In this blog, the NFU's senior BPS adviser, Richard Wordsworth, explains why BPS 2019 is about much more than the application and payment dates. Here's a rundown of what you need to be aware of over the coming months.
We have now passed the last date to submit or, for most situations, amend a BPS 2019 application form. (NFU members can get more information on the process of amending an application here). However, there is always something to consider at this time of the year when it comes to BPS, cross compliance or greening.
Below are some timely reminders. As always, if you have any questions, contact NFU CallFirst on 0370 845 8458.
Now - greening obligations
It is nearly a month since the 15 May BPS application deadline which also included your declaration on how you were complying with greening. Of particular importance at this time of the year is remembering to establish eligible EFA catch or cover crop mixes in the coming months to comply with that declaration. Dates for these and other greening measures are set out below:
- 1 May to 30 June 2019: Period for RPA to check crop diversification, fallow and EFA nitrogen fixing crops.
- 30 June 2019: EFA fallow rules in the main remain in place to this date (such as the ban on the use of plant production products or most cultivations).
- 20 August 2019: 2019 EFA catch crops must be established by this date. Establishment means the crop is covering the ground.
- 1 October 2019: 2019 EFA cover crops must be established by this date. Establishment means the crop is covering the ground.
For more information, please refer to our recent member briefing on these 2019 EFA options.
Before mid-July - hedge/tree cutting derogation
Next up, as you know this is a time of the year when there is a cross compliance restriction on cutting or trimming hedges and trees (which runs from 1 March to 31 August). A few years ago the NFU successfully argued for a derogation from these rules which allows some flexibility on cutting hedges/trees for those sowing oilseed rape or temporary grass in August. In order to use this derogation you will need to apply to the RPA and wait for approval before carrying out any eligible cutting. To avoid waiting in August for RPA approval to come through, you can apply now. Read our guide to this process.
Before September - field boundary management
We always get a lot of questions at this time of year on when someone can trim field margins (not trees or hedges). Read our briefing for members which covers considerations prior to trimming any field boundary.
Irrigation: If you irrigate crops please make sure that you are complying with your licence conditions given that such activity is covered by cross compliance. Here's a reminder briefing.
Keep an eye on changes: This short guide will help you remember the rules on when land claimed for BPS 2019 could become ineligible and would need to be withdrawn from your 2019 claim to help avoid any problems if you are inspected this year.
Inspections: Remember that as soon as BPS claims are submitted to the RPA, inspections start. If you are inspected, please remember the following points:
- Obstructing an inspection can lead to the cancelling of BPS and other CAP payments.
- Inspectors record what they see. They are not the ultimate decision maker when it comes to any sanctions being applied. Do not assume the outcome will be positive as inspectors try to avoid confrontation and will play down issues.
- Remember cross compliance breaches can impact on non-BPS schemes covered under CAP.
- Refer to your application or the scheme rules as these are what you are being checked against.
- Seek help if you are asked things you are not sure about.
- Record what is said by who and take photos/measurements at the time of the inspection for future reference. The official outcome from an inspection may not come for a number of months and evidence can disappear in the intervening time.
- Be aware there is a complaints and appeals process in place if you have any issues post inspection.
That's it for now. While I have covered current scheme issues here, the NFU's BPS team continues to assist members who have ongoing payment problems from previous years. Just like on farm, there is never a quiet time here at Stoneleigh. If you have any queries, please contact NFU CallFirst on 0370 845 8458.