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COMPLEX RULES OBSTRUCT PRODUCTION

by
01 August 2011, at 1:00am

RICHARD GARD takes a look at what DEFRA is doing with ‘remote sensing’, the work of the Farming Regulation Task Force, and why there is a high level of noncompliance

IT appears that bonuses for those responsible for the operation of the Single Payment Scheme are to be blocked by the Government. 

Few people in the countryside have any direct contact with agents or officers but the letterbox offers considerable weight of information and notification. 

For example: “We recently carried out a remote sensing inspection of your farm to confirm the details on your SPS 2011 application. This is an important check that uses satellite imagery to confirm the boundary, area and land use of parcels you included on your application. I am writing to tell you what we found, and to ask you for more information to help us process your claim accurately. It is important that you send us the information we need quickly as we will use it when we calculate your SPS 2011 payment.” 

And: “I enclose the following documents. I appreciate these contain a great deal of information, but hope they will help you understand the position: Annex A, Annex B, Annex C, Statement of remote sensing findings, List of ineligible features.” 

For each of the “parcels”, the Maximum Area Eligible for SPS has been calculated by deducting the total area of all the permanent ineligible features from the Total Field Size. 

Eleven decimal places 

The letter continues: “For the purposes of this calculation, we first calculated each individual permanent ineligible feature area to 11 decimal places, added the individual areas up and then rounded the total to 2 decimal places. However, for convenience, we have rounded the individual figures to 4 decimal places in this list rather than show them to the full 11 decimal places.” 

A highly colourful satellite photograph with red fields and blue buildings shows a field under dispute with an added yellow border and an ineligible feature, calculated at 0.0134 hectares. This works out at something of the order of £1.75 of possible payment dispute. 

Of course the correct payment should be applied and if you add up all the £1.75s on all the farms for all the years, it will come to a considerable sum, but how many years of reclaim will it take to recover the cost of the remote sensing and supporting mailings?  

At EU level, change, as always, is in the air with an intention to make “30% of the future payments dependent on green activities including ‘permanent pasture, crop rotation, fallow or carbon mitigation’.” If this means more forms, more literature and more remote sensing, then please make it somewhat more cost effective. 

The Farming Regulation Task Force report has recommended that the people who farm the land should be the beneficiary of the Single Payment Scheme, which may not be the landowner. It is perhaps worth considering which of the clients of a veterinary practice own and farm the land and the effect that this proposed change would have on livestock management. 

Originally, it was said that the old Single Farm Payment should not form part of the income of the farm but it is clear that many stockowners are dependent on the payments for survival. 

Veterinary surgeons may also have views on the proposals for identification and movement control. The report identifies that the present arrangements, including the six-day movement restriction, are intended to minimise disease spread. 

The current rules are criticised as complex and obstructive to livestock production, with relatively high levels of non-compliance. A new system is proposed that balances the relative risk of disease spread and the need of businesses for a simpler system that takes account of the seasonal nature of livestock production. 

Key elements 

The key elements of this new approach should comprise: rapid adoption of electronic reporting of animal movements; introduction of a single, distance limited County Parish Holding designation (replacing Sole Occupancy Authorities and Cattle Tracing Scheme Links) that will allow farm to farm movement of animals without record keeping; and free movement of animals between individual farms without triggering a six-day standstill. 

Approved separation facilities within a CPH to hold bought-in animals without a standstill on the rest of the holding should also be allowed, thereby allowing producers to make maximum use of limited market opportunities. 

Meat hygiene controls are given within the report as an example of burdensome official inspection. It is proposed that consistently competent meat processors should be able to source meat inspection services from accredited private sector providers within a system managed by the competent authority. 

The longer term goal of a risk-based system requires change to EU rules; the Government should take the lead in piloting innovative inspection processes and making recommendations to the European Commission. 

In the short term, changes that do not require changes to EU rules should be introduced, including the greater use of “cold inspection” in small processors with appropriate facilities. 

The Government should make maximum use of derogations in EU law controlling TSEs and support proportionate, risk-based changes, including the TSE roadmap, to these rules and implement changes without delay once they are agreed. 

Detailed recommendations 

There are some detailed recommendations of interest including:

  • immediate adoption of a single database, commercially and privately operated, to record sheep movements to ultimately replace entirely and make redundant the Animal Movement Licensing System (AMLS); 
  • early adoption of automatic pig movement recording; 
  • an end to paper-based reporting of cattle movements; 
  • consideration in the longer term to developing a single private sector database for all species; 
  • electronic data entry and recording should be immediate; 
  • where alternative reporting systems are provided, movements must be reported within 72 hours; 
  • maximum use of the Central Point Recording Centre (CPRC). 

A total of 215 recommendations are within the report and copies are available to download from the defra.gov.uk website. The Environment, Food and Rural Affairs Committee has decided to take evidence but there was a brief window of opportunity to respond between publication of the report on 17th May and submissions closing on 10th June. 

The Committee will consider in particular: whether it is desirable for DEFRA to change its culture of regulation in the manner suggested by the report; how this cultural shift could be implemented, particularly focusing on strengthened partnership with the farming and food processing industries and more proactive engagement with EU institutions; how a system of “earned recognition” for regulation and inspection recommended by the Task Force would work in practice. 

It is thought that some veterinary practices may have joined the Rural and Farming Network being set up by DEFRA. Some 20 or so of these groups are envisaged to be a source of contact and to give advice directly to the Government on farming, food and rural issues to help inform policies that affect rural people and the food and farming industry. 

The groups will provide a direct line of communication, keeping DEFRA’s ministers in touch with issues, concerns and good practice to be found in rural and farming communities around the country. It is indicated that support would be available for gatherings and discussions. 

One of the great advantages of veterinary work would appear to be that visits and contacts are made to a considerable breadth of clients and at every conference strong opinions are expressed about politics and control. 

At a local level, Networks might appeal to those who have little interest in travelling to London for committee work.

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