Why do the Department’s BPS and Greening T&Cs need 79 pages?

The ‘complexity’ of the Department of Agriculture, Food and the Marine’s explanatory document for the BPS and Greening scheme has been criticised by the ICMSA.

The 79-page document has been circulated to over 130,000 farmers in recent weeks, according to the Deputy President of the Irish Creamery Milk Suppliers Association Pat McCormack.

This document, which outlines the terms and conditions of the BPS and Greening scheme, shows conclusively the ‘bewildering complexity‘ that is the current regime for farmers, he added.

The ongoing simplification agenda being pursued by the European Commissioner for Agriculture and Rural Development, Phil Hogan, must address this matter, he said.

“For many farmers, the BPS/Greening payment represents 100% of their annual income and delays or penalties have a very serious impact on their livelihood, with some individuals still awaiting payment of their 2017 entitlement.

The very fact that it takes the Department 79 pages to set out the T&Cs, around the legal aspects of the regime, is proof-positive that the bureaucracy around this system is simply way over-the-top and hopelessly impractical.

“We accept the need for regulation and oversight, but it is quite clear that there are way too many conditions attached to this payment; there are specific problems recurring and causing problems year-after-year.

“The simplification agenda being implemented at EU level must focus on resolving these recurring problems,” McCormack said.

In a recent meeting with Commissioner Hogan, the ICMSA put forward a number of proposals in relation to land eligibility, administrative penalties and tolerances, he added.

The ICMSA hopes that these proposals would simplify the regime for farmers, reduce unnecessary penalties and speed up payments.

For example, the exclusion of farm roadways from eligible land makes no sense; roadways are an essential part of good farming practice and they should be regarded as necessary farm infrastructure and thus be eligible for payment.

“If these obvious and logical changes were accepted and introduced then the whole regime would become much more understandable, in a way that would have to result in a speedier processing of payments,” he said.

System Reform

The ICMSA has noted that the administrative penalties associated with the Nitrate regulations account for over 40% of the total Cross Compliance penalties, McCormack added.

“In the same way as we see the BPS/Greening T&Cs, the ICMSA believes that this regime can be reformed in a way that reduces the penalties while meeting fully the requirements of the regulations,” he said.

The ICMSA Deputy President also noted that Commissioner Hogan was told that farmers welcomed his simplification agenda.

However, he was also told that farmers need to see and experience tangible benefits from this drive, he said.

The first target of the simplification agenda must be those recurring problems that year-after-year cause such frustration and delays, McCormack said.