Select Committee on Agriculture Appendices to the Minutes of Evidence


Memorandum submitted by Stanyer Consulting Ltd (H 2)

  Further to your Press Notice No 38 dated 21 July 2000, please find below our comments on the implementation of IACS in the European Union. We believe there are four main problems as the IACS system currently stands:

    1.  The lack of an appeals process.

    2.  MAFF's inflexibility—ie the wasted time and expense in always having to judicially review decisions.

    3.  The lack of consultation on MAFF's behalf with the Commission in order to clarify the rules.

    4.  That rules are not communicated effectively enough to the participants in the Schemes.

  We also believe there is a need to review the EU rules governing the application of penalties—ie ensuring they do not breach the principle of proportionality.

  If you have any questions on the above please contact us at the Southern Office address below.

27 October 2000

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