Memorandum submitted by the Royal Institution
of Chartered Surveyors (H 4)
We are grateful for the invitation to submit
evidence to the forthcoming Inquiry into the Implementation of
the Integrated Administration and Control System.
The Royal Institution of Chartered Surveyors
has approximately 4,000 qualified Members who are Rural Practitioners
and are significantly involved in dealing with the practical implementation
of the IACS on behalf of their clients.
Accordingly, we would wish to highlight a number
1. We are concerned at the lack of availability
of IACS information to agents, prospective purchasers, potential
occupiers or landlords of holdings. We have received examples
where such third parties, with a genuine interest in the particular
holding, have been refused reasonable access to relevant non-sensitive
information, eg field number data, and which fields have been
registered as Arable and/or Forage areas.
We feel that there should be mechanisms put
in place whereby reasonable requests for non-confidential information
should be facilitated by the local MAFF Regional Service Centre.
2. We are also concerned at the proliferation
of bureaucracy involved with the different schemes administered
under the IACS; there should be increasing opportunities for greater
cross-referencing and integration of the schemes and, whilst we
appreciate that this is occurring to a certain degree, further
improvements would be welcomed.
A great deal of agents' and farmers' time is
taken up in dealing with the administration of the various schemes
under IACS; we would recommend that the forms and accompanying
guidance are reviewed in order to make them more "user-friendly"
and a less onerous task when making returns.
3. Given that important changes are being
made to the IACS regulations governing certain schemes, there
is often an insufficient period of notice bearing in mind the
complexities of the regulations.
4. One example with which the RICS has been
closely involved, including lengthy discussions with the Ministry
of Agriculture, Fisheries and Food, has been the recent concerns
relating to field margins and cropped areas for both forage and
arable area declarations.
Having requested finalised details of the revised
regulations on a number of occasions (in order to establish the
current position so that our members can properly advise their
clients), we are concerned at the length of time which this matter
has taken to be resolved.
5. The change to the rules for holders of
sheep quota has caused a number of difficulties.
We would want to see better arrangements put
into place for explaining changes to the various schemes in a
thorough and timely manner.
6. The penalties for simple errors and poor
administration (as opposed to deliberate non-compliance) are considered
too draconian. There appears to be no attempt to apply the principle
of proportionality in withholding subsidy payments or confiscating
quota from producers who have unwittingly made an error in submitting
7. We consider that some form of ombudsman
scheme to deal with infringements would assist in resolving disputes
which all too often consume considerable amounts of both the producer's
and the Ministry's time and money.
8. There would appear to be a much greater
opportunity for overlap and/or further integration with agri-environmental
schemes where there appears to be considerable duplication of
information provided that could otherwise be obtained from the
ESAs are an example, as is the MAFF Annual Agricultural
Census, whereby a significant amount of information has already
been submitted to MAFF, which would negate any duplication of
effort on the part of those involved with completing IACS paperwork.
Please do not hesitate to contact me should
you have any further queries or require further amplification
of any of the above points.
24 October 2000