Basic Payment Scheme Roundup June 23, 2015 12:00 am With the dust settling on applications for the Basic Payment Scheme in England there are some issues that applicants may want to consider for this year and the next. Amendments and Errors It is possible to amend forms with penalties up until the 10th July. But is should be noted that penalties only apply if the changes result in a claim being increased. Amendments reducing a claim can be made at any time without penalty, as long as they are made prior to an RPA inspection or before the RPA notifies the claimant of an error. Those who are now fretting about how they have filled the BP5 form in can take a little comfort. The information is being inputted manually rather than being scanned. So as long as the intent is clear to the human being doing the inputting, the data should get through. In addition, the phrase ‘pragmatic approach’ is being used in policy circles when it comes to processing this years claims. Entitlement Transfers There were a large number of RLE1 forms submitted to transfer entitlements ahead of the 15th June deadline. This means that receipts for the transfers have been slow in coming. It may be the end of July before these are all dispatched. There is no need to wait for any ‘window’ to open to transfer entitlements, this can be done right now. The RLE1 form is continuing to be used for this, pending any change in the transfer system. In reality, with entitlement confiscation occurring on excess entitlements in 2015, transferees might want to wait to see a 2015 entitlement statement (or whatever replaces it) before transferring. A reminder that a transferee has to be an Active Farmer. This should be no problem for transfers within the 2015 calendar year as the declaration entered onto the 2015 BPS form is likely to apply. For transfers post-1st January 2016 some sort of Active Farmer certification might be required. ‘Accountable Persons’ Some may recall that the issue of ‘accountable’ persons’ loomed up during the BPS application process. This was a request (soon rescinded) by the RPA that all people involved with a business had to provide information. This was name, address, National Insurance number etc. It seems that this issue has not gone away. This information may well still have to be supplied before payments can start at the end of the year. BPS Run-Off Claimants should remember that, now the forms are in, it is not just a question of waiting for the money to arrive. Certain conditions for receiving the BPS still need to be met; any land claimed must remain in agricultural use (especially relevant where there are utility works, or land is going for development) cross-compliance is a whole-year requirement any cover or catch crops used for Greening need to be planted where buffer strips have been used for Greening these need to be kept in place for the whole calendar year (i.e. don’t plough them out in the autumn). The same applies to hedges used – don’t rip them out those that have used the derogation to record new PIFs on the BP5 form, but did not fill out an RLE1 will need to do so before September Payments The big question for many is when payments under the 2015 BPSwill arrive. Despite George Eustice’s comments that the ‘majority will be paid in December’ and the ‘vast majority will be paid by the end of January’ we would be more cautious. We still believe that budgeting for payment in March is prudent. The funds may arrive before then – it is probably likely that a good chunk will be issued in January. But we would not base business plans on this. Stakeholders are pressing DEFRA and the RPA to be honest about the payment timetable rather than sticking to a line that everything is OK (as was the case with the computer system). BPS 2016 Many will not want to think about the BPS for a few months. However, thoughts are now turning to what might happen for 2016. Despite the presumption of many, it may not necessarily be the case that the abandoned Rural Payments computer system will be dusted-off and a final push given to get it workable. It appears there are fundamental flaws with how the Rural Payments ‘interface’ communicates with the SITI Farmer background system. The most likely outcome for 2016 is that both an online and paper application will be offered (i.e. no digital by default). The presumption would be that the majority of applications would be online with paper only being a fallback next year. What the online system will be is unclear. Rural Payments could be resurrected. Some minor tweaks could be made to SITI Farmer and this opened to all for online applications, or a new (less ambitious) customer interface could be built on top of SITI to allow claims to be made. Greening 2016 There may be some minor changes to the English Greening rules for next year. DEFRA have to tell the EU Commission of any proposed alterations by the end of July.
