Memorandum submitted by Country Land &
Business Association (CLA) (RPA Sub 07)
1. We are delighted that the Efra Committee
are following up the horrendous problems at the RPA. We consider
Defra's decision not to review the failure of the RPA's administration
of the 2005 Single Farm Payment is completely unacceptable. A
thorough post mortem of this process is needed. However, we would
not in any way wish to see the examination delay the current processing.
2. Our advice is that the Committee should
accumulate the detailed questions and understanding of the magnitude
of the failure that we and other organisations can supply, but
that you delay putting those questions to the RPA until the bulk
of the payments have been made, which I suspect will not be until
the end of June or later.
3. Clearly we do not have access to the
sort of detailed information that your investigation will be seeking
from RPA. However, some of the issues and questions that we think
you should look at include the following:
A. It has been suggested by some groups that
the choice of a dynamic hybrid system is the root cause of all
the problems. We don't accept this. Certainly a number of other
EU countries have adopted equally complex systems—including
Denmark, Finland and Germany—and they have managed to make
almost all their payments by the end of last year. The problem
is not with the system, but with the implementation and management
of the system.
B. Choices made by Defra and the RPA made
a complex system far worse than it needed to be. Why, for example,
has the RPA been subjected to an ongoing "change programme"
while this complicated system was being implemented. Surely this
is a time when all resources should be focused on delivery of
the SPS. The "change programme" is all the more questionable
when Defra and the RPA are also introducing the new environmental
stewardship programmes, and a grand, all-encompassing new customer
register. In our view, it is clear that the RPA has been overloaded
and under-resourced.
C. Changes introduced by the new acting CEO,
Mark Addison, suggest the processes under his predecessor were
fundamentally flawed. Why, for example, were there six levels
of authorisation after level 2 validation had been completed?
Why was mapping—so fundamental to the new programmes—so
decentralised around the country? Why was a task-based system
used for processing claims, instead of a claims-based system?
The changes introduced by Mark Addison are very welcome and will
help to expedite processing, but, if their need was so obvious
to him within days of taking over, why were they not implemented
much sooner?
D. We would also ask about the degree of
DEFRA supervisory input into this whole project? What intensity
of scrutiny was put in by the most senior DEFRA officials, through
what processes? We can only observe that the senior official who
used to chair the Stakeholder group dropped out of that process
in spring 2005 leaving it to quite junior officials. Also what
did ministers ask and when? Certainly, the RPA consistently failed
to take seriously the comments of stakeholders, and rejected our
repeated warnings eg about the volume of mapping work in Autumn
of 2004, and the slowness of the processing in early summer and
autumn of 2005. This was a particularly frustrating experience
as, despite the paucity of information—and misleading information—that
the RPA provided us with. We have anticipated all the problems
faced by the RPA and warned them in good time. In every case we
were told that we didn't understand and that everything would
be alright. At each stakeholder meeting we asked for statistics,
were denied them, given obscure IT brush offs and were told repeatedly
that "everything was on track". It has appeared to us
that there was an absence of supervisory management processes.
The RPA could not, or would not, provide us with basic information
that should have been available including the numbers of claims
by type, the incidence of problems among the claims. The RPA consistently
seemed to have a poor appreciation of scale and make-up of problems
they faced.
E. We suggest you might probe more deeply
into Defra's role in all this. From the very beginning, Defra
have been exceptionally slow in reaching decisions. For example,
the seemingly simple matter of "who is a farmer" for
the purpose of entitlement transfers took months to resolve. DEFRA
as ever, took refuge by hiding behind the Commission and it took
us a large amount of time and continual badgering to get a letter
from the Commission which said that the problem was of DEFRA's
making and the solution we had been suggesting for months was
the correct one. Similarly, it was Defra that decided that six
weeks' advance notification were needed for transfers of land
and/or entitlements. This decision alone caused hundreds of anquished
letters, emails and telephone calls to be made, and hours of discussions,
and finally they reduced the period to three weeks. The decision
about the moorland line is another case in point. Defra have been
very slow in reaching policy decisions, which has meant that much
needed information was not available until the very last minute.
At the same time, the seniority of Defra's involvement in the
RPA stakeholder meetings has fallen precipitously. In short, from
everything we have seen, Defra appear on occasions to have been
more of a hindrance than a help for the RPA.
F. When we responded to your earlier inquiry
we made a number of suggestions about lines of questioning which
I am not sure you were able to follow up on. Specifically, can
you track down the dates of when RPA invited tenders for outsourcing
the help with mapping? We had been asking about this from Autumn
2004 onwards. It was plain to all stakeholders that a great deal
more land would have to be mapped than previously and we were
concerned they did not have the resources. We suspect that this
was not acknowledged until quite late in spring 2005. When did
the contract come into force? In similar vein, it appears to us
that the computer system at the heart of the SP5 processing was
never specified adequately for the task. Was the fault the initial
specification, or failure of the IT company to deliver to the
specification, or failure of the systems operation to use the
system correctly? We understand that the system simply could not
cope with the number of operators who required to be online simultaneously
and thus it continually crashed leaving operatives drumming their
fingers. It might be worth getting some expert IT witnesses to
give opinions on this.
G. Extremely poor communications and customer
relations have been a hallmark of the RPA over the past months.
Not only have they provided limited and misleading information
to stakeholders, but—more importantly—they have all
but abandoned their customers, the farmers. The frustration amongst
farmers at not knowing what is happening to their maps, their
claims, or their support payments is palpable, we could provide
sample letters and emails. Until very recently—after much
protest from stakeholders—their website was woefully un-informative
about decisions the RPA were making about the process. At the
critical point, when entitlement statements were first being sent
out, the call centre was actually shut for over two weeks. Even
now, with many farmers having been caught up in a Kafkaesque application
procedure—especially the mapping—for up to a year
in some cases, over half the claimants have no idea what is happening
to their claims or when they can expect to be paid, and thousands
were sent blank application forms which the explanatory letter
said were pre-populated. All summed up by one of our members as:
"unvalidated, unpopulated, unpaid and unhappy".
4. I hope that you find these remarks and
observations helpful to your enquiry. We would, of course, very
much like to have the opportunity to explain and expand on these
points in an oral examination.
April 2006
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