Memorandum by W H Locker
I will confine my remarks to the SFP, others
will have better opinions on the rest.
The reforms of 2003 have resulted in more regulation
and inspections than when the livestock schedules were in operation.
That SFP was sold to our industry on the basis
that; provided the environment was not spoiled, farmers could
get on, farm and produce what the market wanted.
That was a deception.
Sheep market has collapsed. Flocks are being
dispersed. Milk is a disaster and the Auctioneers have waiting
lists, months long, to dispose of dairy herds. Locally the numbers
of suckler cows and beef stores are just not there. Traditional
sales of +1,000 are down to 300 and some sales are cancelled because
of the lack of trade. Unless this decline is reversed the nation's
food supply will be seriously diminished.
What concerns the industry most is that the
staff (DEFRA/SEERAD) previously employed to administer the schemes
have all been retained and now duplicate the inspections of Env
Agency Trading Standards heritage: BDMS, Farm Assurance etc .
. . etc . . . all in the name of cross compliance. A volume has
been produced—complete with penalties. They now inspect
everything in sight and impose penalties. For example, the borders
were blitzed recently. Teams from SEERAD inspected for days at
a time. Passports/ear tags/records. Another team are counting
sheep against records. Substantial numbers of farmers lost 1%
SFP for minute paper errors or the odd tag that had come out.
That achieved nothing to assist agriculture
or food production or for the environment. There is a report in
the Press one man spent four weeks measuring up strips around
arable fields on one farm and measured the wave of the plough
to justify a penalty. Near here 1% deduction; he had a water trough
6' x 3' between two arable fields, when his map showed a straight
line.
That duplication is needlessly costing the public
purse and achieving nothing except artificially retaining civil
service jobs.
Once those penalties are imposed (by junior
staff) there is no way you can successfully appeal. SEERAD run
the appeals, at every stage—including the selection of those
"independents"—who, if they found in favour of
a farmer, would not be selected again. So much for an independent
system!
That body still has not arranged independent
appeals for over 2,000 farmers in respect of their SFP and that
is four years on.
To improve the situation is not difficult but
vital in terms of feeding the nation. The Press records at great
length RPA failures.
Having gone for a complicated system is grand
for staff retention, but hopeless for delivering (reports that
3 x payments are being made to staff to do the job they were engaged
to do).
It makes no sense to consult those who set it
up in the first place and who clearly cannot deliver.
1. Simplify the whole system—one single
payment per acre based on deeds or IACS maps 2003 and paid only
where the land is owner-occupied or bone fide tenanted, but FARMED.
Special provision will be necessary to protect the hill farming
and the environmental contribution they provide for the upland
landscape.
That cuts out all the previous "arrangements"'
which in the past produced subsidy payments. It cuts the bureaucracy
and produces massive savings to the taxpayer (it costs something
like £6.50 to administer £2.70 SFP).
2. The "Env Schemes" are few, difficult
to access and achieve little. There is a high DEFRA/SEERAD staff
involvement on top of Nat Heritage staff.
Farmers always have provided the landscape loved
by the public. That will continue just as soon as there is an
upturn in income without the bureaucracy.
3. The Assurance Schemes take care of animal
welfare issues and do not need RPA involvement.
4. The RPA will continue for some time. A
core will be meaningfully engaged. However, those who have presided
and arranged the present discredited system need to be held to
account. The public would expect them to be treated in exactly
the same way as those who fail in the workplace. It sends out
the wrong signal to treat those who failed to deliver.
5. Disputes will arise. The present appeals
system run by the civil service and controlled by them at every
stage has failed. It encourages needless penalties which those
penalized cannot address. It cannot be within the British Constitution
that those imposing penalties also sit in judgement.
A single completely independent scheme must be
available to both sides or all matters should got to a Court—it
cannot be more costly.
Yours committee has a great responsibility for
the future of farming, our nation's food and the environment.
Its duty is to ensure the public has value for its taxes.
All we in the field can do is point out the
issues.
I will look forward to your report in the Press.
June 2007
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