Examination of witness (Questions 40 -
WEDNESDAY 17 JANUARY
40. Do you see a role for the involvement of
(Mr Curry) Yes. Some farmers will be either unwilling
or unable to adopt the new technology and participate in this
brave new world. They must have the option of continuing to fill
in forms manually, if they prefer, or using a third party to do
the work for them.
41. Can you explain why they should have the
option of filling in forms manually?
(Mr Curry) There is a transitional period here. Initially,
they should still have the option to fill in forms manually if
they wish, but if they are unable to do it electronically they
should be encouraged to use a third party, an agency or whoever.
That raises certain other issues, such as electronic signatures,
delegated authority and so on, but those matters can be overcome.
42. We have been told that progress is being
made on the introduction of digitised mapping. You asked for the
work to be done urgently. We have had progress reports. Do you
think that they would fit with the expression "implementing
(Mr Curry) There has been some delay, but progress
is now being made. MAFF is about to go out to tender on the development
of a digitised mapping system, or GIS. Perhaps the word "urgent"
has not been applied as rigorously as it might have been.
43. Did you visit CTS?
(Mr Curry) Yes.
44. Were you impressed by the performance and
accuracy of the service?
(Mr Curry) It is easy to criticise. David Evans and
his team initially faced a very difficult challenge in building
the business from the start. There are still too many errors.
45. Did you not say in earlier evidence that
the Netherlands had attempted it a while back? Did you not give
that as an example of a particular process?
(Mr Curry) Yes. However, the delay in developing a
CTS system was not the fault of the National Cattle Data Centre
but the fact that Government did not invest money in the systems.
There are two different issues here.
46. I was concerned with a different point.
Did it not occur to you that at least part of a model existed
in another Member State?
(Mr Curry) Yes, and the same model existed in Northern
Ireland which had also developed a national cattle data system.
There was a recommendation by the Wilson Committee in 1992/3 that
the British Government should invest in a national cattle data
register. That recommendation was never adopted other than in
47. We have used the word "urgent"
and have heard your definition of that word. Do you think that
action by the British Government in this respect can be classified
as urgent in any normal meaning of that word?
(Mr Curry) No, because it was first recommended in
48. Do you believe that some reflection on other
models outside the UKyou mentioned the example of Holland
which you discountedmight have helped to improve the efficiency
of the establishment of CTS which was, though you have not said
it, plagued by error and waste at the start of its operation,
remains substantially inaccurate now and has dramatically exceeded
its budget cost? That is another example of British application
of technology to agriculture. We have just had a lengthy questioning
session on how technology might apply. One might think that our
reflection on learning processes in other areas would lead us
to be at least cautious about it?
(Mr Curry) There are two stages to this. One is the
establishment of the National Cattle Data Centre and the introduction
of passports and the provision of information about movements.
CTS, which was the complete cattle-tracing system, was implemented
this year. That should have been done a long time ago so that
we had a complete national cattle register in place. All other
Member States who moved when we should have moved have had to
replace their systems because technology has moved on. Both Northern
Ireland and Holland have replaced their systems, and we would
have had to do the same by now. We would have been in a much more
advanced, better position had we done it much earlier.
49. It is not just that. Perhaps we did not
look hard enough, or at all, at what other people had already
(Mr Curry) I do not believe that there was any lack
of knowledge as to what the system could deliver: there was lack
of willingness to invest the money.
50. And perhaps a lack of willingness to learn
(Mr Curry) I believe that it was a resource issue.
51. Does it concern you that the group which
advised on the technology and implementation of CTS also advises,
I believe, on the technology and implementation of CAPPA?
(Mr Curry) I was not aware of that. Once the decision
was taken, CTS was implemented quickly and efficiently this year.
(Mr Curry) Yes, I believe so. All the problems with
passports are a separate issue. The introduction of the CTS technology
this year has gone well.
53. Let us turn to records and inspections which
you mentioned earlier. Obviously, IACS has led to a big increase
in the need to keep records. Will standard herd and flock registers
be sufficient to make the situation better, or are further steps
possible to minimise the burden?
(Mr Curry) The national flock and herd registers were
an important first step in proving to the European Commission
that we had robust on-farm recording systems. Whenever we challenged
the number of inspections to which farmers were subjected the
retort was that there were so many errors on farm records that
we were being subjected to a higher level of inspection than would
otherwise be the case. If my memory serves me correctly, we are
subject to 10 per cent inspection which could fall to 5 per cent
if we had adequate systems in place. A first step, we believed,
was that farmers needed to improve their record-keeping to reduce
the number of inspections required by the European Union. The
second step is for those records to be held electronically, which
is a much more efficient way to do it.
54. With multiple records for different IACS
(Mr Curry) Clearly, it is a nonsense for farmers to
have to hold multiple records. That is an issue which Haskins
identifies in terms of the Environment Agency and environmental
schemes. The need for farmers to fill in multiple records for
their own mainstream agricultural support system is not so much
of a problem, but there is a cross-departmental issue here.
55. What about the co-ordination of inspections
about which you have had something to say in the report?
(Mr Curry) This is a very important area on which
we spent a considerable time. I said earlier that each individual
scheme had developed over time and carried with it its own compliance
and inspection requirements. The consequence of that was that
farms were being inspected for one scheme, another scheme and
then another scheme independently. We felt that there was a need
to co-ordinate all of that and remove the nonsense of regular,
frequent inspections on farms for separate schemes. One then comes
up against the problem of retention periods and the need for certain
inspections to be carried out during those periods. Therefore,
each scheme carries a separate retention period. All of that needed
to be harmonised, but with the development of CTS, with all information
being carried by it, it is much easier for inspections to be carried
out and rationalised than was the case before. All of the data
is held there. When inspectors visit farms they should inspect
everything on the farm when they are there, whether they be sheep,
cattle or IACS, without each individual enterprise being subject
to a separate inspection. We wrapped the role of local authorities
in inspecting cattle movements and medicine records in with our
recommendations that they too should be part of the reorganisation
56. Did you investigate differences between
the way that we and others carried out inspections?
(Mr Curry) As far as our investigation went, in Holland
and Ireland we did not detect a significant difference in the
way that the schemes were being applied.
57. They also had inspections on different schemes
by different people at different times?
(Mr Curry) Yes. The Dutch appear to have armies of
inspectors to visit farms, which is not regarded very favourably
by farmers in Holland.
58. Let us look at the appeals process, penalties
and so on. Is the level of comprehension of those who fill in
the forms sufficient because of the complexity to make this a
process that is fair and reasonable in view of the appeals that
all of us who have any involvement in this area know arise fairly
regularly which appear to be fairly bizarre? Is this all fair
(Mr Curry) We approached this from the point of view
that there is only one category as far as European auditors are
concerned: fraud. Any errors made on the part of the farming industry
in filling in forms comes under the category of fraud, which is
quite inappropriate. Clearly, we have led the drive to stamp out
fraud in Europe, which must be supported, but farmers are very
concerned about making a simple error that jeopardises the validity
of their claim, potentially exposing them to severe penalties.
It is against that background that we believe farmers should have
recourse to an appeals process if they feel that they have been
unjustly treated either through the interpretation of the information
supplied or mistakes made on their part.
59. There are two levels of appeal, are there
not? At one level someone telephones or goes to the Regional Service
Centre and there is a dialogue in which the farmer is told that
he should not have put a tick in one box but another. Presumably,
the impact is ratcheted-up if the official feels that perhaps
someone is deliberately gilding the lily and something must be
done about it. Can you explain where the boundary exists?
(Mr Curry) We envisage within the recommendation a
two or three-stage approach. Obviously, the first step is to appeal
to one's Regional Centre, if it exists, to report that something
is unfair or a mistake and to ask whether it can be corrected.
If it is a simple matter of ticking the wrong box or making a
mistake with a figure, that should be subject to rectification
fairly easily at the first stage process. If it is a more fundamental
error which may be deemed to be serious in its impact on the farming
business itself, and the individual farmer has not received a
satisfactory response from his first approach, we believe that
he must have the opportunity to take it further and have it considered
more carefully. The second stage could be an independent person
within MAFF with no historical involvement with the Regional Centre
in the filling in of the form, but the ultimate recourse should
be an independent panel, however that is defined legally, where
the case can be heard. The farmer should have the opportunity
of taking it to that stage and having the matter reconsidered.