APPENDIX
Memorandum of personal experiences of
the RPA Implementation of the Single Payment Scheme by John Peter
Michael Scawen, Earl of Lytton BSc FRICS
22. My experiences are related to two holdings
No 36/110/0054 in West Somerset District and another 42/083/0152
in Horsham District, West Sussex. The former is described hereafter
as the Somerset property and the latter, the Sussex property.
23. The Somerset property is an upland (SLFA)
livestock farm and shooting estate totalling some 360Ha and has
been the subject of an IACS return for as long as that system
has been going. I have always completed the IACS return myself
and therefore have become familiar with the system. Over the years
we had simplified a number of the parcel areas for purposes of
the IACS return because the precise positions of land use for
forage crops and game cover crops would vary year on year whilst
the total forage area would vary less dramatically. In order to
simplify matters, parcels were often quite large blocks of land
so that the precise subdivision within the block for forage, grassland
and non-palatable game cover crops (these latter were always excluded
from the claim area) could be dealt with whilst avoiding the need
for re-measuring and agreeing annually year on year changes in
the disposition of land uses. We had even got as far as having
a visit from the Surveyor from the Rural Payments Agency in Exeter
who met with me on site (spring 2003 as I recall) to check the
acreages included in the claim and which were found to be within
normal allowable limits. Beyond confirming those acreages, no
other action by the RPA had ensued.
24. The Sussex property which is a lowland
grassland and woodland holding, was never for or included in an
IACS claim. As the grassland was of value as much for its amenity
as for its grazing and totalled some 17Ha, this was of no great
consequence.
25. My first encounter with the new Single
Payments Scheme was in respect of the Somerset property and in
particular the supply by RPA of new digital maps of the holding
as part of the Rural Data Capture exercise leading up to the compilation
of the Rural Land Register. The first two sets of maps supplied
during the latter part of 2004, were substantially incorrect.
Some of the parcel boundary lines seemed to follow sheep tracks
and there were material inaccuracies. I replied, sending a map
of my own but the new system appeared to have no regard to the
way in which the land had previously been mapped by Ordnance Survey,
to the facts on the ground or to the maps submitted from time
to time in support of IACS claims. It appeared that all the systems
built up over many years of IACS would count for nothing. Eventually
I received a set of plans that was more or less correct except
that it omitted one or more significant parcels in the middle
of the holding and when I made representations about this, I was
told to fill in an IACS 22 form for the allocation of a field
number for the missing area, notwithstanding the missing land
was already IACS registered. Eventually I did receive a substantially
correct set (but see below for the sequel).
26. With regard to the Sussex property,
I applied on form IACS 22, for the issue of new parcel numbers
for a previously unregistered holding. When I had heard nothing
by the early part of 2005, I made an enquiry and was sent without
any other comment, a further form IACS 22. Rather than complete
a new form, I photocopied the old one and sent it back complete
with its accompanying maps.
27. I took the view, however, that with
the growing rumours about the disarray at the RPA, such maps as
I had received on the Somerset property were probably going to
be as good as it would get. I was CLA Sussex Committee Chairman
at the time and was therefore following fairly closely the efforts
by the CLA to obtain additional information on behalf of members
submitted.
28. All the while, I was receiving a plethora
of documents relating to the implementation of the Single Payments
Scheme and advice on what farmers had to do. Some of these were
re-issued with further amendments after a gap of only a few weeks
and it all became very confusing. From the standpoint of the Somerset
property which is also run as a sporting estate, I became increasingly
concerned about the status of game cover crops and what was or
was not qualifying land when used for this purpose. Although I
had all the records going back for a long time under IACS but
it was quite difficult to make the connection between the parcels
shown under the RPA's new digital maps and the divisions of the
farm used for the purposes of the previous IACS claims. In a number
of significant areas, the two simply didn't match. At one stage
I tried to see if someone would meet with me to discuss the ongoing
errors being generated in the RLR mapping exercise but was told
that the consultants did not come to site.
29. In the weeks immediately preceding the
16 May 2005 deadline, I contacted the help-line (Newcastle on
Tyne) in order to try and get clarification about the treatment
of cover crops and whether this would trigger a requirement for
set-aside. I freely admit that I had not anticipated that there
would be a requirement to meet a set-aside requirement on a hill
farm used for extensive livestock raising with game cover crops
having a dual use as fodder crops for winter feed. Suffice to
say that the help-line was unable to clarify the position and
the gentleman I spoke to did not know what a game cover crop was;
he thought it might be a catch crop. My follow up email confirming
the query was not answered. Certainly it would have been very
difficult to have found land on which to provide set aside, even
given the small amount of set aside land that would actually have
been needed. Indeed, the set aside arrangements would have had
to have been put in place some months earlier, well before I had
come to the realisation that there was a set-aside issue at all.
30. During the early part of May 2005 I
received a round-robin letter from the Chief Executive of the
Rural Payments Agency effectively saying that all the information
had been provided by the RPA and that it was up to farmers and
land managers to make use of all the information provided. As
this was manifestly untrue, I wrote to say that inadequate information
had been available and that I was still waiting for information
which had so far not been provided. This produced a telephone
call from somebody in the Chief Executive's office which happened
when I was out; I returned the call and left a voicemail message
but did not thereafter receive any further communication.
31. I concluded that there was too little
information available and too much uncertainty about the whole
system and in the event, did not submit a Single Payment Scheme
application form in respect of either property. This decision
was not taken lightly; there were probably £12-15,000 of
historically-based payments at stake for the 2005 year alone.
32. In August 2005, a further set of maps
in connection with the Somerset property was sent to me. These
were fundamentally wrong and incorporated errors not seen in previous
versions of the maps (in fact each successive set of maps had
errors that were not in the previous set and this was a recurring
theme). I wrote in response to this latest set of maps in early
September to say that they were wrong, that I was not prepared
to devote any more time and energy to the matter and that as far
as I was concerned, correspondence with the RPA over this matter
would cease with immediate effect.
33. I have just received (today, 8 December
2005) for the first time, some maps of the Sussex property. They
are substantially incorrect and miss out large parts of the grazing
land. They are not in accordance with the details or plans previously
provided. I am in the process of writing a letter pointing out
the delays and inefficiencies and that the entire SPS is, so far
as I can ascertain, a waste of time.
34. That is where matters now rest.
35. My opinion is that the whole exercise
has been incompetently organised; there were too many things going
on at one time with the digitisation of the OS maps, the creation
of the Rural Land Register, the mismatch between the body of established
mapping data from the IACS system and the new RLR requirements.
Coupled with a new SPS regime administered by inadequately trained
staff (whether in the consultancy office or the RPA itself, I
do not know) and an inability to answer queries, the process became
a nightmare. A guidance video issued by DEFRA in about April 2005
made no attempt to demystify the whole process. The published
and printed guidance made no attempt to identify changes from
earlier versions and in the end it seemed one had to cross refer
to several different documents at once to get a cohesive picture
of the requirements and even then there were inconsistencies and
a great lack of clarity.
36. Clearly DEFRA was in overall control
of this exercise and seems to have chosen the most complicated
and Byzantine approach possible. On a simple holding this should
have been straightforward but was not. On a complex holding it
has proved impossible to find a way through. I resorted to asking
my neighbouring farmers for advice and the CLA were inundated
with enquiries from members. All this occurred despite my many
years of experience with IACS and a professional knowledge of
mapping procedures.
John Lytton
December 2005
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