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 inflexibilityie 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 penaltiesie 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