Examination of Witnesses (Questions 220
WEDNESDAY 7 MARCH 2001
220. We are good at contributing to future policy
but no one is an admirer of our current systems, or perhaps we
are not very good advocates of our current systems because no
one has as yet taken on any of our processes voluntarily?
(Mrs Purnell) In discussing our forms with Irish officials
they have said that they like the way in our guidance we have
a check-list of the things not to forget, reminders. That is a
fairly minor example but they have said they think that is a good
(Mr Duncan) Some Member States have taken advantage
of the issue I discussed earlier about using cadastral measurements
and field references as part of IACS. Certainly on the livestock
side we have been instrumental in trying to develop this centralised
approach to controls for livestock and we were at the forefront
with the Commission on that one. Certainly that is of interest
to other Member States.
221. Is that the cattle passport?
(Mr Duncan) No, it is the physical controls for animals.
Instead of going out for the Special Premium Scheme and out for
the Suckler Cow and out for checking cattle passports, we can
combine the inspections. That is something that was promoted strongly
by the United Kingdom.
(Mrs Purnell) This is called CoBRA. You may have seen
reference to CoBRA in the papers, particularly the one you have
had from me.
(Mr Duncan) I think there have been successes. IACS
is an over-arching control Regulation and when you talk about
the other scheme Regulations there have been issues there pushed
by the United Kingdom and accepted by others.
222. I have one point on the devolution issue.
I represent a Welsh constituency, Montgomeryshire, and I have
had a number of complaints from farmers who feel they do get treated
as second-class citizens within the United Kingdom itself because
it takes longer for them to get their payments, for example on
Suckler Cow Premiums. Do you have any experience of that kind
(Mr Duncan) Are we talking about cases which are cross-border
223. No, they are Welsh, they are not complex
in the sense that they cross the border.
(Mrs Purnell) Obviously since we do have four systems
there will be different rates of progress in making payments.
I know that the National Assembly for Wales is, as we are, going
to re-engineer its computer systems. I think we are all hoping
that this will make it easier for us to pay farmers quickly because,
as I said, with the trial of the electronic IACS form they all
went through central validation immediately and that means that
they can thereafter be fully validated. You cannot start paying
them straightaway because there are these strict payment windows,
but our hope is if we can persuade the industry to go down the
electronic route that more and more claims will be stacked up
ready for payment so that once the window opens October 16th we
will be able to say, "Pay them", and then there will
only be cases where there is probate or some of these issues which
we cannot resolve where we will have to hold back payment. As
I think we have said, we see IT as the key in all this.
224. So the good farmers of Wales are assured
that you are making sure that they will no longer have any reason
to feel that their payments are being delayed?
(Mrs Purnell) I think that is a point you would need
to take up with officials in the Assembly.
225. I shall do so. I want to ask some questions
about simplification. Comments that come from our opposite numbers
in Northern Ireland as well as from MAFF make it pretty clear
that you are keen to be at the forefront of simplification. What
are the key actions that you are taking to make sure that that
does come about? I know you have already touched on this earlier
on but if you could be more explicit.
(Mrs Purnell) I think perhaps some of it resulted
from our experience at the end of 1999 when we were trying to
agree the implementing rules for Agenda 2000, which I think everybody
was very dissatisfied with, and also particularly for me because
at the same time I was acting as Secretary to Don Curry's Red
Tape Review Group. COBRA, the Combined Bovine Risk Analysis inspection
system, was one of the results of that, but the drivers were what
came out of Agenda 2000 and also from the Red Tape Group. We did
decide that that was a major policy interest, that we did want
simplification, and from that the rest in a sense has followed
in that we had extensive contacts with the French back in June,
we agreed priority lists of simplification areas, they were then
taken round to other Member States by the French Presidency, and
we got this commitment in October that this would all be pursued,
and tomorrow is the first meeting. The field margins was the first
problem we got sorted out, then there was something on set aside
strips alongside water courses, which was a minor change but a
welcome one, and we would like to go further on that one, and
on the cattle schemes we will be pursuing our discussions tomorrow.
When I went out to Westport to give that presentation the point
of that was a bit of evangelism to try and get support from others
and from the Commission and I was able to follow up that presentation
with a fairly long discussion with Mr Slade. So, yes, I think
we have tried to take this forward.
226. How successful have you been with your
evangelical work in regard to other nations?
(Mrs Purnell) I think it is now accepted by alland
we had a first meeting of a group on more general simplification
back in Decemberand I think there is no dissent from this.
All Member States want to see simplification. They have all got
their own particular points. There is a general agreement that
the cattle schemes need straightening out. On the field margins
it was really a United Kingdom problem though we got a fair amount
of sympathy from other Member States. So I think in some cases
it is the Commission that is a little wary that we are trying
to push them a little bit too far too fast.
227. Not for the first time. You mentioned some
specific areas. What would you say are the key priority areas
for the United Kingdom?
(Mrs Purnell) I think it is this work on the bovine
schemes, because this is where the huge new burden arises, both
for us as administrators and for the farmers. There are other
areas: we would like to see a revision of the penalty regime in
line with the recommendations of the Don Curry group, which would
be raising the penalty threshold from three per cent to five per
cent for area claims. We would also like to see perhaps some sort
of time limit as to how far you could go back in applying penalties
when you find at inspection that there are errors in a claim which
have obviously been around for a number of years. But I have to
say that the Commission is far less forthcoming when it comes
to a commitment to simplify and ease the penalty regime. I think
you had a taste of that last week.
228. What sort of timescale are we talking about?
There has been mention from the French government about doing
this rapidly, and the implication is that you do have a timetable
(Mrs Purnell) Yes. The first experts' group is tomorrow.
I shall be looking at the papers later today. A first idea of
how they are thinking is emerging on revising the basic Regulation
3887/1992. The plan, I think, is to have two or three more groups
this year, with the idea of agreeing changes so that they can
come into effect on 1 January next year.
229. Are you satisfied with the proposals for
the individual schemes? What else do you think could be done to
make them even more farmer-friendly?
(Mrs Purnell) The actual schemes are not the responsibility
of the IACS team, in a sense, because policy responsibility for
the cattle schemes would lie with our Beef and Sheep Division
colleagues, and for the arable schemes with our Arable Crops colleagues.
We would in fact work with them.
230. Is the Small Farmers' Scheme part of your
(Mrs Purnell) Partly. The Small Farmers' Scheme raises
some quite serious questions about the future direction, because
you are talking about switching the direction of CAP support,
modulation, degressivity, switching support progressively to the
second pillar. The Small Farmers' Scheme, which takes smaller
claimants out of IACS, has to be considered in that context, and
to that extent the policy issues go wider than my Division. But
clearly, if you are going to be taking these farmers out of IACS,
you have to freeze their land, you have to freeze their quota,
you have to make sure that nobody who is in IACS is borrowing
sheep from someone in the Small Farmers' Schemethere are
all sorts of quite difficult control issues that come out of that,
and to that extent we are involved in looking at it. It is also
the case that it is a scheme which will affect other Member States
in very different ways from us. No decision has been taken as
to whether it should be implemented in the UK. It is currently
subject to consultation with the industry, but I think it is generally
recognised that we would have comparatively few farmers who would
be eligible for that scheme, so it is going to be of lesser interest
231. The threshold proposed is 1,000 euros.
Do you think that threshold could be made higher given the UK's
circumstances in regard to small farmers?
(Mrs Purnell) Obviously, there is a lot of pressure,
as Mr Slade told you last week, for that threshold to be reached.
I think our view at the moment is that this is a pilot scheme;
it will be voluntary both for Member States and for farmers. 1,000
euros is probably about right in terms of a pilot scheme like
that, but that is not to say that this threshold will not change
as part of the negotiations.
232. A wonderfully diplomatic answer. My last
question is slightly more blue-skying. It seems to me that many
of these changes are, quite understandably, an evolution from
where we are now. Has any work been done to set aside the natural
progressions and say, "If we were to totally re-design the
system, what would it look like?"
(Mrs Purnell) There is certainly thinking of that
kind going on as to what the future direction of the CAP could
be and what sort of policy changes we would want to see. I am
not closely involved with that. Our role is much more "minding
the shop", or looking after the system we have at the moment,
but yes, there is thinking of this kind going on.
233. On a point of clarification, you were talking
about changes to bovine-based schemes and livestock schemes. Mr
Slade told us "In the Bovine Premium Scheme we are aiming
for a paperless system with no claim form." Are we?
(Mrs Purnell) Yes, absolutely.
234. Over what timescale?
(Mrs Purnell) That will depend. As you know, there
was the Cattle Herd Registration exercise last year, and it is
now compulsory for farmers to notify all their cattle to the Cattle
Tracing System. At that point the Commission, both on the veterinary
side and on the subsidy sideMr Slade or one of his staffwill
come across and look at our systemthat will happen some
time this yearand give a view as to whether they think
it is fully operational. In terms of the subsidies, I think they
want the reassurance of it running with a comparatively low error
rate for about a year before they would be happy about saying
we could run our subsidy schemes off it. So if we are talking
about an initial view from the Commission some time this year,
and then a year of running-in, that would take us to next year.
So I think we would not be able to do it before 2003.
235. Mr Todd in his questioning drew your attention
to something which it was obvious you were aware of, which is
the relative simplicity of the Irish form, and you gave us a commentary
to explain why you thought the Irish could get away with two sides
of A4 and we have a telephone directory! Going back to Mr Slade,
I thought it was quite interesting when he commented on a question
that was asked about our forms. He said, "They are among
the more complex and among the more complete forms that are used
in Europe, but they are not necessarily the most complex."
I was interested that he said they were the most complete forms.
Going back to the first question, this translation process, the
regulations lay down the minimum requirements, and often the accusation
is that we addthe term "gold plating" has been
used. Would you like to say whether you think that some of the
extra pieces of information that may be required from a UK perspective
are really necessary? Perhaps you would challenge whether you
do go beyond the EU minimum, but the perception amongst farmers
is that you are mining a vast amount of extra information for
no apparent reason. Would you like to comment on that?
(Mr Duncan) I do not believe there is very much in
the way of gold-plating in our form at all. The first point I
would like to make is that the Area Aid application serves two
purposes. First of all, it serves an IACS purpose in terms of
populating the database so that appropriate checks can be done,
as required by the regulation. Secondly, it provides a claim form
for the Arable Area Payment Scheme. If you were to have time to
look over the large number of regulations there are on that particular
scheme, you would find that each of our questions relates to one
of the scheme rules, so that we can validate everything at one
go. Perhaps farmers do not fully appreciate what we are trying
to do. This causes the form to be quite large. The arable sector
in the UK is complex. It makes full use of all the different crop
types. The protein crops and the oilseed crops have until now
been quite complex in their information requirements. The set-aside
arrangements are diverse. I am not au fait with all the arable
rules, but some simplification has taken place. We are taking
a vast amount of data at one sweep so that we can pay Arable Area
Payments, and a fairly large amount so that we can store forage
data in the UK so that we can then transmit it to the other schemes.
I believe that is perhaps why Commission officials felt they were
complete, in as much as they go that far. They have also provided
information to interface with the old, Less Favoured Area Directive
as well, which was something else that we decided to capture at
that particular point. So it might be that by capturing that amount
of data then, we have had to capture less data at other times.
236. Do you ever sit down and go back through
the forms as they exist and review each piece of information which
you require and say, "Do we actually need this?"
(Mr Duncan) Yes. We do that every year. Once a year
we have to revise the whole process and prepare a form for the
next Area Aid application. At that review we take account of whether
we need it all, and also changes in regulations that have been
applied in the meantime through the European Union. So there is
an annual review. I would accept, of course, that the current
system is designed with our current databases in mind. One of
the things we have done over the last couple of years is to process-map
the whole requirement again in preparation for moving to different
types of computer systems. So that might in fact help us in our
attempts to simplify the forms at the next review, for example.
237. Do you look for opportunities where there
are certain pieces of common information that refer to different
schemessay somebody has a mixed farmso that instead
of having to fill in all the basic parameters three or four times
over, you try to integrate that?
(Mr Duncan) Yes.
238. Our system enables us to do that?
(Mr Duncan) The system enables us currently to save
all that sort of information and transfer it in different directions.
239. Let me ask about the costs to farmers.
The Farmers' Union of Wales in their submission to the Committee
told us that they reckon that it costs farmers on average £2,700
a year to fill in the various forms. It has always been put to
me that where money is concerned, farmers are very happy to fill
in forms, but have you undertaken any kind of assessment of the
real cost to farming enterprise of this bureaucratic exercise?
(Mrs Purnell) We have not in recent years. There was
an efficiency scrutiny of farmers' paperwork back in 1995-96 which
did look at that. As part of the Don Curry review we did not try
and do that.