This Panel was given the task by the Minister for Agriculture and Rural Development (DARD) and the Minister for the Environment (DOE) of reviewing the regulations applying to the farm and wider agri-food sectors in Northern Ireland and have recommended simplification, measures to reduce the administrative burdens involved and identified areas where policy change was required.
UFU Deputy President Graham Furey said: "The UFU, through it's Cut It Out campaign, has helped achieve these positive results and we are delighted that an action plan has now been outlined by the Panel. We told the Panel that we have big expectations about this process; a 25% reduction in red tape must be achieved and it must be meaningful, reducing the paperwork which farmers have to deal with on a daily basis.
"We want farmers to 'feel the difference' created by this process. Reductions in paperwork need to be evident at farm level; it will not be acceptable for a 25% reduction in bureaucracy to be achieved by reducing internal administration in DARD or DOE.
"These recommendations are a positive start but we must now ensure that all action points are effectively implemented."
Some measures previously considered by a DEFRA study are already being implemented and decisions taken at European level such as dropping the 10 month rule in the Single Farm Payment Scheme and the abolition of set-aside have somewhat reduced administration.
However, the top ten most burdensome regulatory areas in the agriculture and food sectors still create an administrative imposition on the sector equivalent to about £51m annually. The Review Panel suggested measures and recommended structures to embed better regulation within the Departments which could see this burden reduced by about £10m -£15m in the period up to 2013. To achieve this challenging objective, the Panel recommends concentrating future work on the five most burdensome regulatory areas which collectively account for over 90% of the total burden.
Recommendations from the Panel are as follows:
Inspections
A number of measures are possible to reduce the real or perceived burden involved in on the spot inspections both for SFP eligibility and cross-compliance:
- Reducing the number of control agencies would reduce the risk of multiple inspections. This could be achieved by amalgamating the two control agencies within DARD and upskilling inspectors to perform multiple tasks. The downside is that a farmer who might be checked for only one cross-compliance elements under the present arrangements could find himself checked for a number of elements and so potentially be liable for greater sanctions. The Panel feel that the proposed new arrangements are better for farmers as a whole and for the administration.
- Where feasible, spot checks would be replaced by administrative controls and on-farm inspections reserved for cases where problems are identified or suspected.
- Greater use of remote sensing for eligibility checks should further reduce the number of on-farm inspections needed. By 2013 DARD should aim to ensure that 80% of these checks are carried out by remote sensing.
- Greater credit should be given to quality assurance and agri-environment scheme membership in the risk analysis to determine the farmers to be subject to on-farm inspections. Risk factors, evaluation criteria and weightings used to assess selection for SFP eligibility checks and cross-compliance inspection by both DARD and NIEA should be made public.
- Duplication of data assembly must be avoided. Animal identification and other information checked during the annual disease tests should not have to be checked again for cross-compliance purposes.
Use of Information Technology
The European Commission has estimated that better use of information technology could reduce the administrative burdens on farmers by €400m across the EU. The Panel made recommendations regarding the Single Farm Payment Scheme, Cattle and Sheep Identification, Registration and Movement systems as well as the potential for further developing on-line environmental permitting.
l Single Farm Payment Scheme
The Panel recommend that DARD should scrutinise every aspect of the application process with a view to reducing the average completion time by at least 60 minutes. The use of on-line applications would greatly assist this. The Panel believe there should be greater certainty about the timing of payments and recommends that SFPS applicants who have been subject to availability and cross-compliance checks and found to be trouble free, should be guaranteed payment in December. Where problems are detected, DARD should introduce a clear and time bonded process for the calculation and payment of the amount due.
Cattle and Sheep IRM
Regarding the existing system, the information required to be notified should be minimal i.e. there is no need to include animal colour in either birth or movement notifications. Subject to a positive evaluation of a pilot project, the possibility of telephone registration of births should be extended to all of NI. The introduction of electronic alternatives to all paper based movement management processes is also supported.
- DARD should seek to ensure that if electronic identification of cattle is introduced, it applies only after an appropriate phasing in period and is acceptable as an official means of identification for all statutory purposes. The Dept should also seek confirmation from the European Commission that the use of an APHIS based system is an acceptable substitute for an on-farm register and that all records required of farmers can be created and stored electronically.
- The Panel notes that electronic identification of sheep is a requirement from the end of this year. It is recommended that DARD consider introducing the derogations whereby the burden of recording individual animal identities on movement documents and flock registers is removed from the flock owner and substituted by a central database linked to markets and slaughterhouses equipped with EID scanning technology and the also the slaughter derogation exempting lambs to be slaughtered before 12 months from the EID and individual recording requirements.
l Disease Eradication Schemes
The minimum herd size threshold at which annual Tuberculosis and Brucellosis tests are routinely combined should be removed. The Panel recommended that an early review of the factors which led to ROI considering disease free status, with a view to adjusting arrangements in NI.
Meat Inspection
The Panel have been advised that the cost of the meat inspection service is excessive and could be reduced if those involved follow normal private sector work practices. If the system moves towards full cost recovery this could become significant in the future. The aim should be to ensure that a move to the full cost basis involves only a minimal increase in charges. Privatisation would help but is precluded by current EU legislation. Efforts should also be made to have the legislation suitably amended. In the meantime, it might be possible to have the auxiliary meat inspection duties undertaken by contract staff under the supervision of an official veterinarian.
l Environment Permitting
While recognising the relatively low burden associated with individual environmental regulations, the Panel believes that it is worth considering whether the introduction of simplified integrated environmental permits could reduce the cumulative burden of environmental regulations for the agri-food industry.
l Guidance Material
It is clear that much of the burden on farmers comes from the need to study and become familiar with the terms and conditions of the various schemes and regulations. The Panel recommends that all materials be reviewed and simplified. All guidance documents should be accompanied by a quick start summary and web pages should be reviewed regularly to ensure that they are up to date and provide information and guidance in an easily understandable format.
l Providing Advice
The Panel recommend that NIEA should consider more accessible solutions for providing advice. Appropriate measures could include the introduction of dedicated telephone helplines or perhaps a partnership with DARD that would allow NIEA to maintain an advisory presence in some or all of the DARD Direct Offices or other regional offices.
Structures
It is essential that adequate structural measures are in place to support better regulation objectives.
- While DARD and NIEA have Better Regulation Units, enhanced provision and a new unit within DOE Policy Division would effectively assist in ensuring that better regulation is embedded and actively supported in each Department.
- Officials should be required to report regularly on progress being made in achieving better regulation goals.
- Non-executive board members and stakeholders should play a significant role in monitoring that progress.
- A better resources unit in DETI should be an enhanced role in ensuring that the better regulation function is effectively fulfilled in each Dept and in auditing the activities in that regard.
- DARD should introduce a Charter of Farmers' Rights similar to that employed by Department of Agriculture Fisheries and Food in the ROI. This covers the detail of the various Departmental schemes including inspection arrangements, application procedures etc. and specifies farmer obligations and departmental commitments including payment timeframes.
- Regulatory Impact Assessments should continue to be used as a key element in minimising the administrative burden posed by new regulations. Before being submitted to the Minister, RIAs should be formally signed off by a specified Senior Civil Servant and should be open to review by the audit body within the DETI unit.