AEA SUBMISSION TO THE NEXT GOVERNMENT
January 8th, 2010AGRICULTURAL ENGINEERING ASSOCIATION
SUBMISSION TO THE NEXT GOVERNMENT
Introduction
Agricultural engineering – the manufacture and supply of tractors and farm machinery – has a vital role to play in the support of world agriculture. It was ahead of many other industries in responding to the globalisation of the market place.
At first the UK benefitted from this because several of the multinational tractor companies had manufacture and assembly plants in this country, supplying not only Europe but the Middle East and Africa also. In the last two decades several of these companies have switched production to the Continent or to South America. As a result the UK has moved from being a net exporter to a net importer of farm equipment.
Similarly, the Outdoor Power Equipment industry – the manufacture and supply of equipment used in public parks, corporate facilities, golf courses, sports grounds and consumer lawn and garden is an important sector and has also become more multi-national.
Nevertheless the Farm and Outdoor Power Equipment industries still have a substantial UK presence. The industry has a total value [production plus imports] of £4.1 bn. In 2008 £1.6 bn of domestically manufactured farm machinery was exported, mainly to Continental Europe.
The General Economy
The perception of the AEA on current policy needs is as follows:
European Industry: The 2008/2009 fiscal world crisis has brought the economic dominance of the USA and Asia into sharp relief. The future prospect is of intense competition, with China producing more high value quality products to satisfy not only its own expanding market but for sale elsewhere in the world. At the Lisbon summit the EU pledged itself to develop the knowledge economy but it is the United States that is consolidating its lead in this area.
At the same time as the world population is predicted to increase to 6 bn by the year 2050, the demographics for Europe show that the working-age population by that date will have fallen by at least 18% and the numbers of those aged over 65 years will have increased by 60%. Irrespective of the need to climb out of the current crisis, how is Europe (and the UK in particular) to prepare itself for these developments which will have a direct bearing on GDP growth rates?
Food Security and Climate Change. Leading figures in world agriculture, gathered at the Food and Agriculture Organisation in November, agreed that to meet developing world scale food shortages
(a) every advantage should be taken of scientific and technological innovation in food production, thus confirming the key role to be played by GM technology and agricultural engineering;
(b) that public and private investment in agricultural infrastructure had to be increased throughout the world in order to intensify and expand food production; and
(c) there should be more open trade in food products between countries, both developed and developing.
Against this background the agricultural engineering industry has good prospects for development but needs a background of macro economic stability and an academic and institutional research capability to complement the product research undertaken by companies. Governments have a major role to play in both of these objectives.
Competitiveness: Every effort must be made to increase and improve the competitiveness of European and UK industry. Without resorting to a command economy governments are able to use public finance to stimulate business activity in the manufacturing sector. There is a need to re-iterate the basic principles which are:
a. The development and encouragement of an enterprise culture.
b. Improving the performance in industry of science, research and innovation.
c. The development of a skills base relevant to the global economy.
d. Supporting exporters and re-establishing the UK as a leading destination for inward investment.
e. The delivery of secure, sustainable and affordable supplies of energy.
AGRICULTURAL ENGINEERING AND OUTDOOR POWER INDUSTRY SPECIFIC POLICY REQUIREMENTS
1. Research and Development: Agricultural engineering research is in danger of being pushed to the margins. The emphasis in all of the proposals for the investment of public funds to improve food security has been on the biological sciences. Since the closure of the Silsoe Research Institute [formally the National Institute of Agricultural Engineering] in 2005 there has been very little public funding allocated to farm equipment research in the UK. Large companies have of course improved their own products and the best of the SMEs have kept at the front of the market but there is scope for wider more academic research into such subjects as electronic instrumentation and controls, precision agriculture, automated inspection systems, new materials for machinery construction, water quality and management and energy conservation.
Defra has the main policy responsibility for dealing with food security. At least three of the Research Councils have a project responsibility affecting food security. Research Councils UK and the Technical Strategy Board have done much to encourage multidisciplinary research and are attempting to co-ordinate publicly funded programmes. However the fact that agricultural engineering has been neglected could indicate the need to establish in the UK a National Institute of Food and Agriculture, similar to the NIFA created in the United States earlier this year. This would be a focused body with overall responsibility for the direction of policy and co-ordinated programmes of research into food supply and quality and crisis management.
Action taken by the industry: The industry has created the Land Equipment Research Partnership with assistance from the Bomford Memorial Trust with the object of bringing together a record of the total agricultural engineering research capacity in the UK in order to make the relevant options known to companies seeking product improvement.
Action required by the next Government: There is a need to stimulate and assist in funding the agricultural engineering sector research base to complement the work the companies are doing. In particular, strategic pre competitive research including how machinery can be developed for a low carbon environment.
Establish in the UK a National Institute of Food and Agriculture (as in the USA). This would be a focused body with overall responsibility for the direction of policy and co-ordinated programmes of research into all aspects of food supply, quality and crisis management.
2. Employment Skills: Like many of industries in manufacturing there is a need in agricultural engineering to improve the quality of skilled labour and to attract good candidates to take an interest in a career in the industry. In the opinion of the AEA the Learning and Skill Council has proved to be insufficiently responsive to this need and should be restructured to increase the policy input from industry. Skilled staff are needed, not only in manufacture and assembly but also in the provision of after-sales service. A large percentage of the companies rely on recruiting skilled staff from other firms in the industry as well as training and promoting their own employees. The increasing sophistication and complexity of tractors and land based equipment requires many employees to have a good understanding of electronics and IT systems.
The introduction of more flexible short-term courses for the Graduate, Engineering Technician, and Chartered Engineer designed to increase skills and to enable them to deal with emerging technologies.
More positive incentives should be provided to both SME employers and workers for career transition and some line training and support.
Action taken by the industry: The Association was a partner with LANTRA and the Institute of Agricultural Engineers in the creation of a common industry standard for Land based Technician Accreditation [LTA] training. This gives employees a qualification status and career path that will encourage them to stay in the industry.
Action required by the next Government: A future government should again review the school’s curriculum to include increased provision of science, technology, engineering and mathematics related subjects.
3. Open Markets and Competitiveness: Our industry in the UK is composed of British companies looking for markets abroad and multinational global suppliers. Both of these categories are looking to the government and the European Union to develop a trade policy that leads to free and fair trading conditions internationally and effective internal market surveillance. Within that framework the industry is also looking for access to energy and raw materials at reasonable and competitive prices.
The Association advocates strong resistance by the government and the European Union to any form of protectionism. In particular we currently deplore the barriers raised by the Russian government to the import of combine harvesters and other types of land equipment in the defence of its home industry. Similarly the seizure by the French government of imported outdoor power product on the basis of debatable safety concerns, as a means of depriving the manufacturers of access to a profitable market, is unacceptable and in the circumstances difficult to contest in the French courts.
In view of the failure to conclude a satisfactory outcome in the Doha Round of WTO negotiations, the AEA fully supports the pursuit by the European Union of bilateral trade and political agreements. In the opinion of the Association these agreements should include matters outside the scope of the agreement sought by the WTO, including public procurement [many developing world contracts for tractors and land equipment are contracts with governments], the strengthening of Intellectual Property rights [product sophistication is an important advantage in developed world manufacture of land equipment], and the breaking down of trade barriers similar to those mentioned above.
In the interests of both the agricultural and outdoor power sectors of the industry, the Association believes that there is a need for a future government to continue to monitor closely the Chinese business and regulatory environment.
Action taken by the industry: The Association has developed a valuable system of market intelligence including the collection and distribution of industry statistics, which sharpens competition between companies within the industry and assists with the management of an efficient after-sales service to the benefit of the customer. It also actively supports the industry’s European organisation, CEMA, in seeking to identify and break down international trade barriers.
Action required by the next Government: The Association advocates strong resistance by the government and the European Union to any form of protectionism. There is also a need for a future government to continue to monitor closely the Chinese business and regulatory environment.
4. International Standards: The progressive globalisation of manufacture and trade in agricultural engineering and other industrial sectors leads inevitably towards the need for the recognition of a single source of product regulation and manufacturing standards. The Association believes that national standards institutes have no substantial role to play in this scenario and could be reduced in capacity and eventually phased out.
In the UK the BSI has become principally a publishing agency for CEN and ISO Standards. Within the present structure the profit made from the sale of standards should be used more beneficially to assist the industries that it serves.
A substantial amount of the standards co-ordination work of BSI is now performed by trade associations and other agencies. The transition from a national to a European (CEN) or International (ISO) platform could occur without undue disruption and with an immediate cost saving to government and to purchasers of standards, many of whom have contributed time and resources towards the agreement of the standard.
Actions taken by the industry: The Association is a substantial participant in standards committees at all levels and acts as chairperson and co-ordinator of many CEN and ISO committees of direct relevance to the industry.
Action required by the next Government:
- Review the role of BSI and transfer savings to the benefit of the industry it serves.
- To fund key associations, such as the AEA, that can provide advice and expertise to under resourced government departments such as DFT and BIS. Funding is the key.
5. Export Support: Throughout Europe there is an emerging awareness that economic dependence on the service industries has its dangers and that an imbalance has developed between invisible and visible trade. In parallel with measures to encourage manufacturing, governments (including the UK) will have to put more emphasis on the promotion of exports. It is only in this way that the balance of payment can be improved and wealth generated to pay inflated national debt.
Action required by the next Government: The Association recommends:
- The reinstatement of financial assistance to Small and Medium-sized Enterprises to enable them to take part in overseas sales missions and trade fairs.
- The introduction of a system of Trade Credit Insurance to cover the failure to receive payment, particularly in contracts with purchasers in developing countries that are regarded with suspicion by UK banks.
- to organise its export support by sector: at present support for export activity is administered on a regional basis. Overseas missions and other co-ordinated export programmes are organised on an industry or sector basis.
- Make a determined effort needs to be made to improve the quality of UKTI representation abroad. This has been done in the past but in the struggle for orders competing nations are constantly upgrading and expanding the overseas support given to their own national corporations.
- Conduct an urgent review of the aims and outputs of the International Agri-Technology Centre [IATC] on the promotion of UK skills and expertise in the agri-food & related technologies sector.
6. Tractor/Trailer Testing: The industry has queried whether many agricultural trailers in use by farmers have sufficient braking power to be classed as safe on the highway. There is also frustration on the part of farmers (and country road-users) that by UK regulation tractors cannot be driven at speeds faster than 20 mph and that maximum weight loads are limited to 24,390 kgs.
The AEA would combine these linked policy issues into one proposal, namely that trailer/tractor braking tests be introduced and that, for such combinations meeting enhanced criteria, the maximum permitted road speed for tractors with front suspension be raised to 30 mph and the maximum weight load be increased.
Currently at speeds below 20 mph an agricultural trailer must have a braking efficiency of not less than 25% but a 50% level would be part of the higher requirement within our proposal.
A new braking Directive is to replace the existing Directive 76/432/EEC in 2011/12. The new controls will make trailers without safe braking systems impossible to sell (although a substantial part of lower specified trailers will exist for many years to come).
Actions taken by the industry: The Association has entered into negotiations with the Department of Transport, NAAC, NFU and BAGMA with a view to agreeing the appropriate changes to the law and creating a network of centres equipped to undertake the necessary testing. It does however believe that the testing of the braking system on the tractor is an integral part of the overall safety check and this has proved to be controversial.
Action required by the next Government: DfT to change the law to permit users to meet improved speed and weight requirements subject to appropriate testing.
7. Pesticides - The Voluntary Initiative: In the last 40 years the world population has nearly doubled. Agricultural technology has kept pace with food demands and globally farmers are now producing more per head of the population than 40 years ago. Will the same be said in 40 years time? Insecticides, herbicides and fungicides reduce crop losses both before and after harvest, and increase crop yields. They are however chemical substances and must be used with the utmost care.
The farming industry has faced that responsibility by joining with environmental groups to create the Voluntary Initiative which is designed to promote best practice in the use of pesticides by farmers. Collaterally the NFU is also promoting the Crop Protection Management Programme to its members as part of the Voluntary Initiative.
The AEA believes that any further control or restraint that may be considered necessary to limit the use of pesticides, can be accommodated and administered within the framework of the Voluntary Initiative.
Actions taken by the industry: The Association administers the National Sprayer Testing Service. NSTS ensures that sprayer machines used in agriculture are properly calibrated (a speed check can be included as an option should the machine owner wish to have the electronic control system checked) and deliver pesticides as efficiently as possible, with minimum impact on the environment.
Action required by the next Government: Governments must be realistic that they have no chance of feeding the world by organic means alone. Pesticides do provide a pragmatic and increasingly safe option. Any further restraint from the EU should be resisted and the work of the Voluntary Initiative and NSTS should continue.
8. Machinery Directive: The Association supports the EU type-approval system. A new Machinery Directive [2006/42/EC] will come into operation on 29 December 2009. This will be complimented by the introduction of a revised Market Surveillance system for the harmonisation of safety controls throughout the EU. The AEA welcomes the strengthening of common machinery standards in the Single Market and is anxious that the enforcement should be adequately monitored by the European Commission. The conformity of products imported, predominately from countries in the Far East with lower safety standards, is seen as a priority.
Tractors have long been the subject of separate type-approval legislation dealing with all aspects of safety. The Association notes that on this account tractors have been excluded from the Machinery Directive in all respects except those risks not covered by tractor type-approval. The Association believes that any such inconsistencies can be brought within the tractor type approval regime quickly.
Action taken by the Industry: The machinery directive guidance document first edition is 337 pages long and will be revised in spring 2010 and again in December 2010 and this is likely to produce a document of over 400 pages and that in itself highlights the size of the task ahead for the industry. Over 600 CEN standards have been modified to accommodate the changes and offer an aid to compliance.
Action required by the next Government: The biggest challenge is to ensure that the industry follows the new requirements and to provide it with supporting documentation and guidance in the wake of policing and authority mandates and in cohesion with the 27 EU member states. This is a huge undertaking and needs to be recognised fully by Government.
9. ATV – A tractor or a motorcycle? The issue at present is that the definitions show the ATV to be a machine and covered by the Machinery Directive when off-road. Complications arise with the UK DfT/BIS interpretation and the EU Commission not deciding whether on-road ATV vehicles should be placed in either the Motorcycle Directive or the Tractor Directives for type approval (2002/24/ EC and 2003/37/EC).
A new category in the Tractor Directive is favoured by the UK authority. The choice of the appropriate licensing class and the introduction of new safety standards will add to the continuing confusion.
The AEA is in discussion with the DfT and BIS on a new category of definition for ATV vehicles but an early resolution of drafting problems is not expected. The side by side vehicles (seating for a passenger adjacent to the driver) may also be subjected to a type approval process and resource to progress this issue is required from within the industry with assistance from the UK participants.
Similar category problems occur with telescopic handler machines with ambiguities resulting from the application of conflicting Directives and Regulations.
Action required by the next Government: There is an urgent need to resolve the category of definition for both ATVs and side by side vehicles.
There is also a need to clarify the road licensing position for these vehicles and for a further clarification of the permissible use within concessionary agricultural classifications.
10. Excessive legislation: The Association endorses the new approach to policy making and regulation based upon a thorough impact assessment, consistency of policy objectives, cost-effectiveness, through consultations with industry and with an understanding of the need for adequate lead-times before new regulations become effective and with account being taken of the affordability of the regulatory demands.
Actions taken by the industry: The Association’s CEO is a member of the government’s Better Regulation Task Force.
Action required by the next Government: There is a need to ensure that there is better regulation not more regulation!
Roger Lane-Nott
Chief Executive Officer
Agricultural Engineers Association