Back to HOMEPAGE
Jobsworth RPID officials describe grass
grown for silage or hay as "unused" because
it was not cut when they came to inspect
the farm and because they did not
bother to ask.
James Irvine
Cultybraggan Farm, Comrie, Perthshire
Filed 23 July 09
©www.land-care.org.uk
As part of the Less Favoured Area Support Scheme (LFASS) the Rural Payments and Inspections Directorate (RPID) at Perth announced that they were going to carry out an inspection of my farm, Cultybraggan Farm, on 19th June 2009. In fact their inspection for LFASS and other schemes continued from the 19th to 24th June. Whether this involved one official or more than one is uncertain. Their inspection was aimed in part at redefining land areas that had previously been established by the same department (but then called Scottish Executive Environment and Rural Affairs Department) four years previously. Essentially, neither the geography nor the use of the land had changed in the interim. Were they really going to find sufficient differences which would justify the public expense involved? Or was this simply an exercise in trying to reduce the amount of subsidy paid to farmers?
It was subsequently explained to me that this exercise was to remove such things as burns from their new format of assessment. And to check up on whether their colleagues from the same Department had made any mistakes in their previous assessment.
The name plate for the government offices at Broxden, Perth
where the Rural Payments and Inspections Directorate
for the area resides.
Photo©Kimpton Graphics
They also were carrying out the inspection to see that the new guidelines for LFASS payments were being complied with, although few people (if any) knew what they were with any precision. The emphasis was to be on "active farming", which is plausible enough, but only so long as the farmers in Less Favoured Areas and the government's inspectors know what the criteria are. Another essential ingredient is that officials when applying such criteria can use some basic commonsense.
But lack of commonsense is a characteristic of the Jobsworth official, as so ably described by Magnus Linklater in his brush with a City of Edinburgh parking official (1).
I also subsequently learned that the RPID was to be visited by a team from the EU authorities to see that the UK was complying with EU Directives etc. May be that was the explanation for the avalanche of gold plating that was duly applied to their inspection of Cultybraggan Farm and possibly other farms.
When informed of the inspection I asked if I could be of any help should they wish any information. My offer was ignored. They already knew how to contact me by phone or by email. I received, nor was sent, any enquiries whatsoever. from the officials.
The full brief for the inspection was to carry out
"SAF, LFASS & SEPA Diffused Pollution & Engineering Regulations inspections at Cultybraggan Farm".
SAF stands for the Single Application Form that incorporates the previous Integrated Administration and Control System (IACS). SEPA stands for the Scottish Environmental Protection Agency.
The inspection would include assessment of any land management contracts or options. As none were considered to be of any value to the farm, none had been applied for or were in operation. That is apart from £40 rebate with regard to the Cattle Quality Assurance fee paid to Quality Meat Scotland - a government quango. This shifting of money from one aspect of government to another would probably cost the government in administration at least as much as the sum that the farm received. But it allows the government to claim that its Land Management Options were taken up by a large number of farmers.
It would be pretty obvious that no SEPA regulations were being broken as the farm is not in a Nitrogen Vulnerable Zone and tries to be as environmentally aware as feasible. The Farm had declined to pay the fee of £500 now demanded by SEPA for a licence to enable the Farm to continue to take a modest quantity of stones, at the appropriate time, from the part of the River Ruchil which the farm owns. This would have enabled the practice to be continued of replacing the bottoming of the one of the cattle courts. In my view the Farm has looked after the River over the past 20+ years far better than the Roads Department of Perth and KInross Council and its botched flood prevention manoeuvres (2).
Since there were no engineering works on the farm, this inspection exercise would boil down to a reassessment of field sizes using GPS technology, checking that the land was in "good agricultural condition" (compliance) and assessing whether the land was "in active use".
Two RPID officials came to the farm by appointment to report their findings on Wednesday 15th July. One was a Higher Agricultural Officer and the other was an Agricultural Officer. The only information I was given as to the purpose of the meeting was stated as follows:
"To complete the inspections I need to see the documentation for the seasonal let land entered on SAF 2009 application for farm code 275/0178, field NR/91818/47136. Also the Cattle movement records for the years 2008 & 2009. There are various inspection proformas to be completed and signed."
what did they mean by "inspection proformas to be completed and signed"? The RPID gave no advanced warning of what these proformas contained. If they had, I might well have ensured that I too had a second person with me before I agreed to meet them.
"Are you letting out the farmhouse?"
The first comment that one of the officials made was to ask if the farmhouse was being let out. Why was he asking such a question? I asked if that was part of the remit of his inspection. It was not. So why was he asking it? Was he and his colleague on a mission to try and establish that the farm was not "active"?
Documentation regarding lease of land and cattle movements
These were provided and accepted. But I did point out that these could have been sent direct to the RPID by internet at any time. They responded that many farmers do not have internet or did not use it. Before completing my SAF form for the current year, I had checked that the cattle retained on the farm more than met the minimum stocking density required for LFASS payment.
Reduction in size of eligible land
It seemed to me that most of this exercise consisted of gold plating and nit picking. Apparently burns now had to be deducted. The proportion of the land area to which burns contributed must be very small. Was this really a productive and cost efficient exercise involving so much government officials' time?
Then I was told that a previous assessment made by the same department - but under another name - was wrong as to where a fence was recorded. I was invited to view this on a pathetically small and barely readable screen on a laptop computer that the officials had brought with them. They had not taken the trouble to print out clearly where the problem was and expected me to agree with it without the information being presented in a competent and professional manner. Estate agencies and lawyers can do it. Why not the massive organisation of the Rural Payments and Inspectorate Directorate?
So the officials reckoned that they managed to deduct some 10 hectares or so as being not eligible for subsidy payment. I was asked to agree there and then, having been presented with quite inadequate information, either at the time or prior to the meeting.
Most of the grassland is "unused"
Then the officials went on to declare that most of the grassland was "unused". They said I would not like what they had to say, and they were right - I did not. Because such a statement was unjustified.
A field of grass with the end rigs cut and baled for silage.
This photograph was taken on 12th July 09. The RPID officials came to the farm
between 19th and 24th June and described the field as "unused"
They would not change their classification when they reported
their findings on 15th July.
The aim is to try and make hay from the remaining grass when the weather permits
(To enlarge photo Click Here)
Photo©Kimpton Graphics
When the RPID officials did their inspection between 19th and 24th June none of the silage or hay fields had been cut. So instead of asking me what they were going to be used for, the officials designated the fields as "unused". Worse, they refused to alter their assessment when they presented their findings on 15th July. They could not avoid seeing that the fields had either been totally cut or had their end rigs cut when they approached the farm from whatever direction in their car when coming to the meeting on the farm on 15th July. There were two officials. One of them could have been looking out the window. Or they could have stopped the car for a moment and had a look out the window. Or they could even have got out of their car to have a look.
Wrapped baled silage in a field classified by officials as "unused grass".
This would have been obvious from the roadside when they came back to the farm on 15th July. The above photograph was taken on 12 July 2009.
(To enlarge photo Click Here)
Photo©Kimpton Graphics
May be they thought that the silage had been sold to someone else. They did not ask. When they were invited to look at the silage area close to the steading where the wrapped silage bags were stacked, they refused although it was only a short walk away. When the officials were invited to phone the local contractors who had been helping with cutting, baling and wrapping the silage and helping to stack it on the farm, they refused. If they had done, they would have had confirmation concerning how the "unused" grass in the in-bye silage/hay fields was to be managed. And how the "unused" grass on the hill areas were to be used.
Big Boy (formerly known as Ulysses) eating up the grass in another "unused" paddock.
He was assisted by fellow bulls and bullocks, They made pretty short work of it and
will shortly be heading off to another "unused " area of grass.
Photo©Kimpton Graphics
Most of the suckler cows on the farm are autumn calvers. They are presently on fields with relatively easy access to the steading, in order that assistance with calving and care of the calves is made as easy as possible. Furthermore, the amount of grass on these fields is currently much more modest than the "unused" grass on the hill areas. To put cows that are close to calving on to rich grass would invite having big calves and calving difficulties. After calving, the cows and their calves will be shifted to the hill areas. All the land will be used. They will eat the grass down more effectively that a grass topper in these rougher areas.
The field (known as Eaglesfield) classified as "unused by the RPID officials yielded
a useful number of silage bales on 21st July. The weather did not allow haymaking.
Photo taken on 21st July 09
To enlarge photo Click Here
Photo©Kimpton Graphics
The RPID officials appeared uninterested as to how the grass was to be used and what the management plan was. They simply emphasised that they would be back to see that it had been "used". What met their criteria of being "used" was not explained.
While Cultybraggan Farm is thankfully not in any scheduled conservation area, it is ironic that if it had been it would not have been allowed to cut grass for hay until August 1st. Recording standing grass, that is scheduled to be cut for hay or silage as weather permits, as being "unused" in June on a conventional Scottish upland farm is absurd.
Injurious weeds
The next criticism presented by the RPID officials was that there were too many injurious weeds when they inspected between 19th and 24th June. They were not prepared to look at the fields when they revisited on 15th July.
This illustrates the flowering stage of thistles that were topped July 12th - 17th.
The RPA made their report on19th to 24th June. The stage illustrated is the
correct stage to top thistles if you wish to dissuade them from returning
next year in the absence of weed killer.
This photograph was taken on 17th July.
To enlarge photo Click Here
Photo©Kimpton Graphics It is common knowledge that the optimum time to top thistles is when they are flowering and before they spread their seeds. The adjoining photograph shows the condition of the thistles when they were being topped between 12th and 17th July. It would seem to me that the thistles were being topped at the ideal time and that the RPID officials criticism was unfounded. It was also, in my view, regrettable that they simply refused to look at the grassland that had been topped, insisting that they had to stick by their report as per 19th to 24th June.
Topping of thistles at the optimum time as described above has the addition environmental value in supporting insect life: such as the all important bees that are currently under serious decline (3). Bees are essential for the pollination of many species of plants, including crops.
A bee (and a wasp) enjoy the remaining flowering thistles on
Cultybraggan Farm on 21st July 2009.
The field is rich in glover, that has the great merit of fixing nitrogen from
the atmosphere and incorporating it into the soil.
To enlarge photo Click Here
Photo ©Kimpton Graphics
Cultybraggan Farm is not an organic farm. According to the Food Standards Agency there is no substantive evidence that organic food has any better nutritional qualities than food derived from conventional extensive hill farms such as Cultybraggan, There is also no substantive evidence that animal health and welfare is any better (and could be worse) on farms classified as "organic" compared to that on conventional Scottish hill farms.
Avoiding the unnecessary use of weed killers to control thistles by topping them at the appropriate time is not the prerogative of organic farming. It has been practiced by conventional farmers long before the term "organic" was usurped by such bodies as the Soil Association. The practice has the additional advantage of promoting the all important bee population (essential for the pollination many plants including crops) and preserving the growth of clover in grassland (an important binder of nitrogen from the atmosphere into the soil). Weed killers aimed at the control of thistles and dockins may have the undesirable effect of killing the clover.
My reaction to the manner in which the RPID officials conducted their inspection
I felt that the officials had failed to adequately discuss the farm's management plan when they did their inspection on 19th to 24th June. Not only was all grass going to be used for the benefit of the livestock on the farm, but the injurious weeds were topped where feasible at the appropriate time, which happened not to coincide with the date of their inspection.
I believe the officials did much harm to the farm by their conduct, causing unnecessary stress and undermining confidence in the Department (sorry, Directorate) of which they are members of staff.
Gone are the days when one could look to the offices at Perth for advice or guidance. Now they are simply regarded as the equivalent of traffic wardens with a similar jobsworth attitude. Their job is to issue penalties, rather than be helpful. Who knows, they may be on a bonus scheme for imposing a target number of penalties, and another for reducing the number of hectares of land eligible for farm subsidy.
By failing to discuss the farm management plans at the time of their inspection, I believe they also caused considerable waste of public money.
The officials asked me to sign their "proforma" report which they had refused to alter in the light of what I had explained to them. As I was unhappy with the report they offered that I could say why in a small area of the form. Clearly that was not adequate from my point of view.
As we seemed to have reached an impasse I offered that they should give me a copy of their report and that I would send it to Pentland House (the organisation's HQ) together with an explanatory letter from myself as to why I wa so unhappy with their report.
The officials then agreed to add a comment themselves that
"Dr Irvine had explained the farm management plan".
But one can have little faith as to how the officials would use such a statement as they had seriously undermined trust.
The next day, the 16th July, I complained, in the first instance by telephone, to the head of their department (sorry, Directorate) at Perth. At first he suggested that in due course I could lodge an appeal - yet more bureaucracy, yet more expenditure of public funds. Then he agreed to look into the matter and to come and see me on the farm at some time in the future to be arranged.
Visit to RPID offices at Perth on Friday 17th July
I called at reception at the RPID Perth Offices to ask for any leaflets that may be available concerning "Active Farming". The only literature they had was published in 2007
"Rural Payments and Inspections Directorate: LFASS 1007 - 2009. Explanatory notes"
I was already familiar with that publication. I mentioned that I thought that new regulations had just recently been established, and that was the purpose of my visit. I was informed that the above publication was still valid. If I wanted to look for new announcements I should look on the internet. I mentioned that many farms do not have the internet or broadband to go with it. In that case I was told that I should consult my adviser, such as the SAC or other independent advisory source (i.e. I would have to pay for it as RP|D were not going to tell me even when I presented myself at their offices). But I suspect they did not know.
On reading the RP|D LFASS 2007 - 2009 document again I note it to say in Para 4 on page 7
"To be eligible for payment of LFASS you must co-operate with inspectors and give reasonable help during any inspection"
Unfortunately the inspectors did not ask for any help although help was offered. As a result they produced a seriously misleading report.
Comments by my SAC adviser
I related my experience to my SAC adviser. He agreed that
a question as to whether I was renting out the farmhouse was inappropriate,
19th to 24th June was too early to make any comments about grass being unused,
the officials should have discussed any concerns they had about the use of grass at the time of their inspection and before writing a report,
my comments about the optimum time to top thistles are justified,
I was making a reasonable request to see a clear, printed map of the changes in part of the fence boundary of the farm as claimed by the officials.
I had done the right thing in reporting my concerns to the Head of the Regional Department in Perth in the first instance.
Conclusion
Suckler herd farming in Scotland's uplands is currently in a dire state (4), with suckler cow numbers falling to dangerously low levels. A display of such over burdened bureaucracy from a department of the Scottish Executive is about the last thing that is needed. When hill livestock farms are so desperately short of skilled manpower, as well as funds, it is galling to experience so much unnecessary, gold plated bureaucracy delivered with such thoughtlessness.
©www.land-care.org.uk
References
1. Linklater, Magnus (2004). Me 1, mindless bureaucracy 0
See SOCIAL/ECONOMIC/POLITICAL Homepage, filed 14 Sep 04, www.land-care.org.uk Click Here to View
2. WWF (2002). Opening the flood gates. Click Here to View
3. Campbell, Matthew (2009). Nicolas Sarkozy’s new pet is minister of the birds and bees
The Sunday Times 19th July 2009 Click Here to View
4. Irvine, James (2009). Lloyds TSB Farmers' questions and answers: Royal Highland Show 26th June 09
See HOMEPAGE. filed 29 Jun 09, www.land-care.org.uk Click Here to View
Finis
|
