Select Committee on Agriculture Appendices to the Minutes of Evidence


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 of points:

  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 their returns.

  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 IACS.

  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

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