to which all farmers need to be a member

    So who do you like to see making the decisions - the DEFRA minister or a newly created joint industry/government body? In what form should this body take?

    However, the more decisive part of the initiative is cost sharing.

    Listening to Lord Rooker last week as I interviewed him for the Farmers Weekly article (see page 18, June 20 issue), it was clear that this is definitely going to happen, but they haven't decided how.

    Should it be a levy on livestock, annual levy on animal numbers, service charge or insurance? Should the costs be restricted to livestock farmers, or broadened out to arable growers and feed compounders?

    Lord Rooker said: "Widen the base, the less it will cost each individual business," but somehow I don't think arable growers will see it that way

    Another question they seek views on is: should it only apply to just exotic diseases or include endemic diseases?

  • Thu, Jun 19 2008 15:57 In reply to

    • sjk
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    Re: Who should decide animal health policy and pay for disease costs?

    If farmers are going to be responsible for sharing the cost then surely they should have an equal say as if it is only an advisory board and ministers still decide it would be no different than what its like now other than they would have created more pointless civil servant jobs but still ultimately decide for themselves whether the board agreed with them or not.

     

    As for the cost sharing I still think that if it comes from either a DEFRA site or a private firms site then they should be responsible for paying the costs and not us the same as if a firm was found to be responsible for dumping industrial waste they would be responsible for paying the costs to clear it. Otherwise it just seems like we are paying for their mistakes.

     

    Sam

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  • Thu, Jun 19 2008 16:09 In reply to

    • townie
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    Re: Who should decide animal health policy and pay for disease costs?

    I very much doubt there is an ideal solution to either of these questions that will equally suit the various kinds of farmer as well as government and general public heath.  However I do have some serious concerns.

    Firstly with regard to any advisory or industry body it must be restricted to those groups that have a direct financial/commercial interest in the results.  Namely government (whose monetary input comes in the forms of subsidies, grants, etc.), farmers (or their representatives such as NFU) and other supply chain operators, such as abbatoirs and processors.  Specifically excluded should be the various spurious 'stakeholders' who pop up whenever our industry is being targeted, such as English Nature, CIWF, Badgers Trust etc. etc.  Clearly it would be of help if the proposed group were able to take on board qualified advice from scientists, etc., but not in the form of decision making, just as advisory input.  The chief challenges with any body will be in ensuring transparency of decision making and in communicating hte output policies: we see little enough of this transparency with our so-called democratic representatives these days!

    With regard to cost sharing, who is being targeted here?  All owners of livestock from a back-garden smallholder with a dairy goat or half a dozen chickens to a commercial operator with hundreds of sheep, cattle or pigs?  What about keepers of other non-commercial livestock such as equines and camelids?  What about owners of cats, dogs or rabbits?  It is the case that all of the above (except the chickens) can contract and carry bovine TB, so why lump the cost onto cattle farmers?  The same question applies for the dreaded bird flu that has been aiming to wipe out civilisation for some time now, but is being very surreptitious about it.

    If we are going to target endemic diseases when can I get compensation for the cold I caught last time I used a public transport service?

     

  • Thu, Jun 19 2008 16:10 In reply to

    • Jacobus
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    Re: Who should decide animal health policy and pay for disease costs?

    The options outlined in the DEFRA consultation document are:

    A      More or less status quo  - not an option if they want my money

    B      Advisory body like FAWC, but the minister still decides - powerless talking shop

    C      New industry/government body - but who appoints the industry bods and what powers does it have - none probably

    D      Industry mutual to which all farmers need to be a member - compulsory? membership fee? do members get a vote?

    Ultimately, whoever recommends whatever action, the minister will decide and will never decide to take the option that looks bad to the general voters e.g. badger culling

    However, the more decisive part of the initiative is cost sharing

    However this is ultimately achieved it should be done with the minimum cost addition.  It would be a real shame if a whole new structure, administration and database had to be created simply to collect this contribution.  If it is decided that livestock farmers should pay, then why not collect an additional levy at the point where current levies are collected.

    If we want to spread the pain of payment, the best option is to go for the widest base - people who eat meat, eggs and dairy products.  Put 1% VAT on foods containing animal products. 

  • Thu, Jun 19 2008 17:08 In reply to

    Re: Who should decide animal health policy and pay for disease costs?

    I find your comments really interesting as it reinforces one observation I had when interviewing Lord Rooker - the question of who should be on the body and who should pay actually conflict with each other.

    For example, widening out who should contribute brings the question of whether they should be represented on the body - ie if arable growers or compounders are paying into the kitty, then they will want a say on how it is spent. This could then lead to a large unwieldy, and expensive, body that could end up sucking any savings made by the sector into administration costs.  

    I agree with townie that hobby keepers of livestock also contribute to the disease risk (potential reservoir of disease) and this brings the question whether hobby/showing groups need to be included. Then problem then is how do you collect the cost fund, as there will always be some groups that fall outside of the levy collection system. Perhaps a tax on food, as suggested by Jacobus is the way forward - certainly the most straightforward, and there is a public benefit.

    My one fear is that to bring in all animal keepers, it raises the spectre of licencing farms and having an annual fee to farm. I dont think that would be the way to get farmers buying onto working with DEFRA.

  • Thu, Jun 19 2008 20:47 In reply to

    • Jacobus
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    Re: Who should decide animal health policy and pay for disease costs?

    Richard Allison:

    My one fear is that to bring in all animal keepers, it raises the spectre of licencing farms and having an annual fee to farm. I dont think that would be the way to get farmers buying onto working with DEFRA.

    I wouldn't mind betting that this scenario is on some EU commissioner's agenda!  It's always the same with these damn continentals, they can't stand the thought of anyone doing anything without the bureaucracy knowing about it and charging a fee for a licence.

    I know that all poultry keepers on however small a scale were being encouraged to register with DEFRA because of bird flu, but I'll bet there are thousands who haven't, and I also know of several people in the locality with a handful of pet sheep or goats who aren't on DEFRA's radar.

    By the way. if Lord Rooker is keen to know farmers' views, did he mention any mechanism for letting him know how we feel?

  • Thu, Jun 19 2008 21:07 In reply to

    Re: Who should decide animal health policy and pay for disease costs?

    Richard,

              I have only just put my silly old head to this but my initial thoughts are this

    1] Animal Health in general should be down to and controlled by the Keeper of animals who has a vested interest in Disease control.

    2] The Technical side of this arrangement should in theory be down to the Veterenary Surgeons at the point of delivery who in turn because of their Technial education and " Field experience " are the only people with an overall view from a position of both practicality and expertise.They are also able to direct and interpret scientific advancement at both Research Establishments and Universities.

    3] It could be said that the Vets may abuse this position for commercial gain so we could look at Regional Committees made up of both Farmers and Veterenary Surgeons.

    4] We could perhaps have Government Regional Laboratories for VS to send Samples etc, and for a point of Reference for the Govt to come togeter with the Industry.Therefore if a Disease is detected in a Region the Committee of that Region [or it's CEO] would instantly contact the Regional Vet Centre and give instruction on the spot with first hand local Knowledge.The Regional Vet could then contact the govt and all other regions and instant control and observation remedies could be installed by Farmers and their Vets.

    5]Policy must be laid down at Regional Level and when a majority says so rubber stamped by Parliament as they are the only Organisations with the Tecnical and Academic and commercial expertise to come to these Judgements.

    What I am trying to say is that at the moment we have Academics who mostly have no practical experience whatsoever giving Politicans with mostly no practical or commercial experience views and Opinions who consequently are either not making or if they are making Policy it is missguided or flawed and the whole thing is in a Vortex that is swallowing Millions of Pounds and Disease control is really out of hand.

    My thoughts and there are plenty out there with good ideas and thoughts that need throwing in the Ring.

  • Fri, Jun 20 2008 14:06 In reply to

    • townie
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    Re: Who should decide animal health policy and pay for disease costs?

    Jacobus:
    I know that all poultry keepers on however small a scale were being encouraged to register with DEFRA because of bird flu, but I'll bet there are thousands who haven't, and I also know of several people in the locality with a handful of pet sheep or goats who aren't on DEFRA's radar.

    I recall there being a follow-up story on this poultry register recently that exposed the government's intention to expand the remit of the register to allow access to all sorts of other agencies beyond Animal Health, including local councils, HMRC and others.  This highlights my nightmares about scope creep.  Once some sort of disease fund register, or whatever, is set up, what other uses will it be turned to?  I'm sure the commisars are already planning these out.

     

  • Sun, Jun 22 2008 15:01 In reply to

    • Peter Wells
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    Re: Who should decide animal health policy and pay for disease costs?

    If we assume this government is really concerned about the killer diseases being let loose on us, it might first wish to consider testing everyone flying into the country from countries  where Aids, TB and Malaria are endemic. However, because it does not do the one big thing, we can assume that the issue of disease is not really as serious as they make out. This means therefore, that thy are free to play about with issues of secondary importance.

    As to disease control in domesticated stock and who will pay for it, Jacobus has it spot on.

    Jacobus:
    the best option is to go for the widest base - people who eat meat, eggs and dairy products.  Put 1% VAT on foods containing animal products

    This action would require little additional paper work and no extra Civil (sic) Servants to administer.

    One further point. Why is it that in my hobby of Singing, I have to pay the full costs of that hobby including payment of creative and performing rights to the creative composer, but in the case of the man whose hobby is badgers, he does not have to pay for the loss of the right to the farmer who has created a dairy herd? In the interests of fairness the Badger Hobbyist should pay the full costs of his hobby, including costs of the person whose livelihood is impacted adversely.

    If all this sounds a bit convoluted, remember that the solution offerred by Jacobus would spread the cost of disease control across all those who supposedly benefitted from the controls.

     

  • Fri, Jun 27 2008 11:48 In reply to

    Re: Who should decide animal health policy and pay for disease costs?

    Thinking of the badger hobbyists reminded me of the debate over the new poultry register 2 years ago. Currently, only flocks of 50 birds or more must register with DEFRA, but many in the industry thought it should include all flocks.

    Broadening this out, any payments/disease control system should also include small scale hobbysists and exhibitors, effectively anyone owning birds, keeping a pig on an allotment, or a couple of ewes. They are all part of the national flock/herd and are so part of the disease risk. But how do you bring this into any responsibility/cost sharing scheme.

     Perhaps the 1% VAT would be the easiest, and certainly th echapest to manage system.

  • Fri, Jun 27 2008 12:44 In reply to

    • 2658336
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    Re: Who should decide animal health policy and pay for disease costs?

    As a smallholder, I don't think many of us object to paying our fair share of health costs.  We DO object to subsidising larger farmers via large health scheme membership fees, as in the present MV scheme. 

    Otherwise, looking at recent large recent animal health costs, "polluter should pay":

    BSE    Gov.t changed regulations to allow feeding of under-processed meat and bone meal.  Central Government should pay.

    BSE in sheep (National Scrapie plan)    Public health, not animal health issue                     Central Government should pay

    Foot and Mouth (2000/1)   Imported from Africa as a result of inadequate controls.               Levy on air transport and food importers

    Foot and Mouth (2007)              Government laboratory bungle.                                          Central Government should pay

    Blue tongue             BTV8 imported to Maastricht from Nigeria by air freight                        Disease risk levy on air transport

    Avian Flu                 In Europe an endemic disease of wild birds now                                  Only partial compensation for flock slaughter, i.e. producer pays some, but as the disease is also a public health issue, public health budget should pay some

    TB in cattle             Spread mainly by Badgers, 15% by cattle movement.                          Split costs between Central Goverment (Public Health component, although pasteurisation kills TB) , producer (pre movement tests) , and the RSPCA etc if no Badger control allowed .

     

    Spread of diseases around the world by air transport is a major issue, which the press and chattering classes haven't yet latched onto: sea (and sometimes land) transport is usually slow enough to be self quarantining.  We have had two serious animal epidemics almost certainly arrive via air transport in the last 10 years: next time it could be a killer human disease.

                                                                                                                                                                                                                                                      

  • Fri, Jun 27 2008 13:32 In reply to

    • townie
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    Re: Who should decide animal health policy and pay for disease costs?

    2658336:
    Spread of diseases around the world by air transport is a major issue, which the press and chattering classes haven't yet latched onto: sea (and sometimes land) transport is usually slow enough to be self quarantining.  We have had two serious animal epidemics almost certainly arrive via air transport in the last 10 years: next time it could be a killer human disease.

    The mass transportation around the world of homo sapiens is the biggest health risk we face.

     

  • Mon, Jun 30 2008 15:18 In reply to

    Re: Who should decide animal health policy and pay for disease costs?

    I've just being doing a little research about the consultation process on this issue and found something quite shocking. The first consultation on this issue ended on 28 April and a summary of responses has been issued by DEFRA. It reveals that 14 farm organisations responded - one assumes the NFU, CLA, TFA, NBA, NSA etc are all in this group.

    The bit that surprised me is that only 19 other farmer submissions were put forward. I know some people will have attended one of the workshops, but given this is such a controversial and important issue I expected the number of individual farmer submissions to be higher.

    The reason I was looking for the info is that I was considering doing some kind of survey at the Royal Show (where Lord Rooker is talking about this issue). Having seen the figures, I think I definitly will - because I can then collate the info and send it to DEFRA as a group effort from the farming community.

    So if you have more comments fire away....

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  • Mon, Jun 30 2008 17:38 In reply to

    • Peter Wells
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    Re: Who should decide animal health policy and pay for disease costs?

    On the precise, and some would say, the pedantic point of who decides what action and the extent of that action to take, we should not let policians muddy the waters by serving with them on any body or committee that is responsible for anything other than to collect and collate data analyse the data and then to generate ideas.

    It is my view, that bodies on which we serve should not make recommendations, this is because it is the role of Politicians to make decisions and then to gain office or lose office on the back of those decisions. If a committee on which farmers play a part (probably a small part) recommends a course of action which is subsequently taken up, then, irrespective of the consequences, the ruling party of the day will say that farmers were consulted and agreed with their action.

    We should not be seduced (as are all NFU Presidents) into becoming part of the governing elite and thus allow politicians to use our contribution when and how it suits them.

    We should contribute but only up to the point of analysis of data and generation of ideas. The next logical steps as to recommendations, programmes and action plans are the realm of Politicians and Bureaucrats and we should not give them opportunity to hide their decisions (good or bad) behind recommendations deduced from the work we have done.

    To them must go the Glory, the Power and the Honour (or opprobrium)

    Amen.

     

     

     

  • Mon, Jun 30 2008 18:40 In reply to

    Re: Who should decide animal health policy and pay for disease costs?

    Isabel

    Unfortunately despite a considerable amount of advertising the majority are sleep walking into this.

    The workshops were pitifully poorly attended almost to be embarassing by how few people turned up to voice there opinion. I attended one and wrote a lengthy submission and fear that we will have something imposed upon us due to the lack of interest by the grass roots.

    I can just see the complaints when every animal that is moved has to pay a levy. It is also intended that as many people as possible will contribute, that includes arable farmers for which there would be a levy on feed corn and sugar beet pulp etc. Now none of this is in place yet it is all suggestions as is VAT on all food.

    I personally believe it would be better to contribute to an insurance policy that is owned and run by the industry, not a levy that will go into government coffers.

    It would do the industry a great service if you could highlight some of the suggestions that are being put forward, we will not stop this but we do have an opportunity to mitigate it.

  • Mon, Jun 30 2008 19:04 In reply to

    • sjk
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    Re: Who should decide animal health policy and pay for disease costs?

    When exactly were the workshops as we would have liked to have gone but didn't know usually we get an email about things like that from the NSA and although they had an article about it in one of the news letters I can't remember it saying anything about workshops on it so I presumed it was something that only the people like the NSA, NFU etc were involved in and not individual farmers.

    But if they were held between Febuary and May it seems a bit off due to the fact that most farms are either in the middle or are preparing for lambing and rushed off their feet. But I guess it is like the NSA were saying about compulsory EID that although they are doing everything they can to stop it very few farmers say anything about it and just hope it will never come etc then kick up hell and complain about it when it comes as they think no one opposed it.

    Sam

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  • Mon, Jun 30 2008 19:25 In reply to

    Re: Who should decide animal health policy and pay for disease costs?

    They were earlier this year. We did publicise them, but I think people must have been really tied up.

    http://www.fwi.co.uk/Community/forums/p/12838/76394.aspx#76394

     As I said before I'm going to try and do a survey. I'll post a copy here once it is finalised so you can also feed in.

     

     

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  • Mon, Jun 30 2008 19:40 In reply to

    • sjk
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    Re: Who should decide animal health policy and pay for disease costs?

    Just a little bit although I'm suprised they didn't have the one in Kent at Ashford market as opposed to Tunbridge Wells as then they usually have about them in the reports bits we get in the post which might get glanced through then but saying that when we are busy most letters don't get looked at other than the bills at lunch.

    Sam

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    Groucho Marx

    Man does not control his own fate. The women in his life do that for him.
    Groucho Marx
  • Mon, Jun 30 2008 21:48 In reply to

    Re: Who should decide animal health policy and pay for disease costs?

    Isabel,

    Why dont you set a general question with a yes no answer to it so that numbers can be counted and given to Defra on this subject.Something along the lines: Do Farmers support Defra controlling Animal Health or should it be an Organisation completly separate from Government.

  • Tue, Jul 1 2008 10:06 In reply to

    • Jacobus
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    Re: Who should decide animal health policy and pay for disease costs?

    burocrat basher:
    Do Farmers support Defra controlling Animal Health or should it be an Organisation completely separate from Government.

    bb, as usual I like your style, but it is a bit divorced from reality.  This isn't a debate about who decides what, for the most part that is already outside the hands of the UK or devolved governments.  It is in the hands of the EU Commission.

    If Animal Health were a film, the EU has the starring role, The UK government has a supporting character part, The devolved administrations have one line walk-on parts and we poor sods are faces at the back of a huge crowd scene.  In fact, thinking about it, we're probably dead bodies at the back of a huge crowd scene!

    What this debate is about is how the amount spent by Defra on Animal Health is funded.  The government have indicated that rather than being a drain on taxpayers in general, the livestock industry should fund it directly by having to pay a new form of stealth tax.  They are calling this tax 'cost sharing', and, as a novel wheeze on making it more palatable, are suggesting we should have some influence over the Animal Health policies on which it will be spent.

    This is my view of the realities:

    Policy decisions - the majority of strategic policy making is at an EU level.  There are plenty of examples where EU policies are made with no apparent benefit to anyone let alone farmers eg. EID and are against the interests of the UK, but they still get enacted.  Any variations allowed at a national level, as Peter says, should be made by the politicians.  Most such decisions seem to go through a consultation process, so the views of interested parties are heard already.  So what's new?

     

    Cost Sharing - I have tried to find some information an the disease control costs already shouldered by the industry, without success.  If you think about it, the total value of:

      • Vet fees for farm animal work
      • Prescription drugs/vaccines (including BTV8)
      • Over the counter drugs/vaccines/other veterinary treatments/disinfectant etc.
      • Compulsory pre-movement testing - including TB and BTV
      • Vet fees for attendance at markets etc.

    must come to a very significant sum.  I wouldn't be at all surprised if was actually many times the size of the Animal Health 'bill' that Defra is wanting us to share.  It seems to me that the majority of Defra costs they want our contributions to relate to notifiable diseases, many of which are outside our control.  If they want us to share some of these costs, why don't they suggest they should share some of ours?  Silly question - I know!

    Producers are the weakest economic link in the food chain - the structure of the industry is such that the producer, especially the traditional size farm, but true even for larger scale producers in pigs and poultry, is the weakest economically.  The price we receive for our produce is dictated by the retail buyers or processors supplying them.  If our costs go up it comes straight off our bottom line.  The only effective market mechanism is producers going out of business.  If the price doesn't suit, the buyers will go elsewhere, where the proposed disease control costs either don't exist or are met by government.

    Defra wants the producer to pay - literally, by a reduction in his income. The alternative is that the producer pays and in an ideal world that cost gets passed on to the processor, retailer and the consumer.

    Ultimately, disease control is part of producing food.  The costs should be met by those eating it. At present these costs are met from general taxation.  This may seem unfair on Vegans, but there are very few of these.  Every other taxpayer eats meat, eggs, fish or dairy produce.  The poorest in the population don't pay tax, or don't pay much tax.  Isn't this fairer than increasing the cost of food or adding another stealth tax on farmers?

     

     

  • Tue, Jul 1 2008 11:05 In reply to

    Re: Who should decide animal health policy and pay for disease costs?

    Jacobus,

             I concur with most of what you say but I dont think that Disease control is absolutly down to EU.A good example is the TB scam where Defra [The Labour Govt ] are dictating the Policy being used to try and Control this Disease on the ground .Sure the EU lays down the Parameters to control and I think if the EU did control this field completly there would be WILDLIFE CONTROL to control this Disease.Because the RSPCA gives the Labour Party Donations and because Badger Groups belong to the RSPCA Defra are Hamstrung Politically by a Govt that has another Agenda on its mind rather than Disease Control .Hence my thoughts on why Animal Health should be taken out of Politics.

  • Tue, Jul 1 2008 12:14 In reply to

    • Peter Wells
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    Re: Who should decide animal health policy and pay for disease costs?

    Once again Jacobus has hit the nail on the head so well that it has been driven home, leaving one thinking that there is little point in hitting the nail again. However, I think a little tap on its head might be made as we think of the relationship between the effects of animal health on humans and the effect of human health on other humans.

    As farmers, we are being asked to bear a significant proportion of the costs to the general taxpayer of diseases affecting those animals over which we have some degree of discretionary control. By and large, in the past we have obviousely managed our discretionary element well, because such scares as occur from time to time are usually the result of inadequate control at processors, retailers or government laboratories.

    So ! Farmers have generally proved to be responsible in maintaining adequate animal to human disease control.

    What now about the effects of Human to Human diseases the effects of which are also paid for out of general taxation? How can the government make those responsible for deleterious effects on other humans also pay, in the same way as it expects farmers to pay for the effects of animal to human disease?

    Here is my list of how Ministers make the following groups/activities pay for the costs they put on the public purse. .

      1. Obesity. Free
      2. Teenage pregnancies. Free
      3. Sexually transmitted diseases. Free
      4. Sugar. Free
      5. Immigration whilst knowingly carrying human infectious diseases. Free
      6. Smoking. Tax
      7. Alchohol. Tax
      8. Motoring Accidents. Insurance.  Fines. Imprisonment
      9. Drugs. Fines, Imprisonment
      10. General Lawlessness. Fines, Imprisonment.

    We can thus see that for many activities that have consequences for others, the government imposes taxes or laws, but that for some other groups the consequnces of their actions are free to them. However this situation is complicated because for some groups the government also pays large sums of money, via lawyers, social workers, probation officers etc, to help them escape the penalties that the government has, itself, imposed on them.

    I suppose I am being silly in expecting consistency from this government however, unless it follows Jacobus's suggestion of taxing food; to be consistent it should now set up agencies to help farmers avoid the personal costs it now wants to place upon them. Any suggestions for names for these organisations?

     

  • Tue, Jul 1 2008 12:32 In reply to

    Re: Who should decide animal health policy and pay for disease costs?

    Here is the survey (see attachment). If you want to save it to your own computer fill it in (obviously you can't circle the answers, but make it clear somehow).

    You can email it back to me

    FWiSpace caretaker. Drop me an email if you've got any questions or problems with the site.
  • Fri, Aug 15 2008 20:28 In reply to

    • johno
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    Re: Who should decide animal health policy and pay for disease costs?

    it sounds like this cost sharing is going to be on a per head basis

    defra will set the fee per head and per type of animal

    the payment will also be linked to the risk of disease breakdown e.g.  those in tb hotspots will pay double

     

  • Sat, Aug 16 2008 0:06 In reply to

    • Jacobus
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    Re: Who should decide animal health policy and pay for disease costs?

    Does anyone remember the DEFRA five year plan from 2005?  The FWi report at the time started as follows:

    DEFRA HAS published a five-year strategy which promises farmers that the department will slash red tape and become a "smarter regulator".

    Of course, that was back in the olden days when Ma Becket was on the throne, and the five years will be up before the latest DEFRA nonsense hits the fan, but apart from providing jobs for more civil servants, what benefit is to be gained from yet another form for livestock keepers to fill in, to be submitted to a new department, the data entered by new staff, on a new database, which won;t be ready in time and will take years to work properly? 

    If we've got to pay some contribution to running this ludicrous government agency, why does it have to be collected in such a way that a large chunk of our money will instantly go down the drain in administrative costs?

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