The European Union Committee (or rather its Energy and Environment Sub-Committee) of the House of Lords has just released its latest report looking at the challenges posed by Brexit.
This one was looking at plant and animal biosecurity, particularly how leaving the EU may alter the risks to native species, farmed livestock and food consumers from invasive species, pest, diseases and contaminants. It also studied the UK’s capacity to identify and manage such risks.
Perhaps reflecting the nature of debate in ‘the other place’, the language is fairly gentle, couched in terms of urging and encouraging rather than insisting or demanding (despite the same approach in previous reports having had no discernible impact on government action).
Yet it is difficult to read the conclusions and recommendations as anything other than a stark portrayal of difficult choices that will soon have to be made.
Currently, the UK benefits from formal and informal participation in a number of EU-wide networks and institutional arrangements relating to various aspects of biosecurity.
These range from links between universities and other research bodies to share information and expertise on the ecology and epidemiology of pests, diseases and invasive species, through surveillance mechanisms for detecting and raising alarms about changing risks, to agreed common processes for managing risks and auditing procedures to ensure adherence to agreed processes.
Notwithstanding government assurances, Brexit puts continued membership of these networks and arrangements into question.
Either bespoke agreements need to be reached to maintain continued participation and to benefit from shared information, knowledge exchange and common processes or the UK has to replicate (and resource) a whole host of overhead functions currently shared and supported across 28 countries.
It is not that the UK is necessarily incapable of replicating these functions (although there are concerns about the availability of suitably skilled and experienced staff, such as for border controls or even abattoir inspections, not least since many such positions are currently filled by EU nationals).
It is more a case of the additional administrative burden of designing and implementing such functions and then the additional on-going funding requirements. Is it really sensible to reinvent wheels?
And how much faith should one have that we can do so in double-quick time? Few if any of folk providing evidence to the Committee seemed to have much faith in the wisdom or practicality of this approach.
Alarmingly, the report notes the possibility of Ministers taking direct responsibility for some decisions, including food safety.
Given competing demands on their time, this raises questions around how much deliberation and scrutiny could feasibly be exercised, but also around the maintenance of arms-length decision-making around such issues.
The Food Standards Agency came into being in the wake of the BSE (‘mad cow disease’) precisely because it was deemed no longer appropriate for Ministers to have direct responsibility for food safety issues and therefore independent oversight by specialist bodies able to identify and assess risks was preferable.
Yet the alternative of negotiating continued membership of current arrangements depends on either some comprehensive deal (oh dear), or on bespoke negotiations about specific functions and networks. In this case, the fear is that second-class membership may mean reduced access.
For example, not receiving all information, or at least not as quickly as before – which can matter enormously when trying to combat the spread of some pests and diseases.
Failing to have adequate systems in place is not really an option since nature does not respect administrative boundaries, and even if all cross-border trade ceased the UK would still be susceptible to wind-borne and sea-borne incursions: spores, viruses and insects carry on the wind and ocean currents whilst migratory birds and marine species don’t have passports.
Add in the movements of people, vehicles, planes and shipping carrying all manner of biological materials (declared or not) and the need for biosecurity measures is clear, unless we are suddenly comfortable with not bothering to assess or mitigate biological risks to our environment and food.
Some witnesses at the Committee’s hearing on the report actually pushed for tighter biosecurity after Brexit, pointing to (for instance) Australia and New Zealand as examples of how we could do things differently.
The notion of ‘whitelists’ for explicitly permitted imports as opposed to ‘blacklists’ of banned imports was one interesting idea. However, pushing for tighter controls exacerbates concerns about resourcing.
For example, how many border staff would be needed? And how much will new databases cost? £5.1m has already apparently been spent on replicating the EU import tracing system.
In addition, calls for tighter controls serve to highlight an existing tension between the desire to improve biosecurity and the desire to maintain frictionless trade: checks and inspections may help to mitigate incursion risks, but they also impose trade costs and discourage movement of people and goods.
Agri-food supply-chains spanning the border between Eire and Northern Ireland illustrate this tension well, layering-on yet another complication to that particular tricky problem (although it is interesting to note that there are already some biosecurity checks between Northern Ireland and Great Britain – pay attention to the cabin staff announcements if you fly into Belfast from Cardiff, Edinburgh or London).
Oddly, no mention is made of planned changes to livestock traceability through the ambitious Livestock Improvement Programme (LIP) which seeks to replace existing systems in England and (possibly) Wales (Northern Ireland and Scotland are doing their own systems) most notably the Cattle Tracing System (CTS) which was effectively declared no longer fit for purpose last year and was supposedly to be replaced by (coincidently) March 2019.
Delivery of the LIP has yet to be put out for tendering, which doesn’t exactly augur well for quickly replicating all the new functions potentially required if we lose membership of EU-wide biosecurity networks.
Oh well, maybe I should just have confidence in confidence and assume that Ministers know what they’re doing.
By Dr Andrew Moxey, policy analyst at the Centre for Rural Economy, Newcastle University.
The views expressed in this analysis post are those of the authors and not necessarily those of the UK in a Changing Europe initiative.