Dr. Shane Whelan:

I will not dwell on the point regarding force majeure and the restrictions in that regard because it has been very well made. It is imperative that the new appeals system is set up to deal not only with the existing operational model, but also with what we are moving towards. AMS has been referenced previously. The appeals system there is based on a formal decision being made. It also needs to take account of the eligibility and identification of individual farmers where a formal decision is not made. I will use the Shannon Callows by way of example. There is a cohort of farmers in that area who never received a formal letter. Their viewpoint is that the AMS set up to identify eligible farmers did not pick up all eligible farmers. There are close to 50 farmers there whose land was flooded and whose fodder was impacted but who did not receive a formal notification. What I am pointing to is that the system needs to look at cases where formal decisions were not made.

The new world we are living in is parallel to the world farm planners and advisers operate in. A farmer cannot be penalised because of the increased workload of a third party. ACRES is again a case in point. There are multiple examples of farmers missing out on tranche 2 applications because of workloads, moving timelines in respect of TAMS II and planners devoting attention to that scheme rather than focusing on ACRES. The TAMS deadline was pushed out but farmers were penalised because submissions were not in on time. With regard to the submission of scorecards in respect of ACRES, the farmer cannot be penalised where that submission is not made in time. I will reiterate the point that the appeals system needs to be set up for what is coming down the tracks and farmers cannot be penalised.

I will quickly return to a point the Deputy made earlier with regard to simplification. That is central. All farm organisations are consistently of the view that because we are in a very complex and bureaucratic world, there is most certainly a need to simplify. Again pointing to ACRES, the proactive communications proposed by the IFA would alleviate a lot of anxiety, ensure greater compliance and minimise pressure on the appeals system down the road. I consider that important.