Many of you will have completed and submitted, no doubt with a sigh of relief, the 2007 SP5. I anticipate that many of you will have been frustrated by the fact that the pre-populated form was not necessarily that. The Council Regulation governing the SPS states that “a Member State may decide that the aid application needs to contain only changes with respect to the aid application submitted the previous year. A Member State shall distribute pre-printed forms based on the areas determined in the previous year and supply graphic material indicating the location of those areas…”. The idea (and ideal) is that if nothing has changed from the one year to the next, the pre-population should mean that all one has to do is sign and date the form and the application will be complete.
As ever with the SPS the ideal is somewhat removed from the reality and, virtually without exception, no pre-population has been 100% accurate. In one example a farmer with over 100 parcels had column C10 (area to be used for activation) pre-populated in all cases bar one field on 10ha. No reason but had this not been picked up there could have been a loss in excess of £2000.
In addition to the above, discrepancies have appeared between the 2006 data and the 2007 data resulting in the majority of SP5’s that I am aware of being accompanied by covering letters.
As I have said before, the SPS depends on the base data (2005) being correct. RPA is under a legal (and fiscal) responsibility to get it right. You will have read in the farming press about the possible disallowance (fine) being imposed by the Commission as possibly being in excess of £300m. Until RPA gets the data, and controls, right, this figure could be added to. Therefore RPA has no option other than to work through all discrepancies/anomalies
If you are over or underpaid, RPA has to recover or make good those payments. Under European law that could occur up to 8 years after the original “mistake”. Therefore the message is that if you think that the data that RPA is operating on is incorrect, tell them and do not give up.
In the meantime – good luck!