Thank you, Chairman. I am accompanied by my colleagues, Mr. AidanMurray, Mr. Brendan Gleeson, Mr. Billy McAteer and Ms Anne-Marie Dempsey. We are pleased to be present to assist the committee in its examination of the Commission's proposal to which you have referred, Chairman. In layman's language it is referred to as the live exports regulation.
By way of background, Ireland exports significant numbers of cattle to the continent. These exports consist mainly of younger animals - calves and weanlings - which are mainly for production fattening. The main destinations are Spain, Italy and the Netherlands. Some 39,700 cattle in 2001 and 101,000 cattle in 2002 were exported to the continent. The corresponding figure for this year is higher already, at 117,784 head of cattle. In addition, 29,900 adult cattle have been exported to the Lebanon this year and 24,861 to Northern Ireland, bringing the total number of live exports in 2003 to 172,000. From these figures it will be clear that these outlets are vital to the livestock sector. They provide a good economic return and competition within the sector. For the most part, cattle are transported to the continent on roll-on/roll-off vessels, although on occasions dedicated cattle boats are used.
Apart from cattle exports, we also export smaller numbers of breeding pigs and horses to the continent. As a country which is heavily dependent on livestock exports to sustain competition and farm incomes, Ireland has been to the forefront in introducing rules for the transport of animals. In particular, detailed welfare related rules were applied in Ireland prior to the adoption of EU-wide rules for both intra-Community and third country trade. This regulatory regime has contributed significantly to protecting the welfare of animals being exported and there have been insignificant numbers of mortalities in animals being transported under the regime that has been in place since the mid-1990s.
It is often forgotten that exporters and transporters have a vested interest in ensuring that animals arrive at their destinations in good condition because prices are frequently based on the weights at arrival, and in the context of securing repeat business.
On the draft regulation that is now before the Council and this committee, in July this year the Commission published its proposal for a Council regulation to strengthen the controls on the welfare of animals during transport. This proposal follows a widespread consultation exercise by the Commission and is based, in part, on an evaluation of some scientific information by the EU's scientific committee on animal health and welfare. Not surprisingly, producers, transporters and exporters on the one hand, and animal welfare groups on the other have different perspectives on the various elements of the Commission's proposal.
The Commission's proposal includes a number of elements relating to the registration and training of transporters, improved control arrangements along the chain of transport, including the possible use of tachographs, and a focus on improved mutual assistance among member states. Ireland has traditionally favoured the strict implementation of existing rules and is at present engaged in an exercise to develop a harmonised system of sanctions for transporters in breach of those rules.
The proposal also provides that sea journeys are not to be considered as part of the overall journey time. We are particularly pleased that the Commission has adopted this approach which we have consistently advocated. However, other elements of the proposal involve a ban on the use of staging posts, reductions in stocking densities and in the maximum journey times allowable prior to a rest period. It is important to remember this is a Commission proposal, examination of which has only recently commenced at the various fora in the Community. Chief veterinary officers discussed the proposal at the end of last month and there is a further Council working group meeting on 23 and 24 October. I suspect the proposal will remain in the various fora of the Council for some time before it is eventually considered in detail at Council of Ministers level. It is rare that a proposal made by the Commission is adopted in that particular form.
We have undertaken some examination of the proposal and are currently engaged in a consultative process with the Commission and stakeholders to acquaint them of the implications of the Commission's proposal and, in the case of stockholders, to get their particular perspectives and to explore with them in some detail various aspects of the proposal. This latter aspect will encompass farmer representative organisations, exporter and transporter interests and welfare bodies at national level. This process is continuing.
Against that background, and bearing in mind that its consultative process has not yet concluded, the Department considers a number of specific aspects of the proposal to be problematic, to put it at its mildest. These aspects are, to a large extent, interrelated but I will deal with them one at a time.
On the staging post element, the Commission proposal provides that animals of all species should be rested for 12 hours on board the road vehicle on which they are travelling rather than for 24 hours at a staging post as is currently provided for. The Commission has based this element of the proposal primarily on concerns about the potential spread of disease where animals mix at staging posts and travel onwards to different destinations. However, on welfare grounds, the Department strongly favours retention of arrangements for unloading animals other than pigs at staging posts. In this regard, it is considered that unloading feeding at such posts rather than retaining them on trucks for 12 hours best meets the welfare needs of cattle. If necessary, disease concerns can be addressed by applying rules on the use of these posts - for example, by confining the use of individual staging posts to animals from a single sea-going vessel at the same time, by a cleansing and disinfection regime, etc. In the case of pigs, it appears to be widely accepted that resting them on the vehicle because of their susceptibility to stress at loading unloading times best protects their welfare. However, even in the case of pigs, it will be essential to identify places - probably staging posts - where vehicles can pull in to allow the animals to rest on the vehicle. Many truck stops on the Continent discourage or do not allow vehicles carrying livestock to stop.
Turning to stocking densities, which are to some extent related to the proposed ban on staging posts, this element of the proposal provides for a reduction in stocking densities by up to 30% in some cases. This element results mainly from the proposal to ban the use of staging posts and to allow animals to properly rest on the vehicle. However, Teagasc research work involving the transport of cattle to Spain and Italy under existing stocking density and journey time provisions, and comparison with a control group on a farm in Ireland, indicates that the existing regime, when properly applied, is not detrimental to animal welfare. In those circumstances, and in view of its wish to retain the possibility of unloading animals at staging posts, the Department favours retention of stocking densities as close as possible to the existing provisions.
Turning to journey times, the Commission is proposing to change the journey time-rest cycle primarily because of the proposed ban on staging posts and the consequent need to rest and feed animals on the vehicle, and to harmonise animal rest times with those of the driver under Community legislation. For all species the Commission proposes that the journey time-rest cycle would be nine hours travel followed by 12 hours rest on the vehicle, followed by nine hours travel and so on. This compares with the current regime which provides, in the case of adult cattle, for travel of 14 hours followed by one hour rest on vehicle, followed by 14 hours travel followed by 24 hours rest at a staging post and so on.
Although the Department believes that the existing regime is not detrimental to the welfare of animals, it would, nevertheless, be prepared to discuss alternative arrangements provided the needs of our island status are catered for and there is a degree of flexibility built into the new regime on completion of journeys. They are the elements of the proposal that create the major problems for the industry and the Department. They are interrelated and I have explained the Commission background and our thinking.
I will turn to some other elements with which we have some difficulties. On sea-going vessels, we believe we have more experience than other member states in this area and we consider the welfare proposals are probably less animal welfare friendly than those currently in place Ireland. We have had much experience of approving seagoing vessels. In the past, we have had difficulties with shipments abroad but the current regime has avoided large scale mortalities of the type witnessed prior to the mid-1990s. For example, we would like to see the Commission propose provisions relating to weather conditions and vessel stability. A difference in the standards of vessels approved in other member states could lead to trade distortions and could compromise animal welfare.
In regard to the legal basis for application of the proposal, the Commission has proposed a regulation but we would favour a directive that would allow for greater flexibility in the implementation of the new rules, taking into account the different systems for assembling and transporting animals in different member states.
We have stated our basic position. The Department has a consistent position on live exports, that is, that they provide a vital market outlet for the livestock sector. Accordingly, and with due regard to the current consultative exercise, the Department's focus in the forthcoming negotiations will be to ensure that this trade can continue on an economically viable basis, while always ensuring that the welfare of animals being transported is protected.
