5 May 1995

Errors equal cash loss

Common IACS mistakes can lead to serious financial penalties for growers. Francis Mordaunt, head of the research department at Andersons Farm Business Consultants, points out some of the most likely errors

Set-aside eligibility

A classic and potentially enormous error is to confuse the eligibility of a field for arable area payments with its eligibility for set-aside. For fields to be eligible for set-aside, they must not only be on eligible arable land, but must also have been farmed by the applicant for the previous two years and have had a crop grown with a view to a harvest in 1994.

For six-year rotational set-aside, the field also must not previously have been in AAPS set-aside. One obvious error is to put a temporary grass field into set-aside. A less obvious mistake often occurs where part of a field was in game cover the year before but the whole field is entered for set-aside the following year. Game cover is not grown with a view to a harvest and is therefore not eligible.

Set-aside width

To make a set-aside strip exactly 20m along a field margin is extremely difficult. Farmers may cultivate the field leaving a strip of what looks like 20m but because of a bulge in the hedge it may not be 20m at all points.

On inspection this would result in some areas being disallowed. Another common error is measuring the 20m from the field boundary and not from the edge of the normal cropping margin. Although you can claim a whole field as set-aside and include normally uncropped field margins, 20m strips must be measured from the edge of the cropped area.

Crop failures

Crops on which area payments are claimed must be taken to flowering or, for oilseed and linseed, to certain dates. If they fail before this stage and are not resown, the farmer must notify the local Reg-ional Service Centre and reduce the IACS claim. Otherwise the areas could be disallowed on in-spection and could mean penalties.

This is especially serious on set-aside where a non-food crop is being grown. If the non-food crop fails and the farmer does not notify the RSC and the processor of the crop, then the area of set-aside may be disallowed on inspection, which would reduce the area paid on other arable crops.

Game cover strips

Where a farm has game cover on set-aside and runs a commercial shoot, MAFF could consider this a lucrative use of set-aside. This would definitely be the case if there was no other game cover on the farm and especially if there were rearing pens on the set-aside.

But the situation is less clear where there is game cover on other areas of the farm, and the farmer can demonstrate that no additional income has been gained by having game cover on the set-aside. When in doubt it is not worth the risk of set-aside being disallowed.

Codes in MAFF IACS booklet

This year MAFF has an endless list of different crop codes to be used in the Field Data Sheets. Not only would you need a microscope to read the small print of the code list, but they are also confusing.

For example, those growing field beans have a bewildering choice of codes BE1 to BE7, which includes "Field Beans" (BE3), "Broad Beans" (BE7), and also simply "Beans" (BE6). In most cases it is easier to write the crop out in full, as use of the codes is not compulsory.

Reallocating field numbers

The requirement this year for single field numbers for all permanently divided or amalgamated fields has caused headaches for many farmers. MAFF also wants new numbers for fields straddling more than one map sheet and fields starting or ending with a "OO".

On many farms with large fields this can mean almost all field numbers have to be reallocated and entered on a new Field Data Sheet, increasing the scope for error.

Mistakes on the IACS printouts

It is up to the farmer to check the accuracy of the Field Data Print-outs and most contain at least some errors. The most common seems to be where a field contains both ineligible and eligible land. This will either be entered as all eligible or all ineligible, and so it is important to cross-check fields with the 1993 application.

Home-saved oilseed

Home-saved oilseed must be from the applicants own farm. A common mistake is when growers use seed saved not from their own holding but from that of a contractor. The glucosinolate test will show which holding the seed came from, so if it is different from the one on which the crop is being produced, MAFF is likely to notice and may not pay the subsidy.

Separate IACS applications for farms which are effectively one business

MAFF is clamping down on separate IACS applications for farms which they consider are part of one business. Even if the farms are run separately in terms of accounts, labour and machinery, the key test is where the overall economic control of the business lies. If MAFF insists on a single application this could create problems where:

lOne farm normally applies under the General and one under the Simplified Scheme.

lWhere different set-aside options are being followed.

lWhere both farms are claiming beef special premium up to the headage limit.

lWhere one farm claims suckler cow premium and the other has a dairy.

The scale of IACS penalties

IACS penalties quickly build up even for small errors. Penalties are calculated individually for the five crop groups – cereals, linseed, oilseed, proteins and set-aside (CLOPS). The way penalties work means that if an area of more than 16.67% is disallowed, this wipes out the claim for that group. &#42